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| Fullname | CommentType | GroupName | SectionName | Comment | Submitted | |
|---|---|---|---|---|---|---|
| Brad Levitt | bwlone@yahoo.com | Personal Comments | 7. Clinical Best Practices | This might not be the right place for this comment, but I always thought it made sense to have a tiered system of therapy services. In office sessions pay the full rate, and teletherapy half or some portion. | 2024-03-24 | |
| Mark D Worthen PsyD | mark@drworthen.net | Personal Comments | General Comments | First, comment box that does not allow for any formatting, e.g., bold, italicized, or underlined text, limits our ability to express ourselves clearly. If you allowed us to upload a Word doc or PDF this limitation would not be a problem, but we cannot upload files. I will use symbols as a stand-in for formatting. *italics* **bold** == Subheading == At present, the proposed guidelines suffer from anemic prose, mainly due to excessive verbiage and ambiguity. I recommend hiring a professional copy editor to work with a small group of dedicated psychologists to improve the manuscript's grammar, syntax, and clarity of expression. Consider what the *APA Manual of Style* (American Psychological Association, 2020, p. 111) has to say: "The main objective of scholarly writing is clear communication, which can be achieved by presenting ideas in an orderly and concise manner. Establishing a tone that conveys the essential points of your work in an interesting way will engage readers and communicate your ideas effectively. Precise, clear word choice and sentence structure also contribute to the creation of a substantive, impactful work." The current manuscript neither satisfies those expectations, nor the detailed advice in chapters 4 and 6 of the *Publication Manual* (chapter 5 is of course also important, but I did not see biased language when I scanned the manuscript). Here are some *examples* of how one might improve the writing. I start with the current text, identified by page and line numbers, followed by a brief description of the *problems* with that text, and concluding with a suggested copy edit. == Example #1 (Introduction, p. 2, lines 24–30) == **Current**: These guidelines are designed to educate and guide psychologists in the area of psychological service provision commonly known as telepsychology. Briefly, telepsychology refers to the delivery of psychological services utilizing telecommunication technologies. A more comprehensive explanation may be found below in the Definitions and Terminology section of these guidelines. The central role of telepsychology in the provision of psychological services and the continuous development of new technologies in the practice of psychology support the need for the development and maintenance of guidelines for practice in this area. *Problems*: (1) verbosity; (2) defining one's terms is important, but this can be accomplished more efficiently with a short footnote for the benefit of readers interested in such specificity. **Copy Edit**: These guidelines will help psychologists deliver efficacious telepsychological services in an ethical, secure manner. Rapid technological developments and burgeoning telehealth research warrant an update to the 2013 Guidelines. == Example #2: (Introduction, p. 2, 38–43): == **Current**: Telepsychology presents unique opportunities to psychologists. Telepsychology allows for the digital translation of traditional in-person psychological services either as an independent method, or as a supplement to in-person meetings. The integration of technology into practice allows for expansion of the array of both general and specialty services available to patents, bolstering of professional training opportunities in psychology, support of psychological research, and advocacy opportunities for the field of psychology. *Problems*: Emphasizes advantages to psychologists as opposed to benefits for patients and communities. (There are also too many prepositional phrases, resulting in prolixity and imprecision.) **Copy Edit**: Telepsychology expands the range of services accessible to patients who might not otherwise access them due to transportation barriers, anxiety, or a shortage of culturally competent, skilled clinicians qualified to meet their specific needs. ? Please note that those are simply two examples. I do not mean to imply that the remainder of the manuscript is well-written. == Conclusion == If we improve the prose, we will help more psychologists provide competent, ethical, and effective telepsychological services, which will in turn benefit more patients, organizations, and communities. == Reference == American Psychological Association (2020). *Publication manual of the American Psychological Association* (7th ed.). P.S. I am willing to volunteer copy editing time, *if* the the Working Group to Revise the Guidelines for the Practice of Telepsychology (TP PPG), Board of Professional Affairs (BPA), and Committee on Professional Practice and Standards (COPPS) engages the services of a professional copy editor and otherwise evinces a commitment to improving the manuscript until it achieves the high standards of scholarship described in the APA Publication Manual (7th ed.). | 2024-03-24 | |
| Dariush Fathi PsyD | dfathi@gmail.com | Personal Comments | General Comments | It's way too long. Would be better if more concise. | 2024-03-25 | |
| Dr. Norman R. Klein | nrkphd@aol.com | Personal Comments | General Comments | This is an essential update. Telehealth is here to stay and likely will only grow. It is vital that the APA differentiate what we do as clinicians from the larger body of biological medicine. We are shepherds in human enterprise—we are not dermatologists. Moreover, it is important to identify the potential diminution of value of tele-psychology vs, in office contact. Much of value may be lost in a two-way direction, and this must be acknowledged in any signed informed consent. Almost needless to say and emphasize: no one can guarantee protection or security from the added risk to confidentiality posed by all electronic communication. NO ONE! | 2024-03-25 | |
| Leslie Berkelhammer Greenberg | DrGreenberg@RichmondNeuropsychology.com | Personal Comments | General Comments | Important to have full coverage for telehealth option. | 2024-03-26 | |
