Telemental Health Training & Resources

Internship & Practicum · Training Module

TeleMental Health

Georgia requires six continuing education hours before any licensee delivers clinical TeleMental Health. This page is the preparation and the reference. The six hours themselves are delivered live, and this page does not substitute for them.

Rule 135-11-.01 · Jurisdiction · Consent & suitability · Platforms & HIPAA · Crisis & risk · The room · Compact · Ethics
This page is not the training

Georgia Composite Board Rule 135-11-.01 requires a licensee to obtain a minimum of six continuing education hours before delivering clinical TeleMental Health. Those six hours are delivered live and synchronously. This page prepares you for them and remains available afterward as reference.

Reading it does not satisfy the rule. Nobody delivers TMH on the strength of having read a web page.

Board requirement
6 CE hours before clinical TMH
Supervisors
9 hours before TMH supervision
Format
Six live hours, synchronous
This page
Pre-work & reference
Who needs what
If you areYou need
A licensee delivering clinical TMH Six CE hours before your first TMH session
A supervisor delivering supervision by TMH Nine hours — the six above plus three on supervising TMH therapy
A practicum student or intern The six hours, plus TMH written into your internship contract, plus a supervisor who meets the rule
Someone who took the hours recently Nothing further — hours taken within the last five years do not need repeating
Hours obtained under this rule within a two-year licensure cycle may be applied toward the thirty-five hours required for that cycle’s renewal. The training counts twice, which is worth knowing when you plan your CE.
The eight content areas

The board names eight areas the six hours may cover. The live training works through all of them; this page is organised the same way.

  • Internet use and technology-related psychological problems
  • Research on TeleMental Health
  • Intake, assessment, suitability, and informed consent
  • Delivery methods — video, phone, chat, asynchronous
  • Theory integration — adapting in-person work to the screen
  • Termination and re-contact
  • Risk management, HIPAA, and legally sound process
  • The business of TMH — advertising, vendors, billing

HIPAA & FERPA module Disclosures module Collaboration module

Hour 1 — What the law actually requires

Ga. Comp. R. & Regs. r. 135-11-.01.

Definitions that decide cases
  • TeleMental Health is assessment, diagnosis, treatment, or supervision delivered by technology-assisted media.
  • The originating site is where the client is. The distant site is where you are.
  • Asynchronous store and forward is transmission of client information from the originating site to a licensee at a distant site without the client present.
What the rule requires
  • Same scope of practice and same ethics as in person. TMH does not expand what an intern may do. See Chapter 135-7, the Code of Ethics.
  • Six CE hours before delivering clinical TMH; nine before delivering TMH supervision.
  • Verbal and written consent, in the chart, before the first TMH session. Both. The consent must name third-party vendors — EHR, billing, platform, attorney.
  • If TMH is not suitable for a client, see them in person or terminate with referral.
  • Failure to comply constitutes unprofessional conduct.
Jurisdiction is the client’s physical location during that hour — not where they live, not where they were last week, not where their mail goes. A Georgia licence permits you to treat a client located in Georgia. A client who logs in from Alabama is Alabama practice, and you need lawful authority there.

Case 1

The beach house

An LPC in Douglasville has a weekly video client who lives in Marietta. In July the client joins from a rental in Florida. The counsellor runs the session anyway.

Teaching point. That hour you practised in Florida. A Georgia licence is not enough. Confirm and document location at the start of every session, and reschedule for when they are back in Georgia — or hold lawful authority in Florida. A Compact privilege, if one exists for that state, still has to be checked rather than assumed.

Case 2

The helpful intern

An APC has not finished the six-hour training. A no-show leaves a gap. The supervisor says, “just hop on video so they don’t drop.”

Teaching point. Delivering clinical TMH before the six hours is a board-rule violation for the licensee and a supervision problem for the supervisor. Offer an in-person slot, or a licensed person who has the hours. Convenience is not an exception.
Hour 2 — Intake, suitability, consent

A TMH-ready intake collects things an in-person intake never needed.

Identity and location
  • Legal name and date of birth
  • Exact physical address for this session
  • A phone number that actually works
  • Emergency contact near that location, with written permission to call them
  • Local 911 jurisdiction and nearest emergency department
Environment and capacity
  • Weapons in the home
  • Who else is in the dwelling, and whether private space is available
  • Technology access and literacy
  • Disability and sensory load — ADHD, autism, auditory processing, low vision
  • Risk screen: suicidal or homicidal ideation, domestic violence, psychosis, intoxication
The suitability decision

Every intake ends with an explicit determination, documented: TMH / hybrid / in-person only / refer out. It is a clinical judgement, it gets revisited, and it is not settled by the client’s preference alone.

Consent must cover
  • Benefits and limits of TMH, and the limits of confidentiality over a network
  • Recording policy
  • No-show and billing terms
  • Third-party vendors by name — platform, EHR, billing service
  • The right to in-person care instead
  • What happens if the call drops, and the crisis plan

Case 3

The teenager and the hallway

A sixteen-year-old in Cobb County joins from a tablet in a hallway. A parent walks through twice. The APC continues because “they consented.”

Teaching point. A minor’s assent is not consent — the legal custodian consents. Privacy is part of suitability, not a nicety. Pause, relocate, or convert to in-person, and document who was within earshot.

Case 4

“I don’t want to sign anything”

An adult with a trauma history will talk on video but will not sign the TMH addendum.

Teaching point. The rule requires verbal and written consent in the record. No signature, no TMH. Offer in-person. Showing up on video is not consent, and treating it as consent is the violation.
Hour 3 — Platforms, HIPAA, and the business of TMH
The platform
  • HIPAA-capable platform with an executed business associate agreement. Consumer FaceTime, WhatsApp, and Facebook are not practice platforms.
  • Encryption in transit, unique logins, screen lock.
  • No sessions where anyone can see or hear your screen. A coffee shop is not an office.
  • Verify identity and location every session, not just at intake.
Records and messages
  • Do not record without the client’s written consent to recording.
  • Text and email carry brief logistics only. Clinical content goes in the EHR.
  • Disclose the EHR, the billing company, and the platform in the consent.
  • TMH notes should show modality, client location, consent on file, and the risk screen.
The business side
  • Advertising is regulated. No “licensed in all states,” no outcome guarantees. See Chapter 135-10.
  • Medicaid carries additional written telehealth-consent language. Private pay still requires the board’s TMH consent.

Case 5

The kind screenshot

A counsellor screenshots a moving breakthrough to show in group supervision, blurring the face “enough.”

Teaching point. That is an image of a session, and it needs written consent to record. Consultation in supervision is permitted; capturing and sharing the client’s image is a different act. Use process notes, not the client’s face.

Case 6

The EHR that handles everything

A new practice uses an inexpensive scheduler that also stores notes. There is no BAA. The owner says the vendor is fine because everyone uses them.

Teaching point. No BAA is a HIPAA problem and a risk-management problem under 135-11. Stop putting protected health information through it until the vendor and the agreement are in place. Popularity is not compliance.
Hour 4 — Making therapy work on a screen

Same theories, different channel.

