Distance Counseling and Supervision. Группа авторов

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Technology

      The risks and benefits of using an online modality should be outlined in the informed consent. Risks include the possibility that the technology could malfunction in the middle of a session, the fact that the counselor cannot guarantee privacy or complete confidentiality, and the fact that several safeguards will be in the hands of the client. Benefits include greater accessibility and convenience.

      Social Media Policy

      It is recommended that all informed consent documents outline the clinician’s policies on the use of social media, as it is a ubiquitous form of communication in modern society. Counselors should outline the appropriate use of social media, especially if they maintain any kind of online presence personally or professionally. Therapists should outline how friend requests and other types of social media outreach will be handled as well as whether they are comfortable with websites that rate therapists. Counselors must make it clear to the client that personal virtual relationships with clients are forbidden by the ACA Code of Ethics (ACA, 2014) and clarify how contact is typically handled when they and their clients occupy the same virtual space.

      Emergency Procedures

      It is imperative that a plan be created for emergency procedures. Online counseling relationships must begin with the possible ends in mind. Clients should identify where they are physically located at the beginning of each session and should provide emergency contacts within a 5- to 10-minute radius who will be available in the event of an emergency. In addition, there should be a record of the closest emergency services (fire, ambulance, police). The more fragile the client, the more comprehensive the plan must be.

      Anticipated Response Times

      In an age when the public has grown more comfortable with 24/7 availability and service, it is important for counselors to identify when they are and are not available and how quickly they will respond to clients. An alternative plan should be in place for times when the counselor is not available.

      Cultural or Language Differences

      It is important that counselors in a digital age recognize the potential for serving a larger population. Language and cultural differences should be clearly articulated. If a translator will be used, this should be outlined in the informed consent. Additional releases may be required.

      Insurance Coverage and Billing

      It is important to note that many third-party billing providers handle distance counseling or online services differently than they do face-to-face sessions. It is imperative to disclose when rendered services incorporate technology to ensure that billing is appropriately pro- cessed. Preapproval should be explored with insurance or other billing entities, and a backup plan for payment should be made with the client in case billing is declined.

      License Number and Licensing Board Information

      As they might do for face-to-face services, counselors might include their license number and contact information for their licensing board and credentialing sites in the informed consent.

      Notes and Documentation

      Counselors should be aware of the guidelines for documenting communication with clients. Some licensure boards or state laws require that all communications, including emails and/or texts, be included in the client’s record. Counselors should consider how these communications should be included in the client’s counseling file and outline those procedures in the informed consent (ACA, 2014; AMFTRB, 2016; NBCC, 2016a, 2016b).

      CNA and Healthcare Providers Service Organization (2019) offered the following list of risk management recommendations to counselors who engage in telebehavioral health services:

       Gain the necessary skills before initiating distance counseling.

       Understand all laws and ethical guidelines governing client interactions, and practice in accordance with the standard of care, the limits of one’s license/certification, and all regulations and ethical guidelines.

       Check state and third-party requirements related to distance counseling, licensure, and credentialing.

       Check regulatory board requirements, or if using a third-party for reimbursement of telebehavioral health services, review contractual requirements for client assessment, coding, and claims submission.

       Recognize potential issues regarding confidentiality, privacy, cyberstalking, and identity theft.

       Review relevant regulatory requirements.

       Follow encryption standards when communicating with clients online, and when consulting with other practitioners.

       Evaluate whether distance counseling is appropriate for a client.

       When initiating the online relationship, verify the client’s identity.

       Obtain informed consent, including a discussion of the purpose of the counseling, privacy and confidentiality, and use of technology with the client.

       Advise the client of their responsibility to be in a private space.

       Obtain informed consent, including a discussion of the purpose of the counseling, privacy and confidentiality, and use of technology with the client.

       Establish a written plan for how to handle an emergent or urgent situation.

       Maintain records that include documentation of observations, services delivered, and treatment plans.

       Transcripts of counseling sessions can be helpful to the client and the counselor; however, they may be used as evidence in a legal action.

      When engaging in supervisory relationships that involve the use of technology, counselor supervisors must hold supervision to the same standards as all other technology-assisted mental health services. In addition, telesupervision should be held to the same standards of appropriate practice as supervision conducted in an in-person setting (AMFTRB, 2016). Special attention should be given to the regulatory standards for the state in which both the supervisor and supervisee are licensed. Some states allow only a portion of supervision to be conducted via technology, and many that allow the use of technology only allow sessions that use HIPAA-compliant, synchronous videoconferencing software to count toward supervision hours. Text, phone, and chat may or may not be allowed, but in many instances they are ancillary forms of communication that do not count toward required supervisory hours.

      ACA (2014) clearly states that supervisors maintain appropriate, meaningful, and respectful professional relationships with appropriate boundaries in both face-to-face and electronic formats. According to the ACA Code of Ethics, “When using technology in supervision, counselor supervisors are competent in the use of those technologies. Supervisors take the necessary precautions to protect the confidentiality of all information transmitted through any electronic

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