| Andrea Davis, Ph.D. | director@greenhousethearpycenter.com | Group Comments | DIR/Floortime Coalition of California | General Comments | Telepsychology has provided the greatest increase in access to care for patients from all communities. Intensive treatment modalities in particular benefit from patient access via telepsychology since scheduling and transportation barriers are removed. Adaptive Behavior Treatment for autistic patients is one such intensive service benefitting in particular from telepsychology, as it is offered in an intensive format over a number of years. Telepsychology often affords greater involvement of the caregiver in the Adaptive Behavior Treatment or greater support and involvement of both parents, despite competing scheduling demands. Greater parent involvement has been documented to yield consistently more robust outcomes in adaptive behavior treatment models. Flexible delivery models of in-person or digital means often allows communities formerly excluded from intensive treatments to be now included. Public policies and funding policies should underscore the importance of flexible treatment delivery models including telepsychology. | 2024-03-28 |
| Dr. Andik Matulessy | andikmatulessy@yahoo.com | Personal Comments | 1. Competence of the Psychologist | In non-pandemic conditions, is telepsychotherapy still needed? If it is still needed, it is necessary to make changes to the psychology professional education curriculum to increase psychologists' competence related to psychological assessment and intervention. | 2024-04-02 | |
| Agustin Hayes | agustin.hayes@open-mind-therapy.com | Personal Comments | 6. Interjurisdictional Practice | It's ridiculous that American psychologists are not allowed to work with people that are not physically located in their state of registry. I think this is a great disservice to both practicioners and clients as American practicioners are missing out from a wealth of possibilities by working with people who are abroad and people who are in other parts of the world don't get to work with the extremely capable and good therapists available in the United States. It's because of this that I have done my studies and professional registration in the Netherlands and I hope to some day be able to register in the United States and live there while working with the population I'm so passionate about. | 2024-04-02 | |
| Theodore Fred Witzig Jr | twitzig@accounseling. | Personal Comments | 6. Interjurisdictional Practice | Context: I now participate in PSYPACT and am also individually licensed in 4 states. 60% of my clinical work is done through telehealth. It is essential that these guidelines help to free psychologists to provide care for clients inter-jurisdictionally. The guidelines are written from the perspective of needing to make sure that every "i" is dotted and every "t" crossed in inter-jurisdictional care. However, the level of rigidity of ensuring every mandate is followed to the letter of the law often comes at the expense of client care. Yes, we must provide competent care. Absolutely! But when the "gymnastics" we have to do to work with clients due to the rigidity of licensure law and the inability to appropriately flex. In the age of telehealth, the concept that if a client or the therapist goes on vacation to another state and that can automatically make their therapeutic relationships unethical or illegal if they have a session is actually not serving clients well. We need to seek to find ways to make this work in the age of Amazon, Apple, Google, and AI. Thank you. | 2024-04-02 | |
| Martha Jackson Oppeneer, D.Min., LMFT | mjo.cpa@att.net | Personal Comments | 11. Emerging Technologies | I have been working virtually for 4 years. At first, this option seemed like the most ethical way to keep myself and my clients safe. I regarded it as temporary. As time went on, I remained virtual, and plan on working in this capacity until I retire. In part, I do have clients who are extremely vulnerable and who would not feel safe in a clinical setting, surrounded by people who may or may not be infected with any number of illnesses. But the most compelling factor has been discovering that there is a sizable group of people who prefer virtual TX. For some, they can take a break during their workday and log on. For couples, they can put their kids to bed and log on from home without needing to find a babysitter. I also have a number of clients who have moved out of the area and who would otherwise have had to terminate TX with me and start all over again with someone else. Those of us who are virtual are also available to clients in under-served areas of the state. I am hoping that our various professional organization will do all in their power to ensure that virtual TX remains available and covered by insurance. | 2024-04-02 | |
| Dr Madhumita G | an09osh@gmail.com | Personal Comments | 1. Competence of the Psychologist | Psychologist needs to be universally recognised & permitted to practice with other Medical Practitioners with equal opportunity & benefits. | 2024-04-02 | |
| Kalsoom Yasin | kalsoomyasin4@gmail.com | Personal Comments | 1. Competence of the Psychologist | no comments | 2024-04-03 | |
| DAGMAWI SHENKUTE | dagmawiget@gmail.com | Personal Comments | 5. Documentation | Really I would like to appreciate everything what I had taken the documents that sent to me so far meaning I am in the learning process. However, still I can't find out (unable to watch) those previous webinars that you invited me and then you had sent to me through my email. Hopefully, I will find out for the upcoming events. Thank you so much. | 2024-04-03 | |
| Katherine Duggan | katherineduggan@gmail.com | Personal Comments | Introduction | I worry the distinction between guidelines and standards (p. 4, line 71) will be lost on politicians or lawmakers who might update telehealth laws. Is there a way to limit this risk, besides the description in the current document? For example, can there be a clear/distinct table with the *standards* which lawmakers or insurers should use? I worry lawmakers and others will use this document as a policy shortcut. | 2024-04-03 | |
| Katherine Duggan | katherineduggan@gmail.com | Personal Comments | 7. Clinical Best Practices | This is an interesting and important section. It's also tricky to balance professional goals with the realities of how health care is provided and adjudicated in this country. I agree that psychologists should consider the availability of comparable in person services (p. 30, line 613), and document why telepsychology services are equivalent or preferable. I worry, however, that published research may document that telepsychology is not equivalent, either now or in the future - and that this could be used by insurance companies to deny patients the ability to seek telepsychology and have services reimbursable by insurance. For example, perhaps telepsychology CBT will be inferior to in-person CBT, even if it's better than no care. Might insurance companies use that as an opportunity to deny patients to access in-person CBT? | 2024-04-03 | |
