Confidentiality, Privacy and Security

Outdoor Therapy Session

  • 1.  Outdoor Therapy Session

    Posted 07-08-2020 14:30
    Hi Privacy Experts,

    I've received the following request from my Behavioral Health Services Manager.

    First, we have a specific situation in which the therapist feels an in-person session is needed due to the nature of the patient's presentation. The therapist wants to met the patient on the lawn outside of the clinic, since it is safer than being inside due to the current climate of Covid19. This is especially true given that when therapists see a patient, they are in a room for 30-60 minutes with the door closed.

    Based on this situation, other therapists in the group started a conversation inquiring about what is possible and doable within HIPAA with regards to an outdoor therapy session. They've discussed benefits of taking walks and sitting outside beyond the scope of Covid19 safety.

    Of note, we couldn't protect patients from others seeing them sit with us... If the individual seeing the encounter knew the therapist at at all, then the purpose of the meeting would likely be known (and we'd be in PPE).

    I've been able to ascertain at a high level that, unofficially, it is okay and appropriate for a psychotherapist to meet with a client outside so long as it is a documented part of the treatment plan. I have a couple followup questions before providing the therapist group with this information...

    1. Is it still okay given the risk of being seen "by the public"?
    2. If so, will we need a specific informed consent?
    3. If so, can anybody point me to a sample informed consent?
    4. Are there any other clearly defined boundaries that we'll need to consider prior to and IF we allow therapists to meet with patients for outdoor therapy sessions.

    Thank you kindly for your time.


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    Sarah Dietz, CHPC
    HIM & Privacy Manager
    GHC-SCW
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  • 2.  RE: Outdoor Therapy Session

    Posted 07-08-2020 14:43
    This is another good one...probably so many innovative ways to approach this.  However...I'll come at this from a "boring" angle.

    Prior to the outdoor session, is there an opportunity to share the reasons for the outdoor sessions with the patient to include the potential for incidental disclosures to get some type of acknowledgement that the patient is fine with the setting?

    Might mean a little extra notation by the therapist beforehand of his or her efforts to schedule the session, but may be an easy fix.

    Thoughts?

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    Frank Ruelas
    Compliance Professional
    Arizona
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