FAQs Related to COVID-19

August 26, 2022

This is an interim guidance on inquiries received by the Board relating to Coronavirus Disease 2019 (COVID-19). The Board will update this guidance as needed and as additional information becomes available.

Supervision

Can the required face-to-face, direct, individual supervision with the primary supervisor be conducted via HIPAA-compliant video? California Code of Regulations (CCR) Sections 1387 and 1391.5)

Yes. Effective August 22, 2022, Business and Professions Code sections 2913 and 2914 were amended (Assembly Bill (AB) 2754) to allow any supervision to be provided in real time, which is defined as through in-person or synchronous audiovisual means, in compliance with federal and state laws related to patient health. The authority granted by way of the Governor’s Declared Emergency (from March, 4, 2020) to allow the required one hour face-to-face, direct, individual supervision to be conducted via HIPAA-compliant video was rendered moot when the provisions in AB 2754 were chaptered into law.

Mode of Psychological Services Delivery

Can trainees provide psychological services and accrue supervised professional experience (SPE) via telehealth?

Yes, trainees can provide psychological services via telehealth as long as they are properly supervised in doing so and the supervisor is adequately trained and experienced in providing services via telehealth. SPE can be accrued if they meet the requirements set forth in title 16 CCR section 1387.

Crisis

Does the primary supervisor need to be physically present at the work site if it is closed due to COVID-19?

Pursuant to title 16 CCR section 1387(b)(6): “ The primary supervisor shall be employed by the same work setting as the trainee and be available to the trainee 100% of the time the trainee is accruing SPE. This availability may be in-person, by telephone, by pager or by other appropriate technology.” Additionally, pursuant to title 16 CCR section 1387(b)(7): “Primary supervisors shall ensure that a plan is in place to protect the patient/client in the event a patient/client crisis or emergency occurs during any time the supervisor is not physically present at the established site at which the trainee is working. The primary supervisor shall ensure that the trainee thoroughly understands the plan in the event of a crisis/emergency.”

Continuity of Care for your Clients

What if I am in an impacted area and I cannot see clients?

The American Psychological Association has published guidance on how to prepare their practice for continuity of care including telepsychology guidance. For more information, go to COVID-19 and Psychology Services.

Please stay informed by visiting the federal Centers for Disease Control and Prevention website and CDPH website. Both websites are updated daily with the latest information and advice for the public.

What is the best way for licensees to comply with Business and Professions Code, section 2936-Consumers and Professional Education In Matters Relevant To Ethical Practice; Standards of Ethical Practice; Notice, when providing telehealth services?

The Board encourages that all licensees comply with laws as best they can while providing telehealth services. It is good practice to post the Notice to California Consumers and information regarding telehealth services in the most accessible form, such as through email or an attached link on the written assessment report.