What changes
  • Slower pacing, more check-backs, shorter bursts.
  • Name the room. Lighting, sound, who else is there, pets, children.
  • Silence on video runs longer than silence in an office. Do not fill it out of your own discomfort.
  • Phone only costs you the face. Raise your risk assessment accordingly and document why audio-only was clinically necessary.
  • Hybrid is a legitimate plan. Some work is safer in person — a first trauma disclosure, certain couple and family work, significant dissociation.
Sensory and processing load

For clients with ADHD, autism, or auditory processing difference, the screen adds load that the office did not. Adjust deliberately: camera optional where clinically sound, written keywords, extra processing time, one speaker at a time, and an agreed signal — “if I fade out, say yellow.”

Case 7

The communication client

An adult with auditory processing difference and ADHD is fine on video until three family members start talking off camera. Speech races, and the homework is missed.

Teaching point. Sensory and processing load is a TMH variable, not a character trait. Headphones, a one-person-in-the-house rule, a written recap after session, or move that hour in person. This is a suitability question, not noncompliance.

Case 8

Couples on two screens, one house

Partners insist on joining from separate bedrooms so they can be honest. One later admits the other was standing outside the door.

Teaching point. You cannot guarantee privacy inside their home. Set the rule in advance — same room, or documented separate private spaces — and stop the session if safety or secrecy collapses. Consider in-person for this work.
Hour 5 — Crisis, duty to protect, mandated reporting

Agree the drop protocol before the first session, not during the first emergency.

If the connection dies
  1. Not an emergency. Wait two minutes, then the counsellor calls the client’s phone. You call them; you do not wait to be called.
  2. An emergency. The client calls 911 or goes to the nearest emergency department. The counsellor does not say “call me back.”
  3. Client unsafe and unable to call. Use the address you collected this session to direct emergency services.
Numbers every supervisee keeps to hand
988 — Suicide & Crisis Lifeline
1-800-715-4225 — Georgia Crisis & Access Line
911 — in the client’s jurisdiction, not yours
Acute risk — self-harm, suicide, homicide
  • Confirm location first. Before anything else, get the address and a working phone number for right now. Everything that follows depends on it.
  • Keep them on the line. Do not end the call to make another one. Use a second device, or ask a colleague or supervisor to call for you while you stay present.
  • Assess as you would in person — ideation, plan, means, intent, timeframe, protective factors — and remember you cannot see most of the room.
  • Means restriction is a conversation. Ask what is accessible and who could hold it. A support person on site, with consent, is worth more than any instruction you can give down a camera.
  • Homicidal ideation brings in duty to protect and possible warning obligations. Consult immediately; this is never a supervisee’s independent call.
  • Involve the emergency contact collected at intake, within the permission already obtained.
  • Supervisor during, not after — and document contemporaneously: observations, questions asked, answers, reasoning, actions, times.
Medical emergencies on camera

Clients have seizures, hypoglycaemic episodes, cardiac events, panic that looks like a cardiac event, and falls, while you watch and cannot reach them.

  • Know at intake whether a client has a condition that could become an emergency, and note it where you will see it before the session, not buried in the history.
  • If a client becomes unresponsive or is clearly in medical distress, call 911 for their location. This is precisely why the address is confirmed every session.
  • Stay on the call. You may be the only witness, and responders will want what you observed and when.
  • Contact the emergency contact within existing permission.
  • Document exactly what you observed and the times — not an interpretation.
What distance does not change
  • Duty to warn and protect still applies where there is clear and imminent danger. Distance makes acting on it harder, which is precisely why you collected the address and the emergency contact.
  • Mandated reporting of suspected abuse or neglect of a child, elder, or disabled adult is not suspended by the screen. A video session with a client located in Georgia is a Georgia mandated-reporter situation.
  • Intimate partner violence has a TMH-specific danger: the session can trap a client in the house with the person harming them. Agree a code word, a camera-off option, and a plan to hang up and call 911.

Case 9

The frozen screen

Mid-session a client says they have a plan and pills on the counter. The connection freezes. The counsellor has only last month’s Marietta address, and today the client mentioned being “at my sister’s.”

Teaching point. Location must be confirmed at the start of this session. Without it you cannot direct help. After stabilisation, update the protocol and reconsider whether TMH remains suitable until risk comes down.

Case 10

The bruise

On video a child client has a linear bruise. They say they fell. A parent is in the next room, audibly coaching answers.

Teaching point. Mandated reporting is not paused for TMH. Document what you observed in plain description, consult your supervisor immediately, and report as required. Do not interrogate the child on camera with the parent present — you may increase the danger.
The Orchard risk response protocol

Orchard’s own model, and the thing that distinguishes how we respond to distress. Learn the sequence; do not improvise one.

Most practices respond to risk at the point of crisis. Orchard responds at the point of distress — earlier, and on purpose. When we see someone struggling, we put resources in their hands straight away rather than waiting to see whether it escalates. The resources are already built, already vetted, and already online, which means the response costs nothing and can happen inside a single session.

That is a deliberate stance. A client given something useful at the moment they are merely struggling is a client who has it at 3am, and who has learned that reaching out produces something concrete.

The sequence
  1. Notice and name the distress. Out loud, without alarm. Distress is the trigger for this protocol — not a stated plan, not a threshold score.
  2. Stay with it in the session, and regulate together. Resources do not replace the conversation. Give the distress somewhere to go first, and use a self-regulation strategy with the client — see the next card.
  3. Put the resources in their hands, in session. Share your screen, open the pages together, and make sure they leave with a way back to them. Do not describe a resource and hope they find it.
  4. Assess. Structured risk assessment where indicated — PHQ-9, GAD-7, C-SSRS — alongside clinical judgement.
  5. Safety plan collaboratively where risk is present, using the Orchard form, completed together.
  6. Escalate as indicated, and involve your supervisor. For a supervisee, steps 4 through 6 are supervised, not independent.
  7. Follow up. Ask at the next session whether they used any of it. That question tells you more than the handing over did.
The three resources every supervisee should know cold
ResourceWhat it is for
Crisis Support Resources
OrchardHumanServices.org/c
Hotlines, emergency contacts, and escalation pathways in one place. The first thing you share when someone is in acute distress, and the page you should be able to open without searching.
Orchard Self-Care Guide
Downloadable e-book
Practical rather than aspirational, written for people who are already tired. Something the client keeps and uses between sessions, and it works as well for clinicians as for clients.
Hope
OrchardHumanServices.org/hope
Orchard’s digital wellness resources. Where the crisis page answers what do I do right now, this one answers is there anything beyond this — which for a despairing client is the more important question.

Crisis support Self-Care Guide Hope

Have these open before the session, not during it. Fumbling for a link while a client cries is a small failure with a real cost. Keep the three bookmarked in the browser you use for sessions, and know what is on each of them.
Sharing resources is not the same as managing risk. The protocol begins with resources because they are immediate and cost nothing — not because they substitute for assessment, safety planning, supervision, or escalation. A supervisee who shares a link and considers the matter handled has misread this entirely.
Self-soothing, self-calming & self-regulation

What you actually do at step 2 of the protocol — and what the client keeps after you log off.

Orchard teaches a small set of regulation strategies deliberately. Clients need something they can do without us, at 3am, with no equipment and no app. Every technique below works that way, and each can be taught over video.

Teach them before they are needed. A strategy introduced during a crisis is a strategy the client has never practised, and dysregulated people do not learn new skills well. Introduce one early, practise it in calm sessions, and it will be available later.

Head & Heart Holding, with heart-centredness

One hand rests on the forehead, one over the heart. Attention settles into the heart while the breath slows and lengthens. The contact is gentle and the holding is sustained — long enough for the settling to happen rather than a moment of contact and on.

