Coronavirus Teletherapy FAQs: Therapist Questions, Answered

Last updated Friday, March 27th, 2020

As many clinicians transition to teletherapy for the first time, at Zencare, we know how important it is to keep your connection to clients strong.

As the situation with COVID-19 changes, states may change their policies to facilitate telehealth sessions, but you’re not in this alone: we will update this article with the most recent information as we have it!

1. Can I provide teletherapy across state lines?

As of March 23rd, 2020, there are no federal provisions that allow mental health professionals to practice teletherapy over state lines; you must register or become licensed in your client’s state to provide teletherapy.

However certain states have relaxed licensure requirements for the duration of the crisis. See here for a list of states and updates on their teletherapy status.

For example:

• Rhode Island has issued an expedited 90-day license: Beginning March 18, 2020, out-of-state licensees can receive a 90-day license to practice in Rhode Island by completing this application form and a statement verifying the license status from their home state; these can be mailed to: Center for Professional Licensing Room 104 3 Capitol Hill Providence, RI 02908-5097. This temporary license can be renewed one time, and there is no cost to obtain the license or the one-time renewal. For questions regarding this license please email doh.elicense@health.ri.gov.
• Washington DC has temporarily waived licensure requirements for providers who are providing a continuation of care for an individual who has returned to DC and who was previously in their care.
• New Jersey has allowed practitioners to apply for an expedited NJ license by completing this one-page form and sending it via email to njtemplicense@dca.njoag.gov. The New Jersey Office of the Attorney General website indicates that your application will be reviewed and responded to within 24 hours.
• Connecticut suspended licensure/certification requirements for being an approved telehealth provider in CT to increase patient access to out-of-state telehealth providers. The Department of Public Health issued an order stating that the requirements for licensure, certification, and registration are all suspended for 60 days in CT.
• Illinois' Department of Financial and Professional Regulation interprets Governor Pritzker's Executive Order 2020-9 to mean that out-of-state providers may practice via telehealth to maintain a continuation of care with clients previously in their care: "The Department interprets Executive Order 2020-9 to permit an out-of-state health care provider not licensed in Illinois to continue to provide health care services to an Illinois patient via telehealth where there is a previously established provider/patient relationship. The Department deems such a provider to be 'authorized to practice in the State of Illinois' pursuant to Section 5 of the Executive Order without further need to obtain licensure in Illinois."

As you begin to expand your telehealth services during COVID-19, it may be appealing to consider offering sessions to those outside of the state you are licensed in.

Generally speaking, the burden of risk management in teletherapy is on the provider, and it is important to do your due diligence when considering how to expand services.

To practice teletherapy with a client who is now in a state that you are not licensed in, there are two important steps for you to take: (1) Contacting licensing boards and (2) Informing your malpractice insurance provider.

(1) Contact licensing boards

Contact the following licensing boards:

1. The licensing board in the state that you are licensed in
2. The licensing boards in the states of the clients you are serving

Here are potential outcomes and steps you may need to take:

• Register with the state: If the state is generally more lax, and this might be the case given COVID-19, you can simply register with them to provide teletherapy.
• Get licensed in the client’s state: Sometimes the regulations are more strict, and in this case you may be required to be licensed in the states that your clients reside in. This could be as simple as transferring your license; other times, you may be required to complete additional training or supervision before receiving your license in that state.

(2) Inform your malpractice insurance provider

Your malpractice insurance provider is there to help you assess your risk. By alerting them of your plans to work with clients out of state, they will be able to let you know what additional coverage, if any, you may need.

Often your professional liability coverage only covers you where you are licensed, so it’s important to determine what limits there are on your coverage before making the decision to practice across state lines.

2. How about agreements between states to allow teletherapy across state lines?

For medical professionals and nurses, cross-state compacts exist, which allow licensed clinicians to practice across state lines in participating states.

However, for psychologists, social workers, and counselors, there are no agreements in effect as of March 23, 2020.

Cross-state telemedicine compacts

• PSYPACT is a newly emerging compact for clinical psychologists. However, this is not in effect yet (tentatively scheduled to be in effect July 1st, 2020).
• IMLC is a compact for MDs and DOs across the nation; it is in effect.
• NLC is a compact for nurses; it is in effect.

What is PSYPACT?

Tentatively scheduled starting July 1, 2020, licensed psychologists will be able to apply to practice under the authority of PSYPACT and provide teletherapy across PSYPACT state lines.

Note that this compact only applies to psychologists, and not other licensed mental health providers.

