Guidance for Practitioners: Coronavirus (COVID-19)

We have received several calls at Trust Risk Management Services (TRMS) about managing the risk of the coronavirus (COVID-19) in your practice, place of work, and in the professional services you provide. As risk managers, we are providing general risk guidance based on current knowledge and conditions. Unfortunately, we are unable to provide medical advice.

  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. You should 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 or telehealth services, but ensure you know applicable state rules and regulations.
    1. There are a number of resources available depending on your area of practice. Some resources include:
      • APA telepsychology guidelines (see https://www.apa.org/practice/guidelines/telepsychology).
      • NASW, ASWB, CSWE, & CSWA Standards for Technology in Social Work Practice, https://www.socialworkers.org/includes/newIncludes/homepage/PRA-BRO-33617.TechStandards_FINAL_POSTING.pdf.
      • American Telemedicine Association, Practical Guidelines for Videoconferencing Based Telemental Health, http://www.ATA.org.
      • Center for Telehealth and eHealth Law, http://www.ctel.org.
    2. Check with your professional association listserv and website. You can be sure that others will be discussing this issue.
    3. Determine if your state licensing board has telepsychology or telehealth regulations or guidelines. These are often available on your Board’s website.
    4. Determine if your client’s health insurance covers telepsychology or telehealth.
      • 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 or telehealth 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.
  1. Remember, this too shall pass.

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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 Companies as the source if you reproduce or distribute any portion of these resources. Reproduction or distribution of this resource without the express written permission of The Trust Companies is strictly prohibited.