  • Over video: do it with the client, both hands visible, and stay silent together once it is established. Your own regulation is doing much of the work.
  • Excellent for children, and for adults who find breath-focused work activating.
  • Self-touch is regulating and available anywhere, which is the point.
The physiological sigh — long, slow exhale breathing

Two inhalations through the nose, the second a short sharp top-up on an already full breath, followed by a long slow exhale through the mouth. One to three repetitions is usually enough. The extended exhale is what does it: it lengthens the out-breath relative to the in-breath and brings arousal down quickly.

  • Over video: demonstrate rather than describe, and breathe along audibly so they can follow the rhythm without watching the clock.
  • Works on the phone, which makes it the technique of choice when you have dropped to audio or the client has moved to a car or a walk.
  • Fast enough to use mid-sentence when someone is escalating.
Cook’s Hookups

A two-part posture from Educational Kinesiology. Seated: ankles crossed, arms extended and crossed at the wrists, fingers interlaced and the hands folded in toward the chest, tongue resting on the roof of the mouth, breathing slowly. Then the second position: legs uncrossed, fingertips lightly touching, breathing continued.

  • Over video: this one needs the camera repositioned so you can be seen from the knees up, and the client the same, or they will not get the posture. Worth the thirty seconds it takes.
  • Hold each part for a minute or two. Children often settle visibly in the first part.
  • Adapt freely for mobility or physical limitation — the crossing matters more than the precise arrangement.
Five Things grounding

Naming what is present through the senses: five things you can see, four you can hear, three you can touch, two you can smell, one you can taste. Attention returns to the room and to the present, which is exactly what dissociation and panic take away.

  • Over video: ask them to name things in their room, not yours. It anchors them where their body actually is — which matters when the screen is pulling their attention somewhere else.
  • The first choice for dissociation, flashback, or panic, where breath work can make things worse.
  • Works with children as a game, and with adults who find anything that sounds like meditation off-putting.
  • Slow it down. Rushing it defeats it.
Teaching these over video — what changes. Demonstrate, never just describe. Reposition your camera so your hands and posture are visible. Do it with the client rather than watching them do it, because co-regulation is much of the mechanism and it is thinner through a screen. Keep watching their face — a technique that is not working shows there first. And name a stopping signal before you start, so they can end it without having to explain.
These are not universally safe. Breath-focused work can trigger panic in some clients, particularly with a history of asphyxiation, respiratory illness, or panic disorder — use grounding instead. Eyes-closed and interoceptive work can deepen dissociation rather than ease it. Always offer an opt-out, always watch what actually happens rather than what should happen, and stop if the client becomes more activated. Discuss which strategy suits which client in supervision before you introduce it.
Learn the Orchard protocol for each of these from your supervisor. The descriptions above are orientation so you know what is being referred to. The precise form Orchard teaches — and how it fits the psychoneuroeducational approach and Fluid Trauma™ work — is taught directly, practised in supervision, and used with clients only once you can do it yourself under pressure.
The four things that make remote risk work

You cannot drive to a client, walk them to a waiting room, or take something out of their hand. What you have instead is preparation.

1. An emergency contact who is actually reachable

In an office, help is down the corridor. Online, the nearest person who can physically reach your client is someone you have never met — and only if you collected them in advance.

  • Collect the name, relationship, and phone number at intake, with written permission to contact them and agreement about what may be disclosed. Permission obtained during a crisis is worth much less.
  • They must be near the client’s usual location. A devoted sister three states away cannot check on anyone tonight.
  • Ask what the client would want said. Many will accept “tell him I need him to come over” while refusing “tell him what we discussed,” and that distinction is worth having in advance.
  • Ask whether the emergency contact is safe. Where there is abuse or coercive control, the obvious contact may be the danger. Never assume the person nearest is the person to call.
  • Re-check when circumstances change — a move, a separation, a bereavement.
  • Record it where you can see it before the session, not buried in the intake history.
2. Resources you can hand over instantly

One genuine advantage of working online: you can put something useful in a client’s hands inside ten seconds. Orchard maintains an extensive library of client-facing material precisely so you are not improvising.

  • Share your screen and walk through it together rather than sending a link and hoping.
  • Paste the link into the chat so they still have it after the call.
  • Follow up by email only where that is safe — see the caution below.
  • Know the library before you need it. Hunting for a resource during a crisis is not the moment.

Crisis support resources Full resource index Self-care guide

Before you email or text anything, ask who else sees that inbox. A safety plan, a crisis number, or a therapy resource arriving on a monitored phone can put a client in danger. Where someone is being watched, hand the material over on screen, or agree a safer route with the client.
3. A proper risk assessment

Screening is harder on a screen. You lose posture, smell, the state of the room, and much of what you notice without noticing. Compensate deliberately rather than assuming your in-person instincts transfer.

  • Use structured measures rather than relying on impression.
  • Ask about ideation, plan, means, intent, and timeframe directly. Indirectness costs more online, where you cannot read hesitation as well.
  • Ask what is in the room. You cannot see it. Means restriction begins with knowing what is accessible.
  • Screening results inform a clinical picture; they do not replace judgement or establish a diagnosis.
  • Document what you asked, what was said, what you concluded, and why.

Orchard completes three instruments. Administration and scoring guidance is on the site; know all three before your first intake.

InstrumentWhat it measuresAdministering it remotely
C-SSRS
Columbia Suicide Severity Rating Scale
Suicidal ideation and behaviour — severity of ideation, intensity, and any preparatory or actual behaviour Ask it aloud rather than sending it to be filled in. The questions are graded and they build; you need to hear the pauses. Never rush it, and never skip ahead because an early answer was no.
PHQ-9
Patient Health Questionnaire
Depression severity over the previous two weeks Item 9 asks about thoughts of self-harm or being better off dead. Never let that item pass as a number on a form — any positive response is followed up in conversation, in the session, before you move on.
GAD-7
Generalized Anxiety Disorder scale
Generalised anxiety severity over the previous two weeks Straightforward on screen or read aloud. Pairs naturally with the PHQ-9, and the two together give you a usable baseline to track.
Reading a scale aloud is a clinical act, not data entry. Online you lose the shift in posture, the delay before an answer, and the look away. Slow down, leave silence after the hard items, and watch the face rather than the form. If a client completes an instrument alone before the session, treat it as a starting point and go through the significant items with them — particularly where someone else may have been in the room while they filled it in.

Assessments — PHQ-9, GAD-7, C-SSRS MSE clinician reference

4. A safety plan the client helped write

Orchard’s safety planning form was assembled by Dr. Darleen Claire Wodzenski, drawing together current best practice from across her training and adapting it for Orchard’s use. Its six-step structure follows the Stanley-Brown Safety Planning Intervention, reprinted with the authors’ permission and credited on the form itself.

It is completed with the client rather than handed to them, and the collaboration is most of what makes it work — a plan written in the client’s own words, naming their own people, gets used. A plan filled in by the clinician and emailed over does not.

StepWhat it captures
1. Warning signs The thoughts, images, moods, situations, and behaviours that signal a crisis is building — in their words
2. Internal coping strategies What they can do alone, without contacting anyone, to shift their state
3. People and settings that distract Names, numbers, and places — social contact that helps without requiring disclosure
4. People to ask for help Those they could tell directly. Often the hardest step to fill in
5. Professionals and agencies Clinician, urgent care, and crisis lines, with numbers written in
6. Making the environment safe Means restriction, agreed concretely — what will be removed or secured, by whom, and when

The form closes by asking the one thing most important to the client and worth living for. Do not skip it because it feels sentimental; for many clients it is the line they return to.