| Katherine Duggan | katherineduggan@gmail.com | Personal Comments | 7. Clinical Best Practices | On p. 30, line 619, the document encourages psychologists to conduct an initial assessment regarding the appropriateness of telepsychology *before* providing services. I worry this can be read as an initial, in-person assessment being required before the provision of any telepsychology services. This could lead to clients in rural areas, or clients without many providers available, being unable to receive services. Could this be rephrased to suggest the initial assessment should include consideration of whether telepsychology is appropriate, regardless of where the initial assessment takes place (e.g., in-person or via telehealth)? | 2024-04-03 | |
| Ali Tavakoli Banizi | psycho.ir747@gmail.com | Personal Comments | General Comments | The trainings are appropriate and practical, and the psychologist just needs to adapt some of them to the culture of Them environment | 2024-04-04 | |
| Haim Weinberg | haimw@group-psychotherapy.com | Personal Comments | 7. Clinical Best Practices | The guidelines are quite satisfying and encompass most of the topics that should be addressed relating to TelePsychology. What is missing is naming the specific obstacles in online therapy, especially the disembodied environment (the lack of body-to-body communication). See a detailed description in my publication below (you might want to add some of them to your references): Weinberg, H., Rolnick A., & Leighton, A. (eds.) (2023). Advances in Online Therapy: Emergence of a new Paradigm. New York: Routledge. Weinberg, H. (2021). Obstacles, Challenges and Benefits of Online Group Psychotherapy. American Journal of Psychotherapy. Weinberg, H. (2020) Online group psychotherapy: Challenges and possibilities during COVID-19 — A practice review. Group Dynamics: Theory, Research, and Practice, 24(3), 201–211. | 2024-04-06 | |
| Katherine M. Slama, Ph.D. | kslama222@gmail.com | Personal Comments | 1. Competence of the Psychologist | Behavioral health professionals offering telehealth services to rural people need to show competencies in rural culture/behavioral health. | 2024-04-07 | |
| Yomna Hassaballa | yhassaballa2013@gmail.com | Personal Comments | General Comments | Telepsychology has indeed revolutionized the therapeutic landscape, providing therapists and clients with unprecedented flexibility in balancing their career and personal lives. Moreover, its reach extends beyond urban centers, empowering individuals in rural areas to access crucial mental health support and connect with their communities more effectively. | 2024-04-08 | |
| Marsha V Hammond PhD | chomskysright@gmail.com | Personal Comments | 6. Interjurisdictional Practice | The NC Psychology Licensing Board issued guidelines on the practice of telemedicine November,2023. See: http://www.ncpsychologyboard.org/data/documents/NCPSY-BulletinBoard-Fall2023.pdf In Feb 2023–8 months prior to that release—-an ethics charge was filed on me regarding the lack of telemedicine information in my Informed Consent. My attny asked:”were you aware of the APA guidelines for the use of telemedicine”; I stated I was. This is the basis of the NC Psychology Licensing Board ethics charge on me. I bought forward the point that APA is a professional society, not a regulating body, Would APA PLEASE make clear if it intends for it to be a regulating body or does APA clearly stand as a professional organization. I had believed it was NOT a regulatory body but the NC Psychology Licensing Board is treating the matter as if APA is a regulatory agency. My attny maintains that there is “overlap.” I maintain that the board is the regulatory agency & APA is not. Please clarify this matter & plz advise the NC Psychology Board of your stance. I will be querying ASPPB about the same matter. Thank you for utilizing my comment. Is there a way for me to know how this will be utilized or not? Thank you. Marsha V Hammond PhD NC Lic Psych 2748 | 2024-04-12 | |
| Marsha v Hammond phd | chomskysright@gmail.com | Personal Comments | 2. Informed Consent | The NC Psychology Licensing Board issued guidelines on the practice of telemedicine November,2023. See: http://www.ncpsychologyboard.org/data/documents/NCPSY-BulletinBoard-Fall2023.pdf In Feb 2023–8 months prior to that release—-an ethics charge was filed on me regarding the lack of telemedicine information in my Informed Consent. My attny asked:”were you aware of the APA guidelines for the use of telemedicine”; I stated I was. This is the basis of the NC Psychology Licensing Board ethics charge on me. I bought forward the point that APA is a professional society, not a regulating body, Would APA PLEASE make clear if it intends for it to be a regulating body or does APA clearly stand as a professional organization. I had believed it was NOT a regulatory body but the NC Psychology Licensing Board is treating the matter as if APA is a regulatory agency. My attny maintains that there is “overlap.” I maintain that the board is the regulatory agency & APA is not. Please clarify this matter & plz advise the NC Psychology Board of your stance. I will be querying ASPPB about the same matter. Thank you for utilizing my comment. Is there a way for me to know how this will be utilized or not? Thank you. Marsha V Hammond PhD NC Lic Psych 2748 | 2024-04-12 | |
| Lloyd Kenneth Chew, Jr., Psy.D., HSPP | lkenneth.chew@indstate.edu | Personal Comments | 11. Emerging Technologies | Under the section of emerging technology, it is highly important to at the very least address or mention the expanding use of AI and chatbots. Given the fact that these are not human interactions, are we as an organization going to allow this to be defined as mental healthcare and a billable service? | 2024-04-19 | |
| Gillian Karp | drgilliankarp@icloud.com | Personal Comments | 6. Interjurisdictional Practice | My comment concerns requirements relevant to the interjurisdictional licensing compact, or PSYPACT as it is currently configured. As a psychologist licensed in Maryland, having obtained a PhD from New York University in Community Psychology, and spent several years of training and supervised practical experience respecializing in Clinical Psychology, I do not meet requirements that would allow me to join PSYPACT. Upon completion of several years of training and supervised experience (externship and internship) equivalent to completing a PsyD, I received a certificate and not another graduate degree from my university (Fielding Graduate University). My strong belief is that APA should revisit the requirement that bars those who have obtained this type of certificate under similar circumstances from qualifying for PSYPACT. | 2024-04-19 | |
