During the COVID-19 public health crisis, many New Jersey mental health professionals have turned primarily, if not exclusively, to providing their needed services via telehealth.
As the crisis begins to show signs of lessening, many mental health professionals are beginning to consider when and how they might return to providing, at least to some degree, in-person mental health services.
Recently the National Association of Social Workers has offered guidance to its members, particularly solo and group practices, in this regard. That guidance can be found at https://www.socialworkers.org/LinkClick.aspx?fileticket=akHuTIoFNPM=&portalid=0. The following is a summary of that guidance. While each professional’s practice and practice considerations are different, this guidance serves as a useful checklist for beginning to think through the steps appropriate for a safer and orderly reopening.
WHEN TO RESUME IN-PERSON SERVICES
The guidance emphasizes that the decision to provide in-person mental health services should be based upon “local” circumstances, including:
- The age and underlying health issues of both the professional and the professional’s family.
- The age, occupation, health status, and behaviors of clients that might put either them or the professional at increased risk;
- The physical characteristics of the professional’s office and building. This would include the size of the therapy room and waiting room; the ventilation system; shared space with other employers/providers; size of the building and public access to restrooms, among other factors;
- The professional’s ability and willingness to provide services via telehealth versus in-person;
- The client’s attitude towards, suitability for, and ability to effectively engage in telehealth versus in-person therapy. Even if the client is interested in and suitable for services via telehealth, does the client have access to and training in the needed technology to do so effectively?
PLANNING THE RE-OPENING OF THE IN-PERSON PRACTICE
The reintroduction of face-to-face services requires careful planning. Some of the suggested steps include:
- A “soft” reopening in which only a few clients are seen in-person each day, scheduling to minimize the number of clients who might come into close contact with one another;
- Continuing to provide services via telehealth for those who prefer and for whom it is appropriate;
- Have personal protective equipment (“PPE”), cloth masks, etc. in the office prior to the reopening;
- Directing administrative staff to work remotely at home when possible;
- Bringing employees back in phases or having them work on different days/shifts to minimize contact;
- Limiting “client companions” to those whose participation in the appointment is necessary;
- Develop and enforce policies regarding the use of PPE and face masks for both clients and staff, consistent with CDC guidance. All individuals visiting the office should wear a cloth face covering. This should be explained to clients prior to their appointments. Those who arrive without one should be provided one, if available;
- Develop and communicate health requirements and expectations to professionals and staff. These would include employees not reporting to work if they have a fever or other symptoms of COVID-19 or have been in direct contact with someone who has tested positive for it. The records of employee screening should be kept in a confidential employment file, separate from the personnel file;
- Rearranging open areas in the office to increase the physical distance between people;
- Communicate with office/building management regarding cleaning schedules and protocols regarding shared spaces, such as kitchens and bathrooms, and regarding the reporting of COVID-19 positive employees in the building.
NASW’s guidance on reopening goes on to discuss other considerations such as the preparation of informed consent materials; updated policies and procedures; changes to the office setting; business considerations and confidentiality/privacy/data security protocols. We will summarize these in a forthcoming blog entry.
The foregoing is intended as a partial summary of guidance provided by the NASW to its members. It is not intended as specific legal advice. Should you wish to discuss the specifics of your practice and your situation, please do not hesitate to call us at (732) 238-8686.