Orchard Safety Plan (PDF)
Safety planning over video
  • Complete it together on screen, sharing your screen so they watch it being written, then get a copy into their hands the same session.
  • Ask where they will keep it. A plan in an email they cannot open at 3am is no plan — a photograph on their phone or a paper copy by the bed works better.
  • Step 6 is harder remotely. You cannot help remove anything, so it must be specific: who is holding it, where it is going, by when, and how you will know it happened.
  • Revisit it. A safety plan written in month one and never mentioned again is a document, not a plan.
Note on the current form. The Orchard Safety Plan lists the Lifeline as 1-800-273-8255. That number still routes, but 988 is the current three-digit Suicide & Crisis Lifeline and is far easier to recall in crisis. Write 988 on the form when you complete it with a client, and add the Georgia Crisis & Access Line at 1-800-715-4225.
You are a guest in a room you cannot see

The board’s first content area is internet use and technology-related psychological problems. This tab covers that, plus everything else about the space your client is actually sitting in.

In an office you control the room. You know who is in the building, whether the door locks, what is on the desk, and whether anyone is listening. Online you know none of that unless you ask, and clients rarely volunteer it. Almost every serious TMH incident traces back to something in the client’s environment that the clinician had not asked about.

Ask every session
Where are you, who is with you, can you be overheard
Screen at intake
Weapons, violence, substances, instability
Never assume
A closed door means privacy
Document
Location, privacy, who was present
Online dangers your clients are living with

Technology is not only how you reach the client. For many clients it is also where the harm is happening. Screen for it, and know that a client’s online life is clinical material rather than a side topic.

Contact risks
  • Grooming and predatory contact, especially through games, chat features, and direct messages
  • Sextortion — an image is obtained, then used to extort more images or money. Rising sharply among adolescent boys, and a recognised driver of youth suicide
  • Trafficking recruitment, which often begins as friendship, a job offer, or a relationship
  • Radicalisation into violent extremism
  • Scams targeting older, isolated, or cognitively impaired clients — romance, tech-support, and impersonation fraud
Content and behaviour risks
  • Pro-suicide, pro-self-harm, and pro-eating-disorder communities, which supply method, encouragement, and belonging at once
  • Harmful challenges and dares
  • Algorithmic amplification — a single search can reshape a feed toward the worst version of a preoccupation
  • Gaming and gambling disorder, including loot mechanics aimed at children
  • Cyberbullying, which unlike playground bullying follows the child home and has an audience
  • AI companions and chatbots substituting for relationship, and occasionally reinforcing harmful beliefs
Ask directly, without alarm. “Who do you talk to online that you have never met in person?” and “has anyone online ever asked you for pictures, or asked you to keep something secret?” get answers that “are you safe online?” never will. Judgement closes the topic instantly, and a client who feels judged will not raise it again.

Case 12

The secret friend

A fourteen-year-old mentions in passing that an online friend of two years — an adult who says he is nineteen — has been sending gift cards and asking her not to tell her mother. He has recently suggested moving to a different app.

Teaching point. Gifts, secrecy, age ambiguity, and moving to another platform are the recognised grooming sequence. Stay calm, do not interrogate, do not shame the relationship — to her it may be a real friendship. Record what she said in her own words. Consult your supervisor the same day. This is very likely a mandated report, and it is not a supervisee’s determination to make alone.
The session itself puts them online

A point that is easy to miss: by meeting you on video, the client is on the internet. That is an exposure we created.

To attend a session, a client opens a browser or an app on a device, often signs in, and frequently uses a network they do not control. Merely being there carries risk that has nothing to do with what you talk about.

  • Phishing. Fake meeting invitations and “your session link has changed” messages are a known attack pattern. Tell clients at intake exactly how you send links and that you will never ask for a password. Then never break that pattern.
  • Identity theft. Clients who are unwell, isolated, or cognitively impaired are disproportionately targeted, and a client managing a crisis is not evaluating a suspicious email carefully.
  • Targeted exploitation. Time spent online is opportunity. A distressed adolescent in a waiting room tab is reachable.
  • Disclosure of their own health information. A shared or family device, a browser that remembers, a calendar entry naming the practice, an auto-saved password. Clients expose their own care without realising, and the consequences are theirs.
The work computer problem

The most common version, and the one clients least expect. Someone books a lunchtime session and joins from the laptop their employer gave them, on the employer’s network, from an empty meeting room. Two separate things then go wrong.

  • They may be breaking a rule they never read. Acceptable-use policies commonly prohibit personal use, installing applications, and non-work video calls. A client can face discipline for the act of attending therapy, entirely apart from its content.
  • They may be disclosing a health condition to their employer. Employers can typically see network traffic, visited domains, installed software, and calendar entries. Many run monitoring that captures screenshots or keystrokes. A device may be remotely inspected or wiped, and an IT administrator may read what is on it. A practice name in a browser history or a calendar can reveal a diagnosis, a treatment relationship, and its timing.
  • They lose the protection they assume they have. Information a client volunteers to their employer this way is not shielded by HIPAA, which binds us rather than them. The disclosure is theirs, it may be irreversible, and it can affect employment, clearances, and licensure.
  • Privacy is usually worse than it looks. A glass-walled meeting room, a booking system showing who reserved it, a colleague outside, and a call that may be recorded by the platform under company policy.
Say this at intake, before it happens. Ask plainly where the client plans to join from, and whether the device and network belong to an employer. If they do, explain what their employer can generally see and let them decide knowingly. Most clients have simply never thought about it, and the conversation takes two minutes. Offer alternatives: a personal phone on cellular data rather than the office wi-fi, a session outside working hours, or a car park — parked, engine off — if that is genuinely the only private space they have.
Cover this in consent, plainly. Shared devices, public computers, public networks, saved credentials, and browser history are named in the ACA and NBCC standards for exactly this reason (ACA, 2014, H.2.b–H.2.d; NBCC, 2023, Standards 97–101). Say it in language a worried person can act on: use your own device if you can, do not save the password, clear the history if others use the machine.

Case 17

The lunchtime session

A client with a new anxiety diagnosis books midday sessions and joins from a company laptop in a bookable meeting room. Three months in, she is asked by her manager whether “everything is alright,” and mentions that IT flagged repeated video calls to an outside domain. She is frightened, and asks whether you can confirm to her employer that the calls were medical.

Teaching point. Two failures here, and the first is ours. This should have been asked at intake and was not. Do not contact the employer — that would disclose the very thing she is trying to protect, and it is not yours to disclose. Explain what you can and cannot do, help her think through her options, and route any letter through the client for her approval before it goes anywhere, under Orchard’s client-routed policy. Change the meeting arrangement immediately, and add the question to every intake.
Three patterns that recur

Composite scenarios drawn from repeated clinical experience at Orchard. Details are changed; the patterns are not rare and you should expect to meet them.

What links all three is that the young people targeted are the ones we are already treating. Emotional difficulty, trauma history, and attachment disruption are not incidental to this — they are what makes a young person reachable. Someone offering to understand, to belong, or to love is offering the thing that is missing. That is the mechanism, and it is why your clients are at elevated risk rather than average risk.