| Julie Radico | juliera@pcom.edu | Personal Comments | 7. Clinical Best Practices | i really appreciate the work that went into this guidelines and their revision. It would be helpful to have specific examples of language for how one would "articulate and document why telepsychology services are equivalent or preferable" (Line 614-616). Is this a specific request to state that the patient preferred and consented to a virtual visit and to list the reasons why? Would this specific documentation be needed in the intake documentation or each and every note? If so, could there be standard language provided by APA? What if the reason is simply that virtual visits are what the psychologist offers and the client is amenable and seems appropriate for such a format? | 2024-04-19 | |
| Purna Chandra Datta | drpcdatta@gmail.com | Personal Comments | 2. Informed Consent | Informed Consent needs to be thoroughly understood, signed and followed in details by all parties. A model Informed Consent has been provided by the TRUST Liability Insurance Co. | 2024-04-21 | |
| Gregory Milbourne | greg@drmilbourne.com | Personal Comments | General Comments | As an independent practicing entirely virtually it is of vital importance to codify and support psychologists working effectively and ethically via telehealth. | 2024-04-21 | |
| Rachel Goldenhar | rachelgoldenhar@hotmail.com | Personal Comments | General Comments | I work with high functioning adults and would like to have the ability to see clients when they are temporarily traveling to another state. This would help with continuity of care and treatment planning. I also would like to see more states allow some flexibility around psychologists seeing existing clients who move to another state and would like to continue treatment with their therapist who resides in CA. | 2024-04-22 | |
| Rachel Eby | rachel.eby.phd@gmail.com | Personal Comments | General Comments | lines: 45: I would add with work or life schedule. Many people I see are able to see me for psychotherapy at an odd hour due to me being physically located in a different time zone. It these people had to be seen in person, they wouldn’t be able to meet from 6-7 AM before their children wake up, or at 4:00AM before they have to start getting ready for work. 203: typo (extra semicolon): including the following considerations: ; greater emphasis on psychologists’ need for continuing” 334: missing word: “access protocols,” 345: typo: “observing f boundaries” | 2024-04-23 | |
| Erin Watson | Erin.Watson@va.gov | Personal Comments | 6. Interjurisdictional Practice | To Whom it May Concern: As a VA Psychologist the last ten years, I wanted to comment on my experience related to practicing across state or international borders. The APA guidelines imply the VA has guidelines on this. I have personally done a lot of work in seeking out guidelines for this very issue, and both national VA and my local VA have failed to provide guidelines beyond "the VA approves it." Psychologists are being asked to see patients outside the state for which they hold a license - without having any information as to the other states ethical or legal policies. The VA does not give us information on this nor do they provide time to learn about another states policies. I fear this is gravely irresponsible and will only fall onto the licensed provider should a mandated reporting issue arise. I personally attended a presentation on this given by a psychologist who practices across state lines and they started the presentation by saying, "Just because the VA tells us we can do this, doesn't mean we should." They proceeded to share the many issues that could arise should we practice across state lines without state board approval. They provided several examples of providers being sued for doing so and running into issues with their state board not supporting this, despite the VA telling them to do so. I would encourage great caution in this area and ask APA to reconsider. | 2024-04-24 | |
| Jessica Jackson | jessicajackson1332@gmail.com | Group Comments | APA Mental Health Technology Advisory Committee | General Comments | April 24, 2024 The Working Group to Revise the Guidelines for the Practice of Telepsychology (TP PPG) Board of Professional Affairs (BPA) Committee on Professional Practice and Standards (COPPS) Re: Guidelines for the Professional Practice of Telepsychology (APA, 2013) Dear Working Group & Consulting Committees: The American Psychological Association (APA)/Mental Health Technology Advisory Committee (MHTAC) appreciates the opportunity to comment on American Psychological Association’s Guidelines for the Practice of Telepsychology revisions. MHTAC is a 14-member committee made up of psychologists and other appropriate stakeholders, with diverse perspectives and areas of expertise in the use of technology to provide services, optimize practice, promote psychology, examine the use of future technology, and engage in regulatory/reimbursement advocacy. We assist APA’s Office of Health Care Innovation (OHCI) staff in developing strategies to advance ongoing initiatives including telehealth, interoperability and health information exchanges, digital interventions, and additional priorities APA should consider based on its strategic plan. This letter includes MHTAC recommendations and comments regarding the Proposed Guidelines for Telepsychology. The following sentence on pg .6 is unclear. It seems to imply that a comprehensive review is customary when developing clinical practice guidelines, but that the literature review used to support these particular practice guidelines is not comprehensive. “The literature review, however, is not intended to be exhaustive or to serve as the comprehensive and systematic review that is customary when developing professional clinical practice guidelines for psychologists.” Under the definition of telepsychology on pg. 6, it states that services are provided by a psychologist. Are trainees or people supervised by psychologists also considered “psychologists” for the purpose of these guidelines? Is virtual reality and AI considered part of the definition of “telecommunication technologies” that can be delivered by psychologists? I assume they are based on the broad definition used, but it might be appropriate to name these technologies specifically for