Notice of Privacy Practices (NPP) compliant with current HIPAA rules for teletherapy
2020 COVID-19 Response
Your physical and emotional health is our greatest focus. Based on public health recommendations of social distancing, my practice will be including telehealth and phone sessions immediately to ensure you continue to have access to care, and that you don’t have to be concerned about possible exposure in my waiting rooms or offices. I am taking the utmost care. I can call you to talk over logistics re video conferencing. You will need to find a quiet place that is private so that they can share freely, as best to their ability. Here is a link to what to expect of a virtual session and how to prepare.
I am concerned about you. Our therapy appointments are important to both of us, but we can’t have them in person while you are sick. I can’t be here for you if I get sick, and I have to try to ensure that your fellow clients can come here without getting sick. If you are sick or if you’ve been exposed to anyone with the virus, been in an airport, or showing any symptoms of ANY illness including a fever, please wait 14 days after the fever has subsided before coming in for an in-person appointment. We can convert your appointment to a telehealth appointment. See this quick article on what a telemedicine session might be like: https://www.apa.org/helpcenter/online-therapy or https://theranest.com/blog/starting-telehealth/
Regarding confidentiality in the current crisis, if you test positive and the CDC asks you for names of people who you’ve been in contact with in order to stop the spread of the virus- you (and I) will need to provide that information. “The Privacy Rule expressly permits disclosures without individual authorization to public health authorities authorized by law to collect or receive the information for the purpose of preventing or controlling disease, injury, or disability, including but not limited to public health surveillance, investigation, and intervention.” Here is in depth information on HIPAA and privacy as it pertains to the CDC and stopping the spread of disease: https://www.cdc.gov/mmwr/preview/mmwrhtml/m2e411a1.htm
Videoconferencing psychotherapy sessions are provided on my HIPAA-compliant Zoom platform. This platform allows for real-time video communication. You do not need your own Zoom account to join me in my “Zoom room.” However, you will need a computer with a video-camera. A day or so before the meeting, I will send you a Zoom link. At the time of the meeting, click on the link. A video screen will pop up. You may have to click on icons in the lower left corner of the video box to turn on your microphone and camera.
Limitations Due to Use of this Technology
A variety of technological problems can cause delays in starting meetings or can interrupt a meeting. If case we lose our connection, you can call my home office at985-893-1248: Please provide the phone number that I can call in case our internet connection fails. Keep this phone charged and with you while we meet so that I may call you as needed. If we cannot successfully reconnect on the internet, we can reschedule or continue on the telephone.
The audibility of videoconferencing may not as good as in face-to-face meetings. My experience is that participants may need to ask each other to repeat what we each said. We will also be less able to observe each other’s’ body language. All of this can result in a less “felt” sense of each other as compared to meeting face-to-face. If you sense that I have missed your meaning or responded in an unhelpful way, please tell me as soon as possible so that we can work to repair the mis-communication or mis-step.
Communication via the internet cannot be guaranteed to be 100% secure. The following are steps that we can take to increase security and confidentiality.
- The Zoom videoconferencing platform and its Epic software are HIPAA-compliant. Our meetings are encrypted with AES-256 bit encryption and dynamic password protected. You can read more about Zoom security here:
- We both agree not to record our videoconference meetings without explicit permission from both parties.
- To prevent non-participants from joining our confidential meetings electronically, we must both secure the links to our Zoom meetings that I send to you via email. Ensure your email account and mobile device have secure passwords and ensure that you close your email platforms when not in use. I will do the same.
- We both agree not to have any other people in the rooms where we hold our video-conference, unless explicitly discussed prior.
- In my experience, interruptions at home tend to occur during videoconferencing sessions and we should anticipate these. We can limit interruptions by telling people in our homes that we are having a confidential meeting, closing the doors to our rooms, and by placing a “Do Not Disturb” sign on our doors. Nonetheless, people may forget and walk in, other phone lines and doorbells ring, pets make their presence known, etc.
Payment for Sessions
Clients paying out-of-pocket for therapy will pay the same fee as when we meet in person. For clients using health insurance, I will seek authorization for insurance payment for video-conferencing therapy. Co-payments will still apply. If the insurance company will not authorize this service, we will make other arrangements.
Payment should be made by check by mail to my home address during the current health crisis:
I also have a establish a PayPal account for this purpose under my firstname.lastname@example.org email address.
Given the demands of the current health crisis, there may be a need for last-minute cancellations and we will need to be flexible with each other. Nonetheless, we must respect the time we each commit to our meetings.
Prior to meeting, I will ask you to sign an agreement syaing “I have read the above information on videoconferencing psychotherapy, the limitations, and confidentiality caveats. With this understanding, I wish to participate in videoconferencing psychotherapy sessions when health or other concerns prohibit our being able to meet in person.”
Some info on etiquette online
Find a quiet area, free from things that may distract others (pets, people, television, phone, doorbell) Even though you can have online meetings from basically anywhere, it’s best to choose somewhere quiet where there won’t be a lot of distractions or noise.
- Do not drive or complete other tasks while you’re in the meeting — this is dangerous
- Treat a live session as though you were in a physical meeting. Always connect via video – and leave it on for the duration of your meeting – (only turn off video when absolutely needed, the same way you would step out of physical meeting).
- Be sure to connect in a location that has strong internet connectivity
- Make sure your face can be seen on the camera and be aware of what is in the background so there are no distractions for your therapist.
- Dress appropriately
- To avoid background noises becoming a distraction for others, simply mute yourself when you’re not speaking for a fair amount of time.
- Listen carefully show that you’re listening
For the period of the current crises, would you like to call or video conference me?