Pattern 1

Recruitment into violent online groups

An adolescent with depression and few friends finds a group online that takes him seriously. Over months the content shifts: grievance, then ideology, then hostility toward his own country and encouragement to see cruelty as strength. He is drawn into war-themed games and pushed toward escalating acts, including harming animals and himself, filmed to prove loyalty. He describes the group as the only place he is respected.

What you may notice. New rigid political or ideological language that does not sound like him. Secrecy about online contacts. Escalating desensitisation to violence. Withdrawal from family alongside intense loyalty to people he has never met. Self-harm framed as proof or duty rather than relief. Sleep collapse from night-time contact.

Teaching point. Do not argue with the ideology — that is the group’s recruiting tool and you will lose. Stay curious about what the group gives him, because that is the clinical material: belonging, status, an explanation for pain. Assess self-harm and harm to others directly. Consult your supervisor the same day. Coerced self-harm and filmed acts are exploitation, not conduct problems, and reporting obligations are likely engaged. NCMEC identifies violent online groups as a growing driver of child exploitation, so treat this as recognised, not exotic.

Pattern 2

Luring out of the home

An adolescent with a trauma history and disrupted attachment is contacted by an adult who is patient, attentive, and available at 2am. Over weeks the relationship becomes the most reliable one she has. He builds a story in which her family does not understand her and he does. Eventually he arranges to meet her, and she leaves the house to go.

What you may notice. A new relationship she will not describe. Gifts, money, a phone or account you did not know about. Secrecy framed as protecting the relationship. Talk of running away, or of someone who “really gets” her. Unexplained absences. Sudden confidence about a future elsewhere.

Teaching point. Attachment disruption is the vulnerability being exploited. Condemning the relationship confirms his story that nobody else understands, and pushes her toward him. Stay warm and curious; hold the concern without contempt. Assess for imminent plans to meet. Consult immediately — this is very likely a mandated report and may be an emergency. Safety planning includes the parents, and the conversation with them must be handled so she is protected rather than punished.

Pattern 3

Sextortion, and coercion toward suicide

In a chat platform an adolescent is drawn into sexual conduct on camera, which the perpetrator records without her knowledge. He then uses the recording to demand more, and to control her. When she becomes distressed and threatens to tell, he tells her the recording will be sent to everyone she knows, that her life is finished, and that the only way out is to end it. He is trying to remove the witness.

What you may notice. A sudden and severe change with no stated cause. Acute shame, secrecy, panic tied to the phone. Terror of a specific person finding out. Statements that there is no way out, or that everyone would be better off. Deleting accounts, giving things away, sudden calm after agitation.

Teaching point. Shame is the weapon. The coercion only works while she believes she did something unforgivable and is alone with it. Your first intervention is to break that, in plain words: this was done to you, you are not in trouble, this is a crime and you are the victim of it, and there are people whose job is to get it taken down. Then a full risk assessment — suicide risk here is acute and driven by an active adversary. Supervisor immediately, during the session if needed. Mandated reporting applies. Do not ask to see the material, do not ask her to send it anywhere, and do not contact the perpetrator.
What none of these are is a supervisee’s solo call. Each engages mandated reporting, possible imminent danger, and coordination beyond the session. Your job is to recognise it, respond without shame or alarm, keep the young person talking, and get your supervisor involved the same day. Document in the client’s own words.
Where to report, and what to tell a family

Know these before you need them. Reporting is directed by your supervisor, but you should be able to say what exists.

ResourceWhat it is for
NCMEC CyberTipline
report.cybertip.org · 1-800-843-5678
The national reporting system for online child sexual exploitation, including enticement, sextortion, and trafficking. Analysts route reports to the right law enforcement agency.
Take It Down
takeitdown.ncmec.org
A free NCMEC service to help remove nude or sexually explicit images and video of someone taken while under 18. Often the single most restorative thing you can offer — it answers “it will be out there forever” with something concrete.
Georgia DFCS
Child Protective Services intake
Mandated reporting of suspected child abuse or neglect under O.C.G.A. § 19-7-5.
911 · 988 · GCAL
1-800-715-4225
Imminent danger, acute suicide risk, and crisis stabilisation.
Telling a young person that Take It Down exists changes the conversation. Much of the despair in sextortion comes from believing the images are permanent and public. That belief is what the perpetrator is selling. Being able to say truthfully that there is a free service that removes this material, and that adults do this work every day, is both accurate and clinically powerful.
The physical space
What to screen at intake and re-check when anything changes
  • Weapons in the home, and access to them. Ask plainly. This matters most for exactly the clients least likely to raise it.
  • Who else is in the dwelling, and their relationship to the client and to the material being discussed.
  • Violence or instability — an intimate partner who monitors, a volatile household member, active substance use, eviction, no reliable power or connection.
  • Medical vulnerability — seizure disorder, diabetes, cardiac conditions, pregnancy, anything that could become an emergency on camera.
  • Where they will actually be. Not where they intend to be.
Places that are not a session
  • A moving vehicle. Never. Not stopped at lights, not on hands-free. End the session and reschedule. The risk is to the client, to other road users, and to you.
  • A workplace, unless genuinely private and the client understands the employer may monitor the network.
  • Public space — a café, a car park, a library. No confidentiality, and often no safety.
  • A bathroom or a wardrobe. Common with clients who have no private space, and a signal to reassess suitability rather than to carry on regardless.

Case 13

The commute

A client joins on time, camera on, clearly driving. They say they always do this and the last counsellor did not mind.

Teaching point. End the session. Say why, warmly and without negotiation: you cannot do good work with someone whose attention is on the road, and you will not be part of a crash. Offer to reschedule, and put the expectation in writing so it is not relitigated weekly. What a previous clinician allowed does not set your standard.

Case 14

What is on the table

Halfway through a session with a client reporting worsening depression, you notice a handgun on the table behind them. They have never mentioned owning a firearm.

Teaching point. Name it calmly and directly — “I can see there’s a firearm behind you, and I want to talk about that.” Move to a full risk assessment. Means restriction is a conversation, not an instruction: explore who else could hold it, and involve a support person with consent. Contact your supervisor during or immediately after the session. Update the record: intake said no weapons, and that is now wrong.
Privacy during the session

Privacy is a condition of the work, not a preference. A client who cannot speak freely is not receiving therapy, however willing they are to try.

  • Ask at the start of every session, not just the first: “Are you somewhere you can talk freely? Is anyone else home? Could anyone hear you?”
  • Watch for the signs — volume dropping, glancing off camera, one-word answers, headphones removed, a door opening.
  • Agree a code word at intake that means someone came in and I cannot say so. Agree what you will do when you hear it.
  • Headphones are a minimum expectation, not an accommodation.
  • If privacy fails mid-session, stop the clinical content. Move to neutral ground, or end and reschedule. Do not push on quietly hoping it holds.
  • Document that privacy was checked, and what you did when it was not there.
Where privacy repeatedly cannot be obtained, TMH is not suitable for that client at that time. That is a suitability decision under Rule 135-11-.01, it is documented, and it is discussed with your supervisor — not a difficulty to be worked around indefinitely.
When someone else is listening on purpose

Not every privacy failure is accidental. Some clients are being watched, and the watching is the point.

A client without privacy is one problem. A client whose privacy is being taken is a different and more serious one, because it usually means the thing they most need to talk about is the person in the next room.

