Guidance for Practitioners: Coronavirus (COVID-19)

We have received a large volume of calls from our insureds about how to manage the risks the corona virus pandemic poses to patients and to themselves. As risk managers, we are committed to supporting you in ethical, safe practice. We provide general risk guidance based on current knowledge and conditions. Of course, we are unable to provide medical advice. If you have specific questions about your individual situation, please feel free to schedule a call to speak with one of The Trust’s Advocate 800 Program's risk managers.

We are aware that many of you are experiencing a wide variety of potential personal issues regarding your health, your business, and your loved ones. The fully understandable worry our callers are experiencing is palpable. Our goal is to present simple, factual and useful information to help you navigate the challenges we are all facing. But this doesn’t mean that we are unaware or insensitive to your feelings or those of your clients. This is the time when we are reminded that psychology is a calling to provide help to those who need it. While following the rules is always important, the primary ethical goal is to provide good care. It seems unlikely that anyone will be disciplined for rule violations if there is a good, recorded justification and violating the rule does not present a risk of harm to the patient or the public. We hope you all stay safe and continue to help your patients deal with one of the worst crises in memory.

Click here for COVID-19 Guidance & Resources

  1. If you are in private practice, the most important thing you can do now is have a plan, and let your clients know what it is.
  2. If you work in an institution, find out what the policies are, and follow them.
  3. Communication will be particularly important and could become difficult if the efforts to contain the virus cause systemic disruption. If you don’t have a reliable, secure and direct means to reach your clients, create one. Obtain written permission from your clients to send communication about appointments via email or text.
  4. For virus updates, look at the CDC website (see https://www.cdc.gov/coronavirus/2019-ncov/about/prevention-treatment.html) and also your state or local public health website. Check frequently for new developments.
  5. Contact your medical provider if you have any symptoms and/or believe you have been exposed to the virus.
  6. Follow obvious health advice: Wash your hands thoroughly and often and encourage your clients to do so before coming into the office if you have facilities available.
  7. Have hand sanitizer available in your waiting room, and encourage your clients to use it before they come into the office.
  8. Avoid body-to-body contact, including shaking hands.
  9. Encourage your clients to cancel if they have any cold or flu symptoms. Consider waiving penalties for cancellations.
  10. Determine your own risk. If you are older and health compromised, you may need to take greater efforts to protect yourself. You will not be able to help anyone if you get seriously ill.
  11. Try to present all of this information in a professional manner. Do your best to be prepared, maintain calmness, and avoid creating additional anxiety in your clients.
  12. Consider using telepsychological services, but ensure you know applicable state rules and regulations and critical guidelines:
    1. Familiarize yourself with the APA telepsychology guidelines (see https://www.apa.org/practice/guidelines/telepsychology).
    2. Check with your state psychological association listserv and website. You can be sure that others will be discussing this issue.
    3. Determine if your state licensing board has telepsychology regulations or guidelines. These are often available on your Board’s website.
    4. Determine if your client’s health insurance covers telepsychology.
      • Be aware that insurance may or may not cover audio visual services.
      • Telepsychology services must be appropriately coded. A common CPT code modifier used by insurance companies to indicate telepsychological services is “95.” Be sure, however, to check with each insurance carrier, as requirements may vary.
    5. Find a HIPAA compliant communications platform. The following site provides reviews: https://telementalhealthcomparisons.com. (Remember that HIPAA’s privacy, security and breach notification rules remain in effect during this health emergency, as do your state privacy laws).
    6. If services are not covered by insurance, discuss with clients whether they are willing or able to pay out-of-pocket. If you decide that it makes sense, you can offer to negotiate rates for the duration of the emergency. If you are an insurance panel member, this likely will not be a problem for insurance companies under this emergency situation.
    7. If insurance does not cover telepsychology services, determine whether you or your clients would be more comfortable with telephone sessions.
    8. Do not bill insurance companies for remote services as if they were delivered in person. This is high risk and can expose you to licensure issues.
  13. Please know that your Trust Sponsored Professional Liability insurance policy covers psychological and other associated professional services including such services as telehealth, provided the insured is in compliance with the appropriate state practice rules or regulations. All other policy terms and conditions apply. While there is currently no specific requirement for a certain number of or kind of telepsychology courses by The Trust for coverage, we certainly recommend proper training and education to ensure protection of you and your clients/patients. As we all know, the practice of psychology includes adherence to legal and ethical regulations and standards, which includes competency in all areas of one’s practice. In telepsychology, competency includes technical competency and knowledge and practice of the telepsychology guidelines, at a minimum.
  14. Remember, this too shall pass, and we are available for consultation.

NOTE: This information is provided as a risk management resource and is not legal advice or an individualized personal consultation. At the time this resource was prepared, all information was as current and accurate as possible; however, regulations, laws, or prevailing professional practice standards may have changed since the posting or recording of this resource. Accordingly, it is your responsibility to confirm whether regulatory or legal issues that are relevant to you have since been updated and/or to consult with your professional advisors or legal counsel for timely guidance specific to your situation. As with all professional use of material, please explicitly cite The Trust as the source if you reproduce or distribute any portion of these resources.