clarity. Especially with AI tools, the human “delivery” element can be less obvious. Guideline 1: Didactic and experiential learning is emphasized. Should these competencies begin during graduate-level training as well as post-graduate? “Lifelong learning” and completion of “specialized training programs” is noted, but I think a specific point about integrating competency development into generalist training programs would be relevant and important as well. I doubt there is a clinical or counseling psychology program today where students aren’t doing at least some telepractice. Guideline 2: Written informed consent is less essential (though informed consent is nonetheless recommended to some degree) in court-ordered psychological services. In many of these cases, there is no therapeutic or confidential relationship between psychologists and the person they are interacting with (e.g., an examinee). I believe this guideline (and perhaps others) should include language that better recognizes all possible contexts beyond the typical psychologist-patient relationship. I understand the Forensic Psychology Specialty Guidelines are also under revision, but I’m not sure the extent to which they will include telepsychology. Division 41 issued a statement with recommendations related to telepsychology in psycho-legal settings (cited on pg. 36 of this document in relation to testing) in which informed consent is discussed, but these are not authoritative guidelines in the APA sense. Under Guideline 2, it may also be relevant to specifically discourage psychologists from using technological jargon in informed consent as part of “using language easily understandable by patients.” Guideline 3: Although this is broadly covered by the language in this guideline, I wonder if specific language should be included around the use of AI tools to help with tasks like notetaking, report-writing, etc. That psychologists must take care to ensure identifiable data are not uploaded or stored on internet-based software programs unless these tools are appropriately secure (e.g., HIPAA-compliant). Anecdotally, people I’ve trained, talked to, etc. seem especially concerned with these types of tools. Guideline 7: Considering citing the following on pg. 29, which meta-analyzed both intervention outcomes and assessment reliability: Batastini, A. B., Paprzycki, P., Jones, A. C. T., & MacLean, N. (2021). Are videoconferenced mental and behavioral health services just as good as in-person? A Meta-analysis of a fast-growing practice. Clinical Psychology Review, 83. https://doi.org/10.1016/j.cpr.2020.101944 The paragraph on pg. 32 regarding a consistent and secure therapeutic framework may be unrealistic for some settings like jails, prisons, or other closed institutions. While I agree we should always strive for the ideal conditions, some psychologists may have to settle for “good enough” in weighing whether to see a client or not. I mention this because people working in these settings may read this paragraph and think that telepsychology can only be used when there is no or only very minimal risk to privacy, reliability of services, etc. I would argue that increased acceptability of less-than-ideal circumstances is often better than depriving people of services altogether, especially for populations (like those incarcerated) who are already grossly underserved. Therefore, I would suggest softening the language or at least acknowledging psychologists may need to weight the benefits of delivering services vs. not when the environment is less-than-ideal. Further, in inpatient and carceral settings, open dialogue also needs to occur with staff or administrators who are responsible for setting up and managing the virtual environment. Guideline 8: It seems important to emphasize that the on-site proctor should have adequate training in test administration if this is part of their role. Guideline 10: It may be relevant to briefly mention efforts to ensure trainee wellness; for example, there’s some research on the impacts of “Zoom fatigue” which could be compounded with other more typical forms of fatigue in clinical work like compassion fatigue or general demands of graduate training. In other words, there are some unique effects of providing virtual services that supervisors may need to monitor and be aware of with their trainees. As a general comment, the guidelines are centered around the provider-patient relationship, as well as the provision of more stereotypical therapeutic services. Although there are several places within the guidelines that reference the complex nature of telepsychology and the need to tailor one’s considerations and approaches to the population or setting, the heavy emphasis on the provider-patient dynamic neglects other ways in which psychologists provide clinical-related services; for example, in some forensic/legal settings where the court is the client, in consultation where an organization or other professional may be the client, or in supervision of trainees. I understand the guidelines are predominately intended for more traditional provider-patient interactions, but there are so many other ways telepsychology applies to the practice of psychology that it seems these other dynamics/circumstances should be more clearly recognized and considered in the language. Or, there should be a more explicit disclaimer at the outset noting that these guidelines may be less applicable to other forms of practice beyond services provided directly by providers to patients. The guidelines frequently reference “diverse populations” or considerations of diversity. It may be relevant to include a definition of “diverse” or “diversity” for the purpose of these guidelines. I believe this would be consistent with APA’s intention of being more direct and specific when talking about diversity and EDI. Thank you for your careful consideration of the MHTAC’s comments on the Proposed Guidelines for the Practice of Telepsychology. Please do not hesitate to contact the MHTAC with questions about our recommendations and comments. We appreciate the continued opportunity to offer recommendations to improve the practice of psychology. Sincerely, Jessica Jackson, Ph.D. Chair, APA/Mental Health Technology Advisory Committee (On Behalf of the American Psychological Association Mental Health Technology Advisory Committee | 2024-04-24 |