The range you will meet
  • Curiosity. A nosy roommate or relative who hovers because they want to know. Irritating, usually harmless, and often solved by a conversation.
  • Suspicion. A partner who believes therapy is where the client is being turned against them, and who therefore needs to hear it. Frequently an early sign of controlling behaviour rather than insecurity.
  • Illness. A household member with paranoid symptoms who believes the session is about them, and listens because their illness tells them it concerns them. Not malice, and it needs a different response — but the client’s privacy is gone all the same.
  • Coercive control. Deliberate, systematic monitoring: staying within earshot, demanding to know what was said, checking the device, installing monitoring software, insisting on being present. This is abuse, and the session is a threat to it.
  • Silencing a child. A parent who lurks in the background precisely so the child cannot disclose what is happening at home. The most consequential version, and the hardest to name.
Three things are at stake, not one. The client’s privacy rights, their physical safety — because being overheard can bring retaliation after you log off — and their emotional safety, because a person who cannot speak freely learns that therapy is another place they must perform. Weigh all three. Sometimes the safest thing is to say less, not more.
When there is simply nowhere private

Poverty, overcrowding, thin walls, shift work, a studio flat, children everywhere. This is not the client’s failing and it should never be treated as noncompliance. But it is real, and pretending otherwise serves nobody.

  • Headphones or earbuds are a minimum, not a solution. They stop others hearing you. They do nothing to stop others hearing the client. Say that plainly rather than letting the client assume they are protected.
  • The car. Parked, engine off, doors locked. For many clients this is the only door that actually closes, and it is a reasonable place to hold a session. It must be stationary — a moving vehicle is never a session.
  • A walk outdoors. Away from the house, on the phone, with earbuds. Privacy improves, and for some clients the movement itself helps — harder conversations often come more easily side by side than face to face. Check they are somewhere safe, not crossing roads, and able to stop and sit if the material becomes heavy.
  • Move to the phone. The platform generally runs on a phone, and a phone goes where a laptop cannot — the car, the garden, a walk, a locked bathroom. Where safety or privacy is the governing concern, part of a session may be completed by phone: begin on video, move to audio when the sensitive material arrives, and return if it makes sense. Document why audio-only was clinically necessary, and remember you lose the face, so your risk assessment has to work harder.
  • Timing. When is the dwelling empty? A session at an odd hour may be the whole intervention.
  • A library study room. Free, bookable, quiet, and often the best option nobody thinks of. Many branches have private rooms with a door and reliable wi-fi, and using one draws no attention at all.
  • A friend, neighbour, or relative’s house. A spare room at someone trusted, at an agreed time. Worth asking who in the client’s life already knows they are in therapy — that person may be the answer.
  • A private room at a coffee house or similar venue. Some have bookable rooms or quiet corners. Check it is genuinely enclosed, and use headphones — a corner table is not privacy.
  • A community centre or place of worship, which will often make a room available on request.
  • In-person. For some clients the drive is the only privacy they get.
Offer these as options, not instructions. The client knows their household, who notices what, and what leaving the house at a particular time would mean. Where someone is being monitored, an unexplained walk or a locked car can itself raise suspicion. Ask what would be safe rather than assigning a solution.
Using the chat, carefully

Where a client can be overheard but not seen, typing the most sensitive material into the session chat lets them say what they cannot voice. It is a genuinely useful adaptation and it carries its own risks, so use it deliberately.

  • Agree it in advance, so the client is not improvising while frightened.
  • Check who can see the screen before relying on it. Typed words are visible from further away than speech carries.
  • Chat may be logged by the platform and may persist in the record. Know what your platform does and tell the client.
  • Clear the chat before the session ends, and know whether that actually deletes it.
  • Consider whether the device itself is monitored. Where there is coercive control, monitoring software on a phone or laptop is common. If the device may be watched, typing is less safe than speaking, not more.
  • Keep it for what is genuinely necessary. A session conducted entirely by typing is a signal that this arrangement is not working.
Other adaptations worth agreeing at intake
  • A code word meaning someone came in and I cannot say so, and an agreed response — you switch to neutral content immediately, without hesitating.
  • A camera-off option the client can use without explaining.
  • An agreed cover story for the call, decided by the client.
  • A plan for hanging up and calling 911, and what you will do if the call ends abruptly.
  • Agreement about whether you may call back, and on which number, since a callback can be dangerous where a partner controls the phone.
Never test whether someone is listening by asking a leading question. “Is your husband home right now?” can put a client in danger if he is standing behind the screen. Ask neutral questions with agreed answers, use the code word, and where you suspect coerced monitoring, raise it with your supervisor rather than probing in the moment.
Two cases worth working through

Case 18

The partner who is always nearby

An adult client attends reliably. Her husband is always somewhere in frame or just outside it — bringing tea, fetching something, asking a question. She becomes vague whenever the marriage comes up. In week six she says, brightly, “he likes to know what we talk about, he just worries.”

Teaching point. Take that seriously as data. Do not name it as control in the session — you may be overheard, and you may be wrong. Move to neutral ground, and find a way to reach her alone: a different time, a different place, audio only, or in person. Consult your supervisor about intimate partner violence screening conducted safely. Agree a code word and a camera-off option now rather than later. And remember the specific danger of TMH here — the session can trap her in the house with him, and anything he overhears has consequences after you log off.

Case 19

The parent who will not leave

A nine-year-old is referred after a school report of bruising. Her father sets up every session and remains in the room, pleasant and involved, answering for her. When you ask to speak with her alone he says she gets anxious without him, and she nods.

Teaching point. A child cannot disclose harm in front of the person who may be causing it, and her agreement means nothing under those conditions. Do not challenge him on camera — you may increase her risk. This is a suitability determination: TMH may not be appropriate for this child at all, and in-person assessment where she can be seen alone may be necessary. Consult your supervisor the same day, and remember that a report requires reasonable cause to suspect, not proof, and not a disclosure from the child.
The child, the internet, and the watching adult

A genuine conundrum with no clean answer, and one you will meet early.

A child in a session is a child on the internet. Left alone with a device they may wander into material no one intended, and a responsible adult would supervise that. But an adult sitting in earshot means the child has no confidential space — and confidentiality is much of what makes therapy possible.

Both concerns are legitimate. Resolving it well is a clinical skill, and the resolution is explicit and documented rather than left to chance.

A workable sequence
  1. The adult sets up, then withdraws. A parent joins, confirms the connection works and the child is settled, then leaves the room — remaining in the house and reachable. This is the default at Orchard.
  2. Manage the device, not the conversation. Supervision of internet risk belongs to the platform and the device: a session opened by the adult, on a locked-down browser or profile, with nothing else reachable. It does not require a human listening.
  3. Nearby but out of earshot. Door ajar, adult in the next room, child in headphones. The adult can respond in seconds without hearing content.
  4. Agree the terms with everyone, out loud. Tell the child what the adult can and cannot hear. Tell the parent what will and will not be shared, and why. A child who suspects the adult is listening will manage the session rather than use it.
  5. Where an adult must remain present, say so. For a very young child, or one who cannot be left, presence may be unavoidable. Then be honest with the child that this is not a private conversation today, and adjust what you do accordingly.
  6. When it cannot be resolved, it is a suitability decision. In-person, hybrid, or referral. Document the reasoning.
Say the quiet part to the parent. Most parents accept stepping out once someone explains why: children disclose worries they are protecting their parents from, and a child who is being overheard protects them by staying silent. Framed as helping their child rather than excluding them, this conversation almost always lands.

