March 2006

In response to inquiries from licensees and other interested parties, the Board would like to share its current thinking with regard to provision of services via electronic means. We have not come to any conclusions about the appropriateness of providing psychological services electronically because this is an emerging area of practice on which APA is presently working. However, there are some issues we think are important to consider. We believe that any psychologist should recognize that as he or she moves away from direct contact with clientele, the psychologist incrementally loses much of the richness of interaction which, as any psychologist knows, comes with traditional face-to-face contact in an individual session with a client. For this reason, a psychologist should seriously consider conducting the initial evaluation of a client in-person before beginning electronic provision of services, and holding sessions in-person periodically thereafter.

Delivery of clinical services by technology-assisted media such as telephone, use of video, and the internet obligate the psychologist to carefully consider and address a myriad of issues in the areas of structuring the relationship, informed consent, confidentiality, determining the basis for professional judgments, boundaries of competence, computer security, avoiding harm, dealing with fees and financial arrangements, and advertising. Specific challenges include, but are not limited to, verifying the identity of the client, determining if a client is a minor, explaining to clients the procedure for contacting the psychologist when he or she is off-line, discussing the possibility of technology failure and alternative modes of communication if that failure occurs, exploring how to cope with potential misunderstandings when visual cues do not exist, identifying an appropriately trained professional who can provide local assistance (including crisis intervention) if needed, informing internet clients of encryption methods used to help ensure the security of communications, informing clients of the potential hazards of unsecured communication on the internet, telling internet clients whether session data are being preserved (and if so, in what manner and for how long), and determining and communicating procedures regarding the release of client information received through the internet with other electronic sources.

The Board considers that the practice of psychology occurs both where the psychologist who is providing therapeutic services is located and where the individual (patient/client) who is receiving the service is located. In order for an individual to provide psychological services in Massachusetts, that individual must be licensed by the Board of Registration of Psychologists or be exempt under the provisions of M.G.L. ch. 112 s.123. If a Massachusetts licensee renders psychological services electronically to an out-of-state client, it is recommended that the licensee contact the psychology licensing board in the state in which the patient/client resides to determine whether or not such practice is permitted in that jurisdiction. Licensees are advised to review M.G.L. ch. 112, s. 118-129b, and the APA Ethical Principles of Psychologists and Code of Conduct (Standards 3.10(a), 4.02(c), 5.01(a), and 5.04 specifically address electronic transmissions).