| Tamara Shulman | tamara@tamarashulman.com | Personal Comments | 7. Clinical Best Practices | My personal experience with both new and ongoing patients has been consistent with the research showing that Teletherapy is an effective way to provide both CBT and Psychodynamic psychotherapy by well trained, experienced, Post Doctorate Psychologists. Patients have requested teletherapy for convenience and flexibility, accessibility, and effectiveness of virtual psychotherapy. The consistent relationship with a licensed psychologist is essential to providing a quality of psychotherapy that only a well trained and experienced therapist can provide. | 2024-04-26 | |
| Kerry Cannity | kcannity@touro.edu | Personal Comments | General Comments | I appreciate this updated guidance, and in my brief reading, it provides a helpful if vague framework for how psychologists should go about use of telepsychology in modern practice. | 2024-05-03 | |
| Kerry Cannity | kcannity@touro.edu | Personal Comments | 6. Interjurisdictional Practice | My major concern about this document is that the guidance provided is relatively vague and more aspirational than specific when it comes to practice across jurisdictional lines. This was opened up during COVID, but now that these jurisdictional lines will likely be contracting to some degree, I think APA needs to be clear about the ethical obligations of therapists in counseling patients in other locations. This also weaves in with the idea that psychology should work to be a more nationwide body because these lines will continue to become more arbitrary as time and technology goes on. I appreciate that these interjurisdictional issues are not going to be solved with this document, but more specifics and even more of a forward looking vision in this area would be helpful. | 2024-05-03 | |
| Patricia Whitt | lakeviewpsycholo@bellsouth.net | Personal Comments | 2. Informed Consent | I appreciate the distinction of the guidelines being aspirational, however agree with those who express concern about their application by non-psychologists in legal or regulatory settings to cast aspersions on otherwise solid clinical practice. I also have questions about the interpretation of the informed consent guidelines; the benefits and limitations of telepsychology are somewhat situation-specific (e.g., for some individuals there is a significant improvement in ability to access specialized care, and/or care that is accessible despite geographic, work, childcare, or time issues; it would not appear the research is to the point we can be prescriptive in determining blanket "limitations" to telepsychology services). When clinicians do an initial assessment, whether in person or by telepsychology (herein defined as synchronous video conference), a wide range of factors can lead the clinician to determine that the modality being sought is not a "best fit" for the potential client, including because of level of care concerns. As for the suggestion by one commenter that telepsychological services be reimbursed as though they are inevitably inferior, neither research nor professional experience supports that argument; the pandemic forced us to discover that, for example, sensitively and carefully delivered trauma therapy can occur by videoconference, in some cases for individuals who would not have been able to access it in person at all. My hope is that the guidelines will support continued research and ethical practice, and make clear that the standards for in person and telepsychological care are similar: that we bring the best of our attention, training, and expertise to every clinical hour. When I consider the few stories I have heard from clients about experiences with some of the nationally marketed services, the differentiating factor is the clinician's expectation that there will be no diminution of quality because of modality. | 2024-05-04 | |
| Jennifer Franklin | drfranklin@donthateyourguts.com | Personal Comments | 7. Clinical Best Practices | There is no mention of the importance of having the proper camera set-up as a telepsychology provider. Depending on where the camera is located, providers can appear to offer eye-contact, mimicking in-person face-to-face interactions. Otherwise, eye-contact becomes impossible, affecting the relational dynamics between provider and patient, ultimately affecting the quality of the connection and working alliance. This is an important aspect of telepsychology treatment that should be addressed explicitly as a guideline for best practice. | 2024-05-08 | |
| Stewart E Cooper, PhD | stewart.cooper@valpo.edu | Group Comments | CAGAP | General Comments | CAGAP commends the Working Group to Revise the Guidelines for the Practice of Telepsychology (TP PPG) for its diligence in addressing the significant changes in technology and increased focus on DEI that have emerged since the first Guideline for the Practice of Telepsychology was approved in 2013. Our suggested additions are due to the absence of attention to general applied psychology which extends far beyond direct health care practice and encompasses a wide range of fields and applications. In specific, there are two areas of the revised Guidelines where this absence is most evident. The first is the section entitled "Psychological services / psychological practices" (see lines 138 - 141). The second is the section entitled "Special practices" (see lines 750 - 759). It may be helpful for your consideration to have some examples of applied psychology apart from direct health care focus and practice. Educational Psychology: Educational psychologists study how people learn and develop in educational settings. They work with educators to develop teaching strategies, curriculum, and programs that enhance learning outcomes for students. Organizational Psychology: Also known as industrial-organizational psychology, this field focuses on understanding human behavior in the workplace. Organizational psychologists may help businesses improve employee satisfaction, productivity, and organizational effectiveness through strategies such as leadership development, team building, and performance evaluation. Forensic Psychology: Forensic psychologists apply psychological principles and methods to legal issues and the criminal justice system. They may work with law enforcement agencies, courts, and correctional facilities to assess criminal behavior, provide expert testimony, and develop rehabilitation programs for offenders. Sports Psychology: Sports psychologists work with athletes and coaches to improve performance, enhance motivation, and manage the psychological aspects of sports participation. They may address issues such as goal setting, stress management, and confidence building to help athletes reach their full potential. Environmental Psychology: Environmental psychologists study the relationship between people and their physical