Case 15

The mother in the doorway

A ten-year-old is being seen for anxiety. His mother sets up the call and then stays, seated just out of frame. The boy’s answers get shorter each week. In week four he says “everything’s fine” eleven times.

Teaching point. That is not a child with nothing to say; it is a child performing for an audience. Address it outside the session, with the parent, without blame — she is doing what she believes is responsible. Offer the sequence above: she sets up, locks the device, waits in the next room. Agree what she will be told. Then check with the boy whether anything changed, because he will know before you do.

Case 16

The tab that was already open

A twelve-year-old shares her screen to show you a drawing, and you see an open tab from a forum where users compare methods of self-harm.

Teaching point. Do not react to the screen; react to the child. Stay warm and matter-of-fact, ask about it directly, and complete a risk assessment. This is clinical material, not a discipline matter, and treating it as misbehaviour ends the disclosure. Supervisor same day. Then a separate conversation with the parent about device supervision — framed around safety, not blame, and without repeating content the child shared in confidence beyond what safety requires.
Hour 6 — Endings, internships, and the Compact
Termination and re-contact
  • Plan a final session. Provide written aftercare. Give a route back if the platform fails.
  • Ghosting is more common online. Have a documented outreach sequence, follow it, then close the file properly.
Interns and supervisees
  • Only after the six hours. Only within the internship contract. Only with a supervisor who meets the rule.
  • Supervision by video is permitted where the supervisor meets 135-11 and 135-5 — which means the nine hours if supervision itself is remote.
  • Keep contemporaneous supervision logs: date, duration, type, brief summary.
  • Supervisors must obtain the supervisee’s verbal and written consent to supervision by TMH, just as with clients.
The Counseling Compact

Georgia began issuing Compact privileges on 2 June 2026, becoming the fifth state to go live. As of 1 September 2026 the Compact was operational in nine jurisdictions: Arizona, Arkansas, Georgia, Indiana, Louisiana, Minnesota, Ohio, Tennessee, and Wyoming. Around forty jurisdictions have enacted it, but enacted and operational are different things.

  • You need an unencumbered, independent, highest-level licence in a live home state where you also reside. LPCs, not APCs.
  • Both states must be operational. A privilege only works between two live states.
  • Privileges are state-by-state and the roster changes month to month. Check the Compact Commission before every out-of-state client.
  • A privilege may authorise practice without satisfying an insurer, a panel, or a platform. Those are separate questions.
What this means at Orchard specifically. Orchard serves clients in Georgia, Virginia, and Florida. Virginia and Florida have enacted the Compact but are not yet operational, so a Georgia Compact privilege does not reach them. Our authority in those states rests on the Virginia licence and the Florida out-of-state telehealth registration — not on the Compact. Do not treat the Compact as covering Orchard’s existing caseload.
Check the live state roster

Capstone · Case 11

The whole mess

An APC in the Douglasville internship sees a new adult client from a personal laptop in a café, using a consumer video app, with no TMH consent signed. The client is driving home from Tennessee. Mid-session the client says they might not want to be alive tonight. The intern texts the supervisor a screenshot of the chat.

Work the room through three questions. What was already out of bounds before anything went wrong? What do you do in the next ten minutes? What do you do this week, as supervisor and as agency?

Expected answers. Get the client’s current location and phone number. 911 or the Georgia Crisis & Access Line if indicated — noting the client is in Tennessee, which is its own jurisdictional problem. The intern leaves the café. No screenshots. Stop all TMH until consent, platform, and the six hours are genuinely in place. File an incident report. The intern does not practise TMH again until signed off.
Ethics codes sit on top of the board rule

Rule 135-11-.01 tells you what Georgia requires. ACA, NBCC, and APA tell you what the profession expects. You are answerable to all of them.

Professional ethics codes do not replace federal or state law, board rules, payer requirements, malpractice-policy conditions, or agency policy. You must comply with every jurisdiction the encounter touches — above all the one where the client is physically located. Where the authorities differ, use the most protective lawful standard and seek board or legal consultation (ACA, 2014, H.1.b, I.1.c; APA, 2024, Guideline 6; NBCC, 2023, Standards 92–93).

SourceAuthority & statusTelehealth focus
ACA Ethics code for ACA members; standards support ethics complaints Section H — distance counseling, technology, and social media
NBCC Enforceable ethics code for NBCC certificants and candidates Standards 91–108 telemental health; 109–114 social media and technology
APA Aspirational practice guidelines, not independently enforceable standards Eleven 2024 telepsychology guidelines; psychologists remain bound by the APA Ethics Code, law, and regulation
The ACA code is mid-revision. The 2014 code remains the current, enforceable version. A revised code has completed public comment and is expected to be adopted by the ACA Board in autumn 2026, moving to a shorter core document with supplemental guidelines that can be updated more nimbly. Check the ACA source before relying on any citation here, and expect Section H numbering to change.
The shared core

Read together, the three authorities agree on a consistent minimum. You must be competent in both the clinical service and the technology; verify telehealth suits this particular client; obtain telehealth-specific informed consent; protect privacy and data; practise lawfully across jurisdictional boundaries; document the encounter and the decisions behind it; plan for technology failure and emergencies; and keep reassessing whether remote care remains safe and effective (ACA, 2014, Section H; APA, 2024, Guidelines 1–9; NBCC, 2023, Standards 91–108).

Competence and appropriateness
  • Practise only within demonstrated competence in the service, the modality, the technology, the population, and the legal requirements (ACA H.1.a; APA G1; NBCC 91).
  • Screen every prospective telehealth client and document whether remote work fits their goals, condition, cognitive and functional abilities, language, technology access, privacy, and safety (ACA H.4.a, H.4.c; APA G1, G7; NBCC 99–100).
  • Keep monitoring. If telehealth becomes ineffective or unsafe, say so and arrange in-person care, a different modality, or referral (ACA H.4.d; APA G7; NBCC 99–100).
  • Account for multicultural, linguistic, socioeconomic, disability, sensory, cognitive, and digital-access factors. Do not assume comfort with technology is evenly distributed (ACA H.4.c, H.5.d; APA G1, G2, G7, G8).
Documentation and retention
  • Document what is unique to remote delivery: modality, locations, consent, appropriateness, disruptions, risk and safety decisions, referrals, consultations (APA G5; NBCC 92, 95, 99–100, 106).
  • NBCC sets a minimum five-year retention period for telemental health records unless state law requires longer. Other legal, contractual, and organisational requirements may extend it — keep to the longest that applies (NBCC 108).
  • Explain to clients how electronic records are kept, protected, archived, and disposed of (ACA H.5.a; APA G3–G4; NBCC 97, 101).
Boundaries, electronic communication & social media

The area the board rule says least about and where supervisees most often go wrong.

