Originally adopted in March 2005
Updated October 2015
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. The Board recognizes that this is an evolving practice issue, and its policy may be updated from time to time. However, there are some issues and policies that the Board believes are important to share, even as this area evolves. The Board believes that psychologists should recognize that as he or she loses the kind of direct contact with a patient/client that occurs in an in-person, face-to-face office, the psychologist incrementally loses much of the richness of interaction which, as any psychologist knows, comes with traditional face-to-face contact. 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. A psychologist should also recognize that without such in-person, face-to-face interaction, patients/clients may misinterpret or feel injured by a psychologist’s statements, tone of voice, or other perceived empathic failures, and the psychologist may fail to observe the signs of this in a timely way. This may lead to the patient filing a complaint, prematurely terminating the therapy, or both.
In addition, 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 or are insufficient, identifying appropriately trained professionals 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’s current position is that the practice of psychology occurs where the patient/client who is receiving the services is physically located at the time of service. In order for a psychologist to provide psychological services to a patient in Massachusetts, that individual must be licensed by the Massachusetts Board of Registration of Psychologists or be exempt under the provisions of M.G.L. c. 112 §.123. If the patient/client is in Massachusetts at the time of service, and files a complaint against the treating psychologist, that complaint will be heard in Massachusetts.
A Massachusetts psychologist who renders psychological services electronically to a client who is not in Massachusetts is advised to contact the psychology licensing board in the state in which the patient is at time of service, to determine whether or not such practice is permitted in that jurisdiction.
Licensees are advised to review the following:
- M.G.L. ch. 112, s. 118-129b
- 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).
- APA/ASPPB/APAIT Joint Task Force Telepsychology Guidelines