surroundings. They may investigate how factors such as architecture, urban design, and natural environments impact human behavior, well-being, and sustainability. Consumer Psychology: Consumer psychologists examine the psychological factors that influence consumer behavior and decision-making. They may conduct research on topics such as advertising effectiveness, brand perception, and consumer preferences to help businesses develop marketing strategies and products that appeal to their target audience. Military Psychology: Military psychologists provide mental health services to military personnel and their families, addressing issues such as post-traumatic stress disorder (PTSD), depression, and anxiety. They may also contribute to military training programs, leadership development, and resilience-building initiatives. Human Factors Psychology: Human factors psychologists study how people interact with technology, products, and systems to optimize usability, safety, and performance. They may design interfaces, equipment, and work environments to minimize human error and improve user experience. CAGAP appreciates the efforts of the TP PPG in developing a document useful to all psychologists who engage in telepractice to assist their individual, team, and organizational clients. | 2024-05-08 |
| Rachel Bailey | rbailey@uow.edu.au | Group Comments | Project Air Strategy for Personality Disorders | General Comments | The APA Proposed Revision of Guidelines for the Practice of Telepsychology is a welcome document in light of the rapidly changing nature of psychological practice following expansion of telehealth modalities. The Guidelines are clear whilst intentionally general to allow for clinician judgement and broader application. The Guidelines do comment on particular aspects of psychological practice (e.g., testing and assessment; supervision and training). However, the guidelines appear to neglect the opportunity to reinforce the requirement for psychologists to provide person-centred care that is responsive to the needs to the individual. This includes particular population needs that are complex, interpersonally sensitive, and require additional consideration – such as when engaging clients with personality disorder via telehealth. There has been a growing body of empirical literature evaluating the use of telehealth for people with personality disorders and clinical recommendations. The comments below seek to address this omission. Dr Rachel Bailey, Clinical Psychologist and Senior Research Fellow, Project Air Strategy for Personality Disorders Nacquel Knowles, Research Assistant, Project Air Strategy for Personality Disorders Senior Professor Brin Grenyer, Clinical Psychologist and Director, Project Air Strategy for Personality Disorders | 2024-05-14 |
| Rachel Bailey | rbailey@uow.edu.au | Group Comments | Project Air Strategy for Personality Disorders | 1. Competence of the Psychologist | Suggested change on line 279 from “(d) adaptations for special populations (e.g., older adults, children, individuals with disabilities).” To “(d) adaptations for special populations (e.g., older adults, children, individuals with disabilities, individuals with particular psychiatric conditions that require thoughtful telehealth consideration).” As an example, recent research has suggested that telehealth can be acceptable and effective for people with personality disorders, however there may be specific adaptions for this population group to enhance rapport and safety (e.g., Bailey, Knowles & Grenyer, 2023; Reis, Matthews & Grenyer, 2020). Bailey, R. C., Knowles, N. G., & Grenyer, B. F. S. (2023). Efficacy and recommendations for the delivery of telehealth psychotherapy for people with personality disorder. Australasian Psychiatry, 0 (0), 1-10, DOI: 10.1177/10398562231222768 Reis, S., Matthews, E. L., Grenyer, B. F. S. (2020). Characteristics of effective online interventions: implications for adolescents with personality disorder during a global pandemic. Research in Psychotherapy: Psychopathology, Process and Outcome, 23(3), 256-278. doi: 10.4081/ripppo.2020.488 | 2024-05-14 |
| Rachel Bailey | rbailey@uow.edu.au | Group Comments | Project Air Strategy for Personality Disorders | 7. Clinical Best Practices | Line 603: Suggestion to include reference “(Bailey, Knowles & Grenyer, 2023; Reis, Matthews & Grenyer, 2020)”. Line 626: Suggestion to include sentence “The assessment or initial orientation may also need to consider particular population group needs and adaptations (e.g., Bailey, Knowles & Grenyer, 2023).” Line 667: Suggestion to include sentence “The virtual therapeutic frame may also need careful consideration of a variety of diversity issues, including adaptations required for particular population groups (e.g., Bailey, Knowles & Grenyer, 2023).” Bailey, R. C., Knowles, N. G., & Grenyer, B. F. S. (2023). Efficacy and recommendations for the delivery of telehealth psychotherapy for people with personality disorder. Australasian Psychiatry, 0 (0), 1-10, DOI: 10.1177/10398562231222768 Reis, S., Matthews, E. L., Grenyer, B. F. S. (2020). Characteristics of effective online interventions: implications for adolescents with personality disorder during a global pandemic. Research in Psychotherapy: Psychopathology, Process and Outcome, 23(3), 256-278. doi: 10.4081/ripppo.2020.488 | 2024-05-14 |
| Michael Craytor | craytorlpc@gmail.com | Personal Comments | 10. Supervision/Training | The section on telesupervision appears well written and should support appropriate development of telesupervision practices. Did the authors of this section come across any research on the safety of telesupervision compared to in-person, any differences in outcomes? The State of Alaska Board of Psychologists has been holding on out permitting telesupervision to meet requirements for internships and pos-doctural placements, citing a desire to wait for more evidence and guidance that indicates telesupervision does not pose a risk to the general public. A reference in this section of the guideline speaking to the safety and similarity of outcomes to in-person supervision may help state Boards make informed decisions about what mix of remote and in-person supervision is appropriate for their state. | 2024-05-15 | |
