TeleHealth Board Rules Do Apply to You – Therapists and Supervisors!

This week’s post is primarily for licensed and associate licensed counselors, social workers and marriage & family therapists in the state of Georgia. So if that doesn’t apply to you, no worries… I’ll have more general content next week!

To view a copy of the new board rule, check out this link posted by Raymond Barrett, LPC at the Telehealth Certification Institute. Scroll down to see the new rule.

Just in case you are thinking that the new telehealth/telemental health board rule changes don’t apply to you, I want you to consider the following as it relates to your counseling relationships:

  • Do you ever accept phone calls from clients (for example crisis calls or even initial scheduling phone calls)?
  • Do you transmit information regarding clinical case documentation electronically? This could be sending case notes to an employer; carrying case notes on a thumb drive; storing records electronically, sending faxes, receiving e-mails from psychiatrists with case updates?

If the answer is yes, then you are practicing telemental health.

You don’t have to be providing distance therapy or counseling as your primary modality to be considered telemental health practitioner.  The board is defining telemental health as follows:

  • “Telemental Health – means the mode of delivering services via technology-assisted media, such as but not limited to, a telephone, video, internet, a smartphone, tablet, PC desktop system or other electronic means using appropriate encryption technology for electronic health information.  Telemental Health facilitates client self-management and support for clients and includes synchronous interactions and asynchronous store and forward transfers.”
    • Asynchronous store and forward – means the transmission of a client’s information from an originating site to a licensee at a distant site without the presence of the client.”
    • Synchronous interaction – means a real-time interaction between a client and a licensee located at a distant site.”

If you are a supervisor, do you ever have the following contact or activities in your supervisory relationships?

  • Receive or send e-mails to supervisees (providing guidance and answering questions).
  • Receive and respond to crisis calls from supervisees.
  • Listen to audio recordings or view video recordings of sessions.
  • Transmit or send supervisory directives, feedback or evaluation content via electronic medium.
  • Are any of your supervisees providing services via phone or in any way at a distance?

If the answer is yes to any of these, then you are a telemental health supervisor.

Telemental health supervision is being defined as follows:

  • TeleMental Health Supervision – means the delivery of supervision via technology- assisted media by a supervisor at one site while the supervisee is located at a distant site.  Telemental health supervision may include, without being limited to, the review of case presentation, audio tapes, video tapes, and observation in order to promote the development of the practitioner’s clinical skills.

On September 11, 2015 the Georgia Composite Board for Professional Counselors, Social Workers, and Marriage and Family Therapists passed a new rule 135-11.01 Telemental Health.

In essence this rule requires all licensees including associate level licensees to complete 6 hours of continuing education in any of the following content areas “prior to delivery of clinical telemental health services.” “The continuing education hours may include but are not limited to the following, in the discretion of the board:

  1. Internet use dependence and psychological problems – an overview of how Internet users become dependent upon the Internet to such an extent that their Internet use is causing serious problems in their lives.
  2. Research in Telemental Health – review of evidence base for mental health practice conducted using telemental health.
  3. Intake and Assessment– initial intake and assessment necessary to determine a client’s suitability for telemental health, including informed consent.
  4. Delivery Methods – recognize appropriate use of telecounseling, asynchronous email/message posting, synchronous digital chat, video-assisted therapy and other electronically supported modes of delivery.
  5. Theory Integration – understand how to adapt counseling/therapy theory and effective in-person techniques to telemental health.
  6. Termination – recognize similarities and differences between in-person and telemental health closure while providing technology-assisted strategies for reestablishing contact if and/or when necessary.
  7. Risk Management – understanding privacy and security standards of applicable laws such as Health Insurance Portability and Accountability Act ensuring high quality practices and procedures that are legally sound and ethically protect clients and safeguard against litigation, including protection of electronic information.
  8. Business of Telemental Health – review of ethically sound ways to advertise and incorporate telemental health into an existing suite of therapeutic/clinical services.

(ii) If the licensee has taken the hours required in this section within the last 5 years, those hours do not need to be repeated in order to meet requirements in this section.

As you can see the HIPAA/HITECH laws are referenced in this training list. Follow this link for a helpful but not all-inclusive summary of the New HIPAA/HITECH Omnibus Regulation.

It is not enough to meet these standards referenced in HIPAA/HITECH or in telehealth or distance counseling training, it is now vital that you are able to demonstrate 6 hours of continuing education in the areas outlined above. As of October 7, 2015 you could be considered out of compliance with the licensing rules if you cannot demonstrate the requisite training content within the past five years.

Secondly, if you are a Supervisor you must complete an additional 3 hours of continuing education “hours in the category of: Supervising Telemental Health Therapy – understanding the key components necessary to supervise effective, and efficient delivery of telemental health therapy,” for a total of 9 hours of continuing education under this new board rule, in order to be compliant. So six of the hours would come from the categories detailed above and additional 3 must be related to supervision and telemental health.

Again, as of October 7, 2105 you could be considered out of compliance with the licensing rules if you cannot demonstrate requisite training in the past years in these content areas prior to providing these telemental health services. In other words, you should plan to complete the required training as soon as possible if you have not done so already.

My rational for this assertion is based on the following language in the board rules.

  • “Code of Ethics -The failure of a licensee to comply with these requirements shall constitute unprofessional conduct under the Code of Ethics as described in Board rule 135-7. A licensee delivering health care services via TeleMental Health shall comply with all Code of Ethics requirements as described in Board rule 135-7.”

If you are a supervisor or an employer you should inform your supervisees and employees about these training requirements.

If you continue to exercise these very common distance (telehealth) communication practices, without the required training  (after October 7, 2015) then you are risking your compliance with the Composite Board Rules.

You will need to obtain continuing education in the the telemental health content area every two years during your licensing renewal cycle. These hours will count toward your 35 CE’s if the provider from whom you obtain your hours has the appropriate approval for issuing continuing education hour certificates; and if the content is in alignment with the board rules as described above.

The Licensed Professional Counselors Association of Georgia is working to bring training to its membership. Some of the training would be live/in person. Other offerings will likely be online. If you want to remain informed about these offerings please look to your LPCA-GA e-mail announcements and/or join your professional association if you have not done so already.

While I can not guarantee that the following resources meet the standards intended by the composite board, I wanted to provide some resources to assist you if you are or will be seeking training in telemental health.

  1. Telemental Health Institute
  2. The Zur Institute- Telehealth: The New Standard
  3. DeeAnna Merz- Online Therapy Institute (has current options and may be offering more specific to the hours needed in Georgia)
  4. Raymond Barrett, LPC Telehealth Certification Institute, LLC (browse his site, he has some live training events as well as online)

As for the 3 hours related to supervision and telemental health, that may be a little more difficult to find. I know that LPCA-GA is looking into some options. I hope to have more information about this by next week.

I did find one workshop being offered by Charlie Safford, LCSW at, it is a live training event in Roswell on November 1, 2015 that looks to meet the standards for supervisors.

I also plan to develop a three hour training in this content area. Stay tuned and I will share both mine and others training resources as soon as possible!

Remember the impact of training is only as effective as successfully putting what you’ve learned into practice!


The Georgia Composite Board of Professional Counselors, Social Workers and Marriage and Family Therapists, 237 Coliseum Drive, Macon, Georgia 31217.

Copyright © 2015 Ruby Blow. All rights reserved.

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