  • Set written expectations for which electronic communications are clinically permitted, what content belongs in them, response times, emergencies, and boundaries outside scheduled sessions (ACA H.2.a, H.4.b; APA G2; NBCC 96).
  • Keep personal and professional online presences separate. Do not enter personal virtual relationships with current clients — no friending, no following, no direct messages (ACA A.5.e, H.6.a; NBCC 109, 114).
  • Adopt a written social-media policy and discuss it during informed consent: what it offers, what it does not, the privacy risks, and the boundaries (ACA H.2.a, H.6.b; NBCC 109).
  • Do not search a client’s social media without consent and a legitimate clinical purpose. NBCC also requires the risks and benefits to be discussed and documented (ACA H.6.c; NBCC 107, 113).
  • Never disclose confidential information through public social media. Know and use the privacy settings available to you (ACA H.6.d; NBCC 110–112).
The curiosity problem. Looking up a client online feels like diligence and is usually not. If you believe there is a genuine clinical reason — a safety concern, for instance — raise it in supervision first, get consent where required, and document the reasoning. Never search a client because you wondered.
Remote testing and assessment

Before administering any instrument remotely, determine whether the instrument, its norms, the administration procedure, the environment, the technology, and test security actually support valid use. Document every adaptation and its limitations (APA, 2024, Guideline 8).

  • Consider distractions, assistance from others in the room, identity uncertainty, monitoring limits, equipment differences, disability accommodations, unequal technology access, and the absence of remote norms — each can affect validity and interpretation.
  • Use particular caution in forensic, neuropsychological, educational, and other high-stakes evaluations, where remote administration may face heightened scrutiny or may not be accepted at all.
Supervisees do not administer instruments remotely without explicit supervisor approval, instrument by instrument. Some of what we use at Orchard is not validated for remote administration, and a screening tool administered badly is worse than no screening at all.
Telesupervision and emerging technology
  • Supervisors must be competent in the clinical service, the telehealth modality, and the telesupervision technology, and must address privacy, recordings, observation, emergency backup, immediate consultation, trainee competence, and jurisdictional rules (APA, 2024, Guideline 10).
  • Apply the same ethical, legal, empirical, privacy, safety, and competence analysis to emerging tools — artificial intelligence, virtual and augmented reality, wearables, digital monitoring — as to established telehealth technology (APA, 2024, Guideline 11).
Orchard’s continuing education includes Water Keeper, on the ethical use of artificial intelligence in mental health care. Guideline 11 is the professional standard behind it: a new tool does not get a lighter analysis because it is new.
Where the three differ
  • ACA gives the most detailed counsellor duties across competence, consent, security, client verification, accessibility, records, boundaries, and social media.
  • NBCC is the most operationally prescriptive, and therefore the most useful when writing policy: encrypted communications, written communication boundaries, written client security information, documented screening, written emergency procedures, verification of identity and location and readiness at each contact, documentation of relevant state requirements, and five-year retention (NBCC, 2023, Standards 92–108).
  • APA distinguishes aspirational guidelines from mandatory standards, and goes furthest on data management and disposal, remote assessment, emergencies, telesupervision, equity and access, vendor risk, and emerging technology (APA, 2024).
Practical consequence. When Orchard writes a TMH policy, NBCC standards are the sensible drafting baseline because they are specific enough to implement, while APA supplies the reasoning for areas the others treat lightly. Georgia’s rule is the floor beneath both.
Compliance checklist

Drawn from all three sources. Work down it before your first remote session with any client.

  • Confirm you are qualified for this service, modality, technology, and population
  • Verify authority to practise where both you and the client are physically located, and document the analysis
  • Screen and document telehealth appropriateness, access, accommodations, privacy, and safety
  • Obtain and document telehealth-specific informed consent; guardian consent and assent where applicable
  • At every contact, verify identity, current physical location, readiness and privacy, and a callback number
  • Use legally compliant encrypted systems; evaluate vendors, devices, access controls, backups, and breach procedures
  • Keep a client-specific local emergency plan and a technology-failure backup plan
  • Define communication channels, response times, social-media boundaries, fees, and insurance limitations
  • Document modality, locations, contacts, disruptions, risk decisions, consent updates, referrals, and consultations
  • Reassess effectiveness and safety; transition or refer when remote care no longer serves the client
  • Retain and securely dispose of records under the longest applicable requirement
Materials issued to every trainee

Distributed at the live training. Keep them where you can reach them during a session, not filed away.

  • Rule 135-11-.01 one-pager
  • TMH informed-consent addendum — verbal and written, vendors listed
  • Session-start checklist — identity, city and state and address today, emergency contact, privacy, weapons and risk
  • Drop and crisis flowchart — 911, 988, 1-800-715-4225
  • Suitability rubric — TMH / hybrid / in-person / refer
  • Platform and BAA checklist
  • Compact and out-of-state decision tree
The session-start checklist is the one that saves you. Nearly every case on this page turns on something that checklist would have caught — location, privacy, consent, or a working phone number.
References
Georgia authority
  • Ga. Comp. R. & Regs. r. 135-11-.01 (TeleMental Health). Authority: O.C.G.A. §§ 43-1-19, 43-1-24, 43-1-25, 43-10A-2, 43-10A-5, 43-10A-16, 43-10A-17.
  • Ga. Comp. R. & Regs. ch. 135-5 (Requirements for Licensure, including supervisor and supervision requirements).
  • Ga. Comp. R. & Regs. ch. 135-7 (Code of Ethics).
  • Ga. Comp. R. & Regs. ch. 135-9 (Continuing Education).
  • Ga. Comp. R. & Regs. ch. 135-10 (Advertising).
  • O.C.G.A. § 19-7-5 (mandated reporting of suspected child abuse).
  • O.C.G.A. § 30-5-1 et seq. (Disabled Adults and Elder Persons Protection Act).
  • O.C.G.A. § 24-5-501 (privileged communications).
Federal
  • 45 C.F.R. pts. 160 and 164 (HIPAA Privacy, Security, and Breach Notification Rules).
  • U.S. Department of Health and Human Services, Office for Civil Rights. Telehealth and HIPAA. hhs.gov
  • Fla. Stat. § 456.47 (out-of-state telehealth provider registration).
Compact & professional standards
  • Counseling Compact Commission. Privilege to practice and current operational state roster. counselingcompact.gov
  • Georgia Secretary of State, Professional Licensing Boards Division. Counseling Compact. sos.ga.gov
  • American Counseling Association. (n.d.). Ethical & professional standards. counseling.org
  • American Counseling Association. (2014). 2014 ACA code of ethics (see Section H, Distance Counseling, Technology, and Social Media). Revision pending adoption, autumn 2026.
  • American Psychological Association. (2017). Ethical principles of psychologists and code of conduct (2002, amended effective June 1, 2010, and January 1, 2017).
  • American Psychological Association. (2024). APA guidelines for the practice of telepsychology.
  • National Board for Certified Counselors. (2023). NBCC code of ethics (Standards 91–108, telemental health; 109–114, social media and technology).
  • National Center for Missing & Exploited Children. CyberTipline. missingkids.org
  • National Center for Missing & Exploited Children. Take It Down. takeitdown.ncmec.org
  • National Center for Missing & Exploited Children. Sextortion. ncmec.org
Verify before you rely. The Compact roster changes month to month and board rules are amended. Check the current text of 135-11-.01 and the live Compact state list before applying anything on this page to a specific client.
Questions about this module

Questions about this module: contact the Internship Coordinator, Beth Wodzenski, MA CMHC, NCC, APC, at B@orchardhumanservices.org. Questions about applying it to a specific client belong in supervision. Return to the Internship Supervision Index.

Orchard Human Services, Inc. · Uplifting Lives by Counseling, Educating & Caring
This page is preparation and reference. It is not the six-hour training and it is not legal advice.
Content last reviewed September 2026.

Comments are closed.