Implementing Electronic Practice

March 19, 2020

To help prevent the spread of COVID-19, our government and public health authorities are implementing social distancing measures. This means that we are being asked to limit unnecessary face-to-face contacts with people outside our homes.

Providing face-to-face psychotherapy may not be advisable or possible at this time, unless a client is in an acute crisis or the therapist is operating in a managed setting with infection prevention protocols in place, such as a hospital. Electronic practice – either by phone, email or online –  might be an option that will help you meet your clients’ needs during this time.

If you are thinking about providing services electronically, note that the standards and requirements of the Personal Health Information Protection Act still apply.

You may want to review the following resources:

• Professional Practice Standard 3.4, Electronic Practice
• Electronic Practice Guideline
• Security Practice Checklist
• Professional Practice Standards section 2, Competence
• Professional Practice Standard 3.1, Confidentiality
• Professional Practice Standard 3.2, Informed Consent

Before you work with a client using electronic practice technologies, you’ll need to consider key issues:

Suitability

Assess the suitability of electronic practice,  considering each client’s needs and other relevant factors. Look at whether the client has the capacity to access technology in a safe and private setting. Is there a strong possibility that they could have an adverse reaction to the session (such as a panic attack)? Are they suicidal or do they pose some other risk to themselves or others? Can you verify their identity when using a non-visual platform?

Competence

Ensure that you are competent to use whatever electronic means you decide to employ. When we talk about competence here, it refers to both clinical and technical competence.

Keep in mind that electronic practice is its own therapeutic milieu that requires you to possess the knowledge, skills and judgement to be able to provide safe and effective care with clients remotely.

And remember that you will be operating with equipment and software or applications that you must know how to use properly and in a way that ensures you protect the client’s personal health information and their privacy. We would strongly recommend that you practice with whatever technology you choose before you use it in clinical practice.

Other questions that you should consider before offering online psychotherapy include:

• Is the client located in a jurisdiction besides Ontario, and would your ability to provide services to that client be restricted in any way by regulations in that jurisdiction?
• Does your liability insurance provider cover electronic practice?

Remember to look at the Electronic Practice Guideline for more information and support.

Informed Consent

You need specific informed consent to provide services electronically. As part of that, you should consider discussing:

Privacy

Make sure the client knows what you are doing to protect their privacy. You also need to discuss what they should be doing to make sure that they have their own security in place. For example, that any computer they use is password protected and that they are connecting with you from a place that is private.

Technology

Discuss what you will do if there is any unplanned disruption because of equipment or internet issues. Will you move to a telephone call? Will you reschedule?

Recordings

Take extra care in your informed consent process if you want to record a session or if a client suggests they want to. If sessions are recorded, you will have to consider how to store, transmit or dispose of the recordings.

Unless you have a good reason to make a recording, you may wish to let the client know that you won’t be recording the session and suggest that they shouldn’t either.

Risk of harm

If a client is at risk of harm to themselves or others, online psychotherapy will likely not be appropriate. Have a plan for online crisis intervention. Make sure your client understands when you would terminate online sessions because of the risk of harm and how you would facilitate a referral to another service or provider if that happened.

Written agreement

Ideally, you should enter into a written agreement with your client at the end of this informed consent discussion. The Electronic Practice Guideline provides more information about service agreements.

Remember, you can refer to the standard on Informed Consent for more guidance.

Electronic Practice Platforms

If you decide to offer electronic practice to your clients, you might be wondering what electronic practice platforms conform to Ontario’s health care privacy laws.

CRPO can’t recommend a specific platform because technology is constantly evolving and there are so many options available.   However, we are aware that many RPs may be considering implementing electronic practice over the short term and need immediate support.

Considering this, we wanted to share the Virtual Care page on OntarioMD News. This resource includes a comprehensive list of electronic tools that were developed specifically for ‘video visits’ and other forms of virtual or remote medical practice. The list was put together by the professional association for physicians in this province – the Ontario Medical Association  – and an eHealth delivery partner – OntarioMD – who are working together to support physicians in providing care during the pandemic.

Please note that CRPO cannot attest to the effectiveness or appropriateness of these platforms.

Please also note that privacy requirements should be considered from end to end – from the security of your internet access point, to the devices you use, to the features of the specific platforms you use.

Your professional association or an information technology consultant may be able to offer guidance or support on this front.

 Please rely on your profession judgment to find a platform that will work best for you and your clients. Remember, you can use this checklist to self-assess your own electronic security practices: Security Practice Checklist

Want to see our COVID-19 practice advice? Look here.

Questions about electronic practice? Send them to practice@crpo.ca.