As of the writing of this article, here are the states that are part of, or pending joining PSYPACT:

PSYPACT States:

• Arizona – AZ HB 2503 (Enacted on 5/17/2016)
• Colorado - CO HB 1017 (Enacted 4/12/2018)
• Delaware - DE HB 172 (Enacted 6/27/2019)
• Georgia - GA HB 26 (Enacted 4/23/2019)
• Illinois - IL HB 1853 (Enacted 8/22/2018)
• Missouri - MO HB 1719/MO SB 660 (Enacted 6/1/2018)
• Nebraska - NE L 1034 (Enacted 4/23/2018)
• Nevada - NV AB 429 (Enacted on 5/26/2017)
• New Hampshire - NH SB 232 (Enacted 7/10/2019)
• Oklahoma - OK HB 1057 (Enacted 4/29/2019)
• Texas - TX HB 1501 (Enacted 6/10/2019)
• Utah - UT SB 106 (Enacted on 3/17/2017)

Pending PSYPACT Legislation:

• Alabama - AL SB 61 (Click HERE for additional information)
• District of Columbia - DC B 145 (Click HERE for additional information)
• Hawaii - HI SB 2771 (Click HERE for additional information)
• Indiana - IN SB 355 (Click HERE for additional information)
• Iowa - IA HB 2094 (Click HERE for additional information)
• Kentucky - KY HB 110 (Click HERE for additional information)
• Michigan - MI SB 758 (Click HERE for additional information)
• North Carolina - NC HB 297 (Click HERE for additional information)
• Ohio - OH SB 258 (Click HERE for additional information)
• Pennsylvania - PA SB 67 (Click HERE for additional information)
• Rhode Island - RI HB 7171 (Click HERE for additional information)
• Tennessee - TN SB 1142 (Click HERE for additional information)
• Virginia- VA SB 760 (Click HERE for additional information)
• Washington - WA HB 2408 (Click HERE for additional information)
• Washington - WA SB 6549 (Click HERE for additional information)
• West Virginia - WV HB 4427 (Click HERE for additional information)
  Wyoming - WY SF 37 (Click HERE for additional information)

To learn more about PSYPACT and find the most up-to-date information on your state, visit the PSYPACT website.

3. Does health insurance cover teletherapy? Does it reimburse teletherapy at the same rate?

Whether health insurance covers teletherapy or not depends on the health insurance company. It’s always best to verify directly with a client’s  insurance -- as you would for an in-person therapy session.

That said, generally speaking, if a client meets all three of the below criteria, then teletherapy sessions should be covered:

1. The client’s state has a telehealth parity law: All states on Zencare.co (New York, Massachusetts, Rhode Island, California, New Jersey, Connecticut, Illinois, Washington, Washington DC) have a telehealth coverage parity law in place.
2. The client’s insurance plan covers mental health: This would be true for existing clients who have been able to see you in-network for in-person therapy services.
3. The client’s insurance plan covers telehealth: If the insurance company covers telemedicine and the state has a parity law, then teletherapy should be covered similarly to any other telemedicine service.

To learn more, read our article on health insurance coverage of teletherapy.

4. What questions should I ask health insurance companies when I call them?

When calling your client’s health insurance company to confirm coverage, ask questions that allow you to confirm that:

1. Teletherapy is a covered benefit
2. You will be reimbursed for providing care
3. You will be reimbursed the same rate as in-person sessions (if you have been seeing the client in-person to date)

Questions to ask health insurance companies

• Can you please confirm my network status?
• Does this client have out-of-network benefits?
• Is telehealth a covered benefit?
• What specific payer ID should claims be routed to?
• Are there any restrictions or requirements around the location of the patient or provider?
• I am a {psychologist / social worker / counselor / creative arts therapist}. Am I eligible to provide teletherapy services?
• Are there any documentation requirements associated with billing for teletherapy?
• Is the reimbursement rate the same as the rate for in-person services?

For more questions and a comprehensive guide, watch SimplePractice’s video and download the associated presentation!

5. What reimbursement codes do I use for teletherapy?

Billing for teletherapy for the most part looks similar to billing for in-person sessions, with the biggest difference being the added modifiers of "GT" and "95," and the Place of Service changing to "02."

• GT Modifier: Per the AMA, the modifier means “via interactive audio and video telecommunications systems" (including email). GT can be appended to any CPT code for services that were provided via telehealth.
• 95 Modifier: Per the AMA, this modifier refers to “synchronous telemedicine service rendered via a real-time interactive audio and video telecommunications system.”
• 02 Place of Service: The "02" Place of Service references a location where the service is received through telehealth platforms.

6. Do you have a guide or materials for clients on transitioning to teletherapy?

Yes! We have put together this Guide on Transitioning to Online Therapy Sessions for Clients.

