About this episode
In this episode, our guest is Arielle Miliambro, a Partner specializing in regulatory and transactional law within the Healthcare & Life Sciences departments. She assists clients with legal issues related to telehealth, data privacy, value-based care, and fraud compliance. She offers counsel on regulations like the Anti-Kickback Statute and prepares requests for OIG Advisory Opinions.Arielle also guides stakeholders in telehealth and digital health models on fraud, corporate practice, and virtual care requirements. Additionally, she advises clients on data security and privacy issues, including HIPAA compliance and data breach response. She works with providers to develop value-based care and alternative payment models.Her expertise extends to pharmacy clients, whom she advises on remote prescription processing, compliance, and licensing board matters. She also assists practitioners with in-office dispensing and scope of practice concerns. Furthermore, Arielle supports clients with corporate transactional matters, drafting various legal agreements and documents.Telehealth Topics for PodcastWhat is the difference between telehealth and telepharmacyPharmacy role in bigger picture of telehealth modelsConsiderations for kickbacks/fee splitting in telehealth models depending on pharmacy’s reimbursementPharmacists duty to validate script prior to dispensingTelehealth “red flags”Where does the line get drawn as to pharmacist’s obligations with respect to the actual patient encounter between prescriber/patientCovid changesStateLicensing flexibility for prescribersScope of practice of pharmacistsFederalTelehealth reimbursementDEA prescribingHistory / status of new rules related to CDS prescribingTelehealth vs Telepharmacy DifferencesBrief overview distinguishing the definitions of each:Telehealth: Remote provision of clinical careTelepharmacy: Remote provision of pharmacy services (e.g., offsite pharmacist doing DUR, offering patient counseling)Changes in Telehealth During CovidFederal and State WaiversDEA waivers (current through 2025)Physician licensing waivers by state (expired)Modality flexibilities (mostly expired; some extended/made permanent depending on payor)Pharmacist Obligations in Validating Telehealth PrescriptionsPharmacist obligations/duties
