In connection with the Corona Virus, we have received numerous inquiries from our Ohio counselor and social worker clients concerning teletherapy services.
The Ohio Counselor, Social Worker, and Marriage and Family Therapist Board (“CSWMFT Board”) recently posted the following information on its website:
The Board’s rules regarding providing teletherapy are established in Ohio Administrative Code Chapter 4757-5-13. Licensees who are considering offering services via teletherapy should be mindful of the following:
- Independent licensees (LISW, LPCC, IMFT), dependent licenses (LSW, LPC, MFT) working under supervision, and trainees (SWT, CT, MFTT) working under supervision, can all provide teletherapy provided they have training and experience in teletherapy. Examples of training include the completion of continuing education, supervised experience, and peer consultation.
- Services must be provided to ensure the highest level of confidentiality. Video-conferencing software should be HIPAA compliant.
- Licensees should carefully consider whether teletherapy is an appropriate means of providing services to individual clients.
- Licensees must be mindful that ORC 4757 and OAC 4757 apply regardless of how services are provided.
- Licensees who voluntarily choose to suspend providing services must properly terminate with clients and provide referrals as required in the rules. If a licensee is suspending services in response to a public order to do so, the licensee or their employer is advised to provide information, for example on outgoing voicemail messages or websites, regarding resources in the event a client is in crisis.
- Insurers establish which services are eligible for reimbursement. Be sure to verify whether you can bill for teletherapy before providing services to a client. The Board has no authority to direct insurers to pay for teletherapy services.
- Agencies and practices may set their own rules regarding teletherapy. The Board can exercise no authority over these employment/business related decisions.
While the Board staff want to be as helpful as possible, we are not able to provide specific guidance regarding implementing teletherapy. Please consult with peers and supervisors. Additionally, Board staff cannot recommend specific software, nor can the Board recommend specific training programs.
- As the State of Ohio’s response to COVID-19/Corona Virus evolves, the Board will share information with licenses.
PLEASE ALSO NOTE: The CSWMFT Board also recently posted the following update on its website:
Teletherapy Update – Emergency Rule in Progress
The CSWMFT Board is working with Governor Mike DeWine’s office as well as other State agencies on an emergency rule that will provide flexibility for licensees who are seeking to provide teletherapy. We anticipate the proposed rule will be issued soon and will align with the rules being proposed by the Ohio Department of Medicaid and Ohio Department of Mental Health and Addiction Services. Once the rule is issued, we will provide an update and additional guidance.
Below are some additional resources about teletherapy and COIVD-19:
State of Ohio
AMHCA Code of Ethics
NASW Ohio Chapter
Marriage and Family Therapy
NIMH – https://www.nih.gov/health-information/coronavirus
APA – https://www.apa.org/practice/programs/dmhi/research-information/social-distancing
American Telemedicine Association – http://www.americantelemed.org/resources/telemedicine-practice-guidelines/telemedicine-practice-guidelines#.VS_Go40tGUk
Medicaid – https://www.medicaid.gov/medicaid/benefits/downloads/medicaid-telehealth-services.pdf
HHS – https://www.hhs.gov/hipaa/for-professionals/special-topics/emergency-preparedness/notification-enforcement-discretion-telehealth/index.html
Medicare – https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet
In consideration of the rapidly-changing situation in which we find ourselves, we recommend and encourage Ohio counselors, social workers, and marriage and family therapist licensees to frequently visit the CSWMFT Board website. As always, if you have questions about this post or the CSWMFT Board, please contact Todd Collis or Beth Collis.