7. Do my clients need to sign additional paperwork for teletherapy?

If you are located in New York, New Jersey, Connecticut, Washington DC, Washington, Rhode Island, or California, your client will need to provide consent to receive their therapy session via telehealth for you to be reimbursed by the insurer. This should be documented, similar to any informed consent that you require in your practice.

Other states, such as Illinois and Massachusetts, do not require client consent to teletherapy.

That said, in general, it is best practice to have your clients be informed of any changes to the way they experience care in your practice. Even if it is not required through insurance, it is recommended you provide your clients with written updates around your tech, their rights in this context, potential risks, and any relevant logistics related to their new session format.

Here is a sample teletherapy consent form in Google Docs that you can copy that has been modified from SimplePractice’s standard consent form.

You can also download a Word document version here.

Additional sample consent forms can be found below. These are for informational purposes only, so please make sure to read through it and customize it for your own practice and local laws!

• Consent for Telemental Health Services
• Consent to Participate in Telemedicine Consultation
• Consent to Participate in Telemedicine Consultation (Spanish Version)
• Telebehavioral Health Institute Informed Consent Library

8. How do I conduct psychoanalytic or psychodynamically informed sessions via teletherapy?

Response by Laura Federico, LCSW

Adjusting to virtual or phone sessions can absolutely take time, especially for psychoanalytic clinicians. It's normal to experience a higher level of activation around glitches, or to feel unsure or to experience discomfort while learning the new types of pauses or the pace that may come with a virtual session.

When we as providers are feeling an increase in anxiety related to using video or voice modalities for the first time, it can be easy to conflate the new conversational cadence in this format with a clinical problem.

Learning to adjust to a different setting can actually be a wonderful opportunity to renew our attention to the importance of the therapeutic link we have with clients, seeing that strength highlighted in a new way. If there is a problem or interruption with the connection in session, this can actually provide a new opening to process reactions to this and to repair together, deepening the work.

Read Laura Federico's full response to this question here.

9. Are Skype and Facetime HIPAA-compliant? What video platforms are HIPAA compliant?

No, Skype and Facetime are not HIPAA-secure video conferencing platforms.

Here is a table of HIPAA secure vs. not secure platforms:

Teletherapy Platforms: Pricing Comparison

To learn more, read our article comparing pricing, features, and ratings of HIPAA-secure teletherapy platforms.

10. Which HIPAA-compliant video platform do you recommend?

The most commonly used HIPAA-secure platforms by Zencare member therapists are:

• Doxy.me - Used by 30% of surveyed Zencare member therapists
• SimplePractice - Used by 25% of surveyed Zencare member therapists
• Zoom - Used by 13% of surveyed Zencare member therapists

See our full comparison of HIPAA-secure video platforms, including recommendations and tips by Zencare therapists!

11. What can I send clients about starting teletherapy?

Here is what Laura Federico, LCSW, shares with her clients. Here is Zencare's Client Guide to online therapy and how to prepare.

“I am so happy we are able to continue our work together without any significant transition during this challenging time. Although we will continue to meet as normal for our virtual session, one change we will be negotiating is that for many of us, our homes and spaces are going to be a bit more crowded than usual.

This means getting creative in our spaces, finding a room with privacy, and communicating our needs with our family members, partners, housemates. This is happening for me as well. :) On my end, I will be using a white noise machine, will be in a room that has privacy to fully protect our sessions, and will be using wireless headphones. There is a chance you may hear the muffled sound of voices (young and old) in the distant background. We are going to practice mindfulness and acceptance around normal life noises that may happen on either end in session, and we will make space to discuss any feelings that come up around this in our work.

If you're having difficulty figuring out a way to have our session in your home or space in a way that feels comfortable, just let me know and we'll figure it out together. We're in this together, as always, I'm here for you, talk soon.”

11. Will people be more or less likely to seek therapy during this time?

This is a double edged sword: although many more people will likely be feeling anxiety and experiencing other mental health concerns during this time (or having exacerbated preexisting issues), they may not have the means or have had a change in circumstances that make it difficult to consider investing therapy.

12. How will I continue to do this long-term, staring at a computer all day, without the same relationship with my clients?

Acknowledging that there has been a change is a good first step! Recognizing that you are in a different space with clients, and that neither of you is used to using a computer to communicate is key. It might be a good to allow yourself a bit of extra time between sessions (even an extra 5 minutes) to walk around your office and take stock of the previous session.

13. How do I help more people through this when I don’t even know what to say to comfort people about the coronavirus?

Focus on the control and choices they do have. This can be daunting, especially because no one is sure when this will end and what it will look like when it does. That said, you can help them think about ways to maintain normalcy -- waking up and going to bed at the same time, talking with friends, deciding to watch a particular movie.