Telehealth and School Closure FAQ for School Psychologists

Many school psychologists are asking questions about telehealth on online forums as a result of school closures. In response, Schoolpsych.com has created the following document, which consists of answers based on reputable sources to the most frequently asked questions.

CLICK HERE for a free Microsoft Word template of an informed consent document for teletherapy services. It provides the risks, benefits, and confidentiality standards of teletherapy. The template was originally written for practitioners in Nevada using Doxy.me as a platform, so you will need to change the template to fit your individual circumstances. A special thanks to Savannah Armijo, Ed.S., for sharing this template with NASP and Schoolpsych.com
On 3/16/2020, the U.S. Department of Education, Office of Civil Rights has addressed this with the following statement. “If an evaluation of a student with a disability requires a face-to-face assessment or observation, the evaluation would need to be delayed until school reopens. Evaluations and re-evaluations that do not require face-to-face assessments or observations may take place while schools are closed, so long as a student’s parent or legal guardian consents.” Click Here for Full Statement From OCR On 3/21/2020, the U.S. Department of Education, Office of Civil Rights has followed up with further clarification. “As a general principle, during this unprecedented national emergency, public agencies are encouraged to work with parents to reach mutually agreeable extensions of time, as appropriate.” Click Here for Full Statement From OCR On 3/22/2020, NASP provided an FAQ of the USDOE’s guidance for IDEA service delivery and stated the following information. “Despite the guidance from the USDOE, specific decisions may vary by state, district, and individual IEP teams. It is important that we collectively work to protect the rights of students with disabilities and ensure they are accessing FAPE while also balancing the health and safety of school staff and students. For technical assistance regarding IDEA, including best practices and alternate models for providing special education and related services, including through distance instruction, the USDOE encourages you to reach out to one of two centers. For questions pertaining to Part C of IDEA, states should contact the Early Childhood Technical Assistance Center at ectacenter.org. For Part B of IDEA, states should contact the National Center for Systemic Improvement at ncsi.wested.org. We encourage you to work with your state associations, in partnership with your state departments of education, and with other allied stakeholders to share your concerns and solutions for effectively meeting the needs of students while also adhering to public health guidance.” Click Here for Full Statement From NASP
On 3/16/2020, the U.S. Department of Education, Office of Civil Rights has addressed this with the following statement. "If a school district closes its schools and does not provide any educational services to the general student population, then a school would not be required to provide services to students with disabilities during that same period of time. Once school resumes, the school must return to providing special education and related services to students with disabilities in accordance with the student’s IEP." Click Here for Full Statement From OCR On 3/22/2020, NASP provided an FAQ of the USDOE’s guidance for IDEA service delivery and stated the following information. “If an LEA closes due to COVID-19, and educational services are not being provided to the general student population, then the LEA is not required to provide special education services during that same period of time. The IEP or 504 team would make an individualized determination about providing compensatory services based on applicable standards and requirements. If an LEA continues to provide educational opportunities to the general student population during a school closure, students with disabilities must have access to the same opportunities. To the greatest extent possible, each student with a disability should be provided the special education services in their IEP or 504.” Click Here for Full Statement From NASP
Savannah Armijo is a school psychologist who provided remote services for four years and describes her experience in the following statement. “The platform that was used was secure and I was trained by my employer on how to use it. Additionally, when completing psychological testing-we used IQ, Achievement, and Social/emotional measures that were web/tech based and were made to be delivered using technology. It's important to keep in mind that even though the services were given through the web, there was always a human element involved. For instance, there was someone in person to help the student log in and/or to give the tasks requiring writing.” She makes the following conclusion regarding school psychologists who do not have the necessary training, technology platform, and assistance of aides. “It would be a difficult task to train, develop procedures, and require services like this to be delivered in a short period of time.” Savannah was part of the team who developed the following NASP resource: Virtual Service Delivery in Response to COVID-19 Disruptions NASP states that school psychologists who conduct direct assessments virtually are often working for third-party providers. “Third party providers, such as Presence Learning, have been given the exclusive rights to develop online administration of the Woodcock-Johnson IV assessments, for which online assessment is the primary focus. Due to the shortage of school psychologists and struggles to meet the demands for services in hard to fill areas (e.g., rural, urban), third party companies are responding to the demand to deliver school psychology telehealth services.” Link to Full Statement From NASP
On 3/20/2020, NASP addressed this in the following statement. “Consider that even assessment measures that are designed to be delivered using technology most often also involve human support for the student’s use of technology. Practitioners must consider their own training needs and the need to develop clear procedures for service delivery in this manner. Training will also be needed for the adult who is assisting the student at home. It is unlikely that appropriate supports can be developed quickly.” NASP also advises practitioners to question the validity of results when testing students during a crisis. “Potential validity issues must be addressed when assessments are taking place in a time of anxiety for youth, their families and caregivers, and school personnel.” Click Here for Full Statement From NASP In a different document created in September of 2017, NASP advises practitioners to consider the potential validity concerns of virtually administered assessment results when using aides. “Using telehealth services with children raises the issue of needing aides in the room with them in order to assist in administration or to address any behavioral issues. The background of the aides is incredibly varied. This can lead to interruption or undermining of the services through various actions taken on the part of the aides, such as giving feedback to a parent based on observation of a testing session or providing guidance to complete a task, which can confound results.” Click Here for Full Statement by NASP
NASP has addressed this in the following statement. “Practitioners of telehealth must be certified or licensed in both their state of residence and the state in which their client resides. In addition, practitioners who provide telehealth through a third-party contractor are potentially providing services outside the auspices of a school or district, which may not be permissible for specialist-level or doctoral-level school psychologists in many states, without a private practice license. Currently, it is not clear if state department of education certification/licensing regulations specifically address telehealth services in their scope of practice for school psychologists. Private practice licensure also varies per state, so individual practitioners are responsible for ensuring their license(s) cover telehealth/teletherapy.” Click Here for Full Statement by NASP
The US Department of Health and Human Services provides recommendations for various HIPAA-compliant video communication products. “The list below includes some vendors that represent that they provide HIPAA-compliant video communication products and that they will enter into a HIPAA BAA.” • Skype for Business / Microsoft Teams • Updox • VSee • Zoom for Healthcare • Doxy.me • Google G Suite Hangouts Meet” Click Here for Full Statement from USHHS Doxy.me is a free, HIPAA-Compliant telehealth platform, and based on statements from online forums, it has been recommended by multiple school psychologists who have experience using it. Click here for Doxy.me’s website You can learn more information about HIPAA-Compliant video communications at 1:08:12 of this free three-hour webinar titled, Three-Hour Seminar: A Practical Guide to Providing Telepsychology with Minimal Risk. Click Here to View This Webinar NASP advises practitioners to follow HIPAA and FERPA regulations when providing telehealth services. “Practitioners are cautioned to follow all HIPAA regulations, rather than just FERPA regulations. Ensuring secure technology is paramount, as is ensuring that appropriate informed consent is explained and obtained. Districts and third-party providers may not provide liability protections to practitioners, and it is unclear how school psychologists who engage in telehealth practices would fare in a due process or legal proceeding.” Click Here for Full Statement from NASP Also note the following statement from the US Department of Health and Human Services.  “OCR will exercise its enforcement discretion and will not impose penalties for noncompliance with the regulatory requirements under the HIPAA Rules against covered health care providers in connection with the good faith provision of telehealth during the COVID-19 nationwide public health emergency.  This notification is effective immediately.” Click Here for Full Statement From USHHS
Based on comments from online school psychology forums, it has been observed that Zoom is the most popular teleconferencing platform for holding IEP meetings. Zoom can be used on your computer or phone, and it has many features to help facilitate meetings virtually. Zoom usually has a 40-minute time limit on meetings for those with free accounts; however, as a result of schools being affected by the coronavirus, Zoom has removed the 40-minute time limit for school staff. Thus, if you sign in with your school district's email account, you can use Zoom freely and without restrictions. Click Here for Zoom's Website Another popular platform is Doxy.me, which is HIPAA-compliant and allows participants in the meeting to access a link from a computer, tablet, or phone without needing to download the platform. Click Here for Doxy’s Website Savannah Armijo is a school psychologist who provided remote services for four years and describes her experience conducting IEP meetings virtually in the following statement. “A link for an eligibility or IEP meeting could be sent to each member of the team (including parents) and the document on the screen is shared with participants. Conference calls were connected into the online meeting if someone could not use the online platform.” Savannah was part of the team who developed the following NASP resource: Virtual Service Delivery in Response to COVID-19 Disruptions The Department of Education has confirmed that it is permissible for IEP meetings to not be held in person. “Teams are not required to meet in person while schools are closed.” (Click Here for Full Statement by DOE) The US Department of Health and Human Services provides recommendations for various HIPAA-compliant video communication products. “The list below includes some vendors that represent that they provide HIPAA-compliant video communication products and that they will enter into a HIPAA BAA.” • Skype for Business / Microsoft Teams • Updox • VSee • Zoom for Healthcare • Doxy.me • Google G Suite Hangouts Meet” Click Here for Full Statement from USHHS Although Zoom for Healthcare is HIPAA-compliant, Zoom’s basic plan is not. When choosing whether to use the free option for Zoom during this time of crisis, please consider information from the following three paragraphs. On its website, Zoom provides more information regarding the security of its platform and the protection of meetings, data, and privacy. “Communications are established using 256-bit TLS encryption and all shared content is encrypted using AES-256 encryption. Chat can be encrypted for HIPAA-compliant settings.” Click Here for Zoom’s Website NASP recommends following HIPAA and FERPA regulations when providing telehealth services. “Practitioners are cautioned to follow all HIPAA regulations, rather than just FERPA regulations. Ensuring secure technology is paramount, as is ensuring that appropriate informed consent is explained and obtained. Districts and third-party providers may not provide liability protections to practitioners, and it is unclear how school psychologists who engage in telehealth practices would fare in a due process or legal proceeding.” Click Here for Full Statement From NASP Please also keep in mind the following statement from HHS. “OCR will exercise its enforcement discretion and will not impose penalties for noncompliance with the regulatory requirements under the HIPAA Rules against covered health care providers in connection with the good faith provision of telehealth during the COVID-19 nationwide public health emergency. This notification is effective immediately.” (Click Here for Link to Full Statement From HHS)
You do not. As long as you sign up using your school district’s email, it will be waived. Zoom has removed the 40-minute time limit for all school staff during the COVID-19 outbreak. Click Here for Zoom's Website
NASP has addressed this in the following statement. “Many school district forms have not been constructed to accommodate the use of telehealth. This is particularly concerning for informed consent, as the parent must be informed of the service delivery method being utilized and issues involving various risks, benefits, and, in addition, the students’ rights must be addressed. This includes the right of parents to refuse telehealth services.” Click Here for Full Statement From NASP Furthermore, NASP states the following. “Practitioners may need to renegotiate confidentiality agreements to manage the limited privacy students may have at home.” Click Here for Full Statement From NASP The American School Counselors Association states the following. “Recognize and mitigate the limitation of school counselor confidentiality in a virtual setting, which may include unintended viewers or recipients. Emphasize these limits in communications with students and families and when establishing boundaries of virtual counseling.” Click Here for Full Statement by ASCA You can learn more information about informed consent in telehealth at 1:01:25 and 1:35:28 of this free three-hour webinar titled, Three-Hour Seminar: A Practical Guide to Providing Telepsychology with Minimal Risk. Click Here to View This Webinar CLICK HERE for a free Microsoft Word template of an informed consent document for teletherapy services. It provides the risks, benefits, and confidentiality standards of teletherapy. The template was originally written for practitioners in Nevada using Doxy.me as a platform, so you will need to change the template to fit your individual circumstances. A special thanks to Savannah Armijo, Ed.S., for sharing this template with NASP and Schoolpsych.com
