Telehealth Compliance Checklist for Clinicians

Compliance AreaKey RequirementsLicensure & JurisdictionEnsure you're licensed in the state where the client is located during each session. Some states allow temporary reciprocity; others do not.Informed Consent for Telehealth

Provide a specific telehealth consent form outlining risks, benefits, limitations, and technology use. Document signed consent in your records.HIPAA-Compliant TechnologyUse secure platforms (Zoom for Healthcare, SimplePractice, etc.) that offer Business Associate Agreements (BAAs). Avoid standard Zoom, FaceTime, or Skype.Confidentiality in Virtual Settings

Confirm both you and the client are in private, interruption-free environments. Encourage headphones and closed doors.Documentation StandardsChart telehealth services the same as in-person care. Note the location of the client, platform used, and any technical issues.Crisis ProtocolsObtain the client’s physical location at the start of each session. Have local emergency contacts and a crisis plan documented.Billing & Reimbursement Rules

Know which CPT codes, modifiers (e.g., GT, 95), and payer rules apply. These vary across insurers and states.ADA AccessibilityEnsure your platform and materials are accessible to clients with disabilities (e.g., screen readers, captions, interpreter access).Record RetentionFollow state and federal guidelines for how long telehealth records and session recordings (if applicable) must be stored.

Relevant Stats

  • 35% of telehealth providers in 2022 reported unintentional HIPAA violations due to platform or consent confusion (SimplePractice, 2022).

  • Only 52% of providers had documented crisis response plans for virtual clients (APA Telepsychology Guidelines Survey, 2021).

  • Practices with documented telehealth policies were 40% less likely to report client confusion or conflict about virtual boundaries or safety expectations (NASW, 2020).

Special Considerations & Common Mistakes

  • Cross-State Sessions: Even during emergencies (e.g., wildfires, pandemics), providing therapy to clients outside your licensed state may require temporary permission.

  • Recording Sessions: NEVER record without explicit, documented consent. Some platforms auto-record, which must be disabled or disclosed.

  • Client Verification: If working with new clients virtually, verify their identity with full name, DOB, and address at the start of care.