| CPTA - Marianne Ernesto | mernesto@apa.org | Group Comments | CPTA | General Comments | General Comment: There is no mention of interpretation and translation as tools that can be utilized in telepsychological therapy and assessment. With the increase of AI and other technology, it is technically possible to provide AI translation and interpretation during an online session, including close captions for clients who need them. This is an important topic that requires some type of guidance. Definitions and Terminology: p. 6: Telepsychology is defined for the purpose of these guidelines as the integration of telecommunication on technologies with psychological practices. It refers to the provision of telehealth services by a psychologist. --Should also refer to services provided under the supervision of a psychologist (e.g., including test administration by psychometricians). | 2024-05-17 |
| CPTA - Marianne Ernesto | mernesto@apa.org | Group Comments | CPTA | 3. Data Security, Management, and Transmission | p. 19: Psychologists who provide telepsychology services seek to ensure reasonable steps for security measures are in place to protect patient data from unintended access, disclosure, loss, or corruption. --Should also address test security and need to maintain test integrity, including but not limited to patient responses to individual test items and actual test materials/procedures. | 2024-05-17 |
| CPTA - Marianne Ernesto | mernesto@apa.org | Group Comments | CPTA | 8. Testing and Assessment | Rationale p. 33: While some psychological tests and assessment instruments are administered remotely and/or digitally, many such tools were originally designed and developed for in-person administration. --Should more clearly note that many instruments, including many that can reasonably be administered remotely and/or digitally, do not currently have norms specific for these kinds of administrations and that the validity and utility of available norms (i.e., those based on in person test administration) may not generalize to scores derived through remote and/or digital test administration. The availability of appropriate test norms should be considered during test selection. Application p. 34: Psychologists are uniquely trained to administer psychological testing and aspire to adapt established assessment tools appropriately to telepsychology. --This can be misleading as currently written. Many psychologists are not (adequately) trained to appropriately “adapt established assessment tools appropriately to telepsychology” even in an aspirational sense. Psychologists should first strive to use tests that have already been appropriately adapted for use via telepsychology, and for which there is evidence supporting their psychometric properties. Should a psychologist need to remotely/digitally administer a test for which no reasonable alternative suited and validated for telepsychology exists, their decision whether or not to administer a test without established validity and reliability in the context of telepsychology should align with APA Ethical Codes (e.g., 9.02), published guidelines, and contemporary research and best practices. p. 35: Psychologists may elect to mitigate some of the abovementioned challenges through the use of an on-site testing proctor, when available. The proctor may assist in test or subtest administration, maintaining the environment, confirming patient identity and other on-site needs. --To the extent possible and feasible, the on-site testing proctor should be trained in best practices of test administration, in the administration of the test(s) on which they will be assisting, and in necessary guidelines/ethics (e.g., confidentiality, test security, test integrity). Guideline 8: Testing and Assessment: --There is a problematic lack (or limited amount) of guidance on key topics. These include (1) the importance/need for specific (re)training in the remote/digital administration of tests (e.g., having been trained in the in person administration of the WAIS does not equate to being adequately trained to administer the WAIS remotely/digitally) and (2) detailed guidelines on how “to maintain the integrity and security of test materials and other assessment techniques” (APA Ethics Code 9.11) in the context of teleassessment. | 2024-05-17 |
| Sylvie Fortin | s_fortin_cpsych@yahoo.com | Personal Comments | 6. Interjurisdictional Practice | Please note that I have been a Registered Member of the College of Psychologists of Ontario (CPO) since 1997. I am a Member of the Canadian Psychological Association (CPA). My first language is French, and I provide psychological services in French and English. The only Reference related to Canada that I located in the APA information linked to this update was the CPA (2006) Ethical guidelines for psychologists providing services via electronic media. This Reference was updated in 2020 with Interim Guidelines, and the current Reference is CPA (June 2023) CPA Guidelines on Telepsychology. Please note that the Association of Canadian Psychological Regulatory Organizations (ACPRO) published a Memorandum of Understanding effective April 1, 2024 Regarding Interjurisdictional Telepsychology - the ACPRO MOU contains no References. The College of Psychologists of Ontario (CPO) has indicated that effective July 1, 2024 a new Standards of Professional Conduct will come into force. Although I had provided feedback on the DRAFT encouraging CPO to make Reference to CPA / APA the only change was to add a Practical Application note indicating CPA / APA. | 2024-05-19 | |
| Dr. Sylvie Fortin | s_fortin_cpsych@yahoo.com | Personal Comments | 2. Informed Consent | I would like to add to the comments made by Patricia Whitt with respect to Telepsychology not being viewed as inferior to in-person. Specifically, I have provided direct clinical care in a range of settings during my Ph.D. internships, under supervision, and then since 1997 as a Registered Clinical Psychologist. From March 2020 until July 2022 I provided 99% of my clinical care by means of Telepsychology - Canadian Health Services forced the shift to Telepsychology. On a few urgent cases I went to the Hospital to provide clinical support to a patient dealing with end-of-life issues for their partner / or equivalent crisis situations, and only two (2) of the many patients on my case load have indicated that in-person is essential. With the exception of these two (2) patients all of my patients have indicated that Telepsychology provides additional benefits. Specifically, 90% of my patients are retired Canadian Veterans who have combat trauma and associated psychological issues, and they have all indicated that Telepsychology allows them to relax before and after a session as they do not have to travel (which frequently involves triggering events). | 2024-05-19 | |
| Dr. Sylvie Fortin | s_fortin_cpsych@yahoo.com | Personal Comments | 2. Informed Consent | This comment is intended to add to the comment by Patricia Whitt | 2024-05-19 |