Katie (Wren) Busse, MS,
Registered AMFT



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May-June 2020

Ethics Committee Chair — Katie (Wren) Busse, MS, Registered AMFT

Telehealth: Before Your First or Next Session

Broadly speaking, telehealth is typically phone or video contact in which you’re providing psychotherapy services to a client in a different physical location from yourself. When conducting telehealth sessions, several steps need to be taken to ensure the client has been adequately informed and you are engaging in best practices for providing quality care.

Before your first telehealth session with a client, provide an informed consent specific to telehealth. This can be included in your usual informed consent or as a separate document but should also include your license or registration type and number. Obtain and document the client’s consent to the use of telehealth for therapy services verbally or in writing (in addition to the consent of applicable guardians). Inform the client of the risks and limitations of therapy conducted through telehealth (16 CCR 18). This includes technical failures (it may be helpful to outline how to proceed should this occur), limits to confidentiality, clinical limitations, and reduced availability of the therapist in the event of a crisis (CAMFT, 2011, Sec 1.4.2). Document reasonable efforts made to obtain contact information for relevant resources, such as emergency services near the client’s current location (16 CCR 18). This may include suicide prevention hotline, psychiatric mobile response team, local hospital, etc. Finally, ensure that you use a HIPAA compliant software for telehealth. Oftentimes, you will need to obtain a Business Associate Agreement (BAA) with the video software company to fully meet the standards for HIPAA. The preceding steps only need to be taken at the onset of telehealth services, however, identifying relevant emergency services may need to be reviewed should the client change locations.

Unlike the previous sections, you need to take the following steps at the start of each and every telehealth session you have with a client.

  1. Verify that the person you are speaking with is the client by verbally obtaining and documenting their full name.
  2. Obtain and document the address for the client’s current location (16 CCR 18). This address is used to confirm that the client is currently located in CA and so that in the event of a crisis, you know where to send emergency services. Note, the client must be located in CA at time of service, however, they do not have to be CA resident. You can practice therapy in other states, but you need to check with the licensing board to see the requirements for that specific state. It’s best not to assume that your license will automatically transfer or that you have a “grace period” because your client is just “passing through.”
  3. Assess if telehealth is appropriate for the client (16 CCR 18). A client’s needs and mental health can change from each session and should continually be assessed (CAMFT, 2011, Sec 1.4.2).
  4. Use best practice for telehealth that ensures client’s confidentiality and security of the telehealth software (16 CCR 18). Consider researching the platform's security and privacy protocols with an emphasis on ensuring that stored and transmitted data is encrypted. Also, it is important that your computer is up-to-date and secure to ensure that private data is not compromised.
  5. Document all of the above information in the client’s file.

    Note: Failing to comply with the regulations regarding telehealth at the onset and subsequent use of telehealth can be considered unprofessional conduct (16 CCR 18).

    Disclaimer: The preceding article does not constitute legal advice. Always consult with a CAMFT attorney or another legal professional for any legal or ethical questions you may have.

    California Association of Marriage and Family Therapists [CAMFT] (2011). CAMFT Code of Ethics. Retrieved from https://www.camft.org/Portals/0/PDFs/AssocDocs/CodeOfEthics.pdf?ver=2019-06-04-093935-577.

    Board of Behavioral Sciences [BBS] (2016). Order of Adoption for Division 18 of Title 16 of the California Code of Regulations [16 CCR 18]. Retrieved from https://www.bbs.ca.gov/pdf/regulation/2016/1815_ooa.pdf.

Katie Busse is a Registered Associate Marriage and Family Therapist 111673 in private practice under Kent Toussaint, LMFT 44685 at Teen Therapy Center in Woodland Hills. She works with preteens to adults and their families in addressing challenges such as anxiety, depression, anger, and family conflict. Learn more about Katie by visiting her website at www.katiebussetherapy.com. She can be reached at 747.217.2257 or katie@teentherapycenter.org.

San Fernando Valley Chapter – California Marriage and Family Therapists