The American School Counselors Association has addressed this with the following statement. “Have you worked with administrators to develop a plan for how students and families can reach the school counselor through phone, email or online platforms? Do not use your personal phones or email accounts. If a communications method or online platform is not readily available, work with your school and district administration to find a solution. (…) Be accessible to students through email, phone or online platforms for advising following the communication plan developed with school/district administration.” Click Here for Full Statement From ASCA NASP has provided the following statement. “Practitioners need to set clear limits on when they are and are not available for consultation or counseling. Arrangements must be made for back-up communication when individual providers are unavailable. Emergency response plans need to be in place if students threaten harm to self or others.” Click Here for Full Statement From NASP A practical tip for helping set boundaries is to use Google Voice. Google Voice provides you with a new phone number of your choice in order to not provide families with your actual cell phone number. You can call and receive calls from that new phone number for free within the United States. It can be set up on your computer or phone. To further set boundaries, Google Voice gives you the option to switch into 'Do Not Disturb' mode. This allows you to disable all the phone calls that are connected to Google Voice. Click Here for Link to Voice.Google.com
If working remotely, school psychologists may want to support teachers above and beyond email communication. If you would like for teachers to be able to call you with questions, we would recommend using Calendly. Calendly is a website where you can schedule time slots for people to meet with you based on your availability preferences. Once created, you share the link with the teachers via email, and the teachers pick a time slot to meet with you. Alternatively, you can use Google Calendar to schedule meetings and show your availability.
The CDC has addressed this with the following statement. “Check with your school on plans to continue meal services during the school dismissal. Many schools are keeping school facilities open to allow families to pick up meals or are providing grab-and-go meals at a central location.” Click Here for Full Statement From CDC
The Department of Health and Human Services (HHS) has addressed this with the following statement. “OCR will exercise its enforcement discretion and will not impose penalties for noncompliance with the regulatory requirements under the HIPAA Rules against covered health care providers in connection with the good faith provision of telehealth during the COVID-19 nationwide public health emergency. This notification is effective immediately. A covered health care provider that wants to use audio or video communication technology to provide telehealth to patients during the COVID-19 nationwide public health emergency can use any non-public facing remote communication product that is available to communicate with patients. OCR is exercising its enforcement discretion to not impose penalties for noncompliance with the HIPAA Rules in connection with the good faith provision of telehealth using such non-public facing audio or video communication products during the COVID-19 nationwide public health emergency. This exercise of discretion applies to telehealth provided for any reason, regardless of whether the telehealth service is related to the diagnosis and treatment of health conditions related to COVID-19. For example, a covered health care provider in the exercise of their professional judgement may request to examine a patient exhibiting COVID- 19 symptoms, using a video chat application connecting the provider’s or patient’s phone or desktop computer in order to assess a greater number of patients while limiting the risk of infection of other persons who would be exposed from an in-person consultation. Likewise, a covered health care provider may provide similar telehealth services in the exercise of their professional judgment to assess or treat any other medical condition, even if not related to COVID-19, such as a sprained ankle, dental consultation or psychological evaluation, or other conditions.” Click Here for Full Statement by HHS
School districts in various states are re-opening as virtual schools by providing distance learning and are requiring school psychologists to comply with evaluation timeline requirements. To use Texas as an example, the Texas Education Agency (TEA) released the following statement. “If the school remains open (either on a virtual basis or face-to face), the 45 school-day timeline requirements of Texas Education Code sec. 29.004 apply.” Link to Full Statement From TEA It is recommended for school psychologists to support their state association in continued advocacy for promoting best practices. The Texas Association of School Psychologists (TASP) has responded to the TEA with the following statement. “With consideration of the ethical implications and irresponsible assessment practices, the Texas Association of School Psychologists strongly recommends upholding the advice provided by the U.S. Department of Education, Office of Civil Rights as follows, ‘If an evaluation of a student with a disability requires a face-to-face assessment or observation, the evaluation would need to be delayed until school reopens. Evaluations and re-evaluations that do not require face-to-face assessments or observations may take place while schools are closed, so long as a student’s parent or legal guardian consents.’ The state of California has followed this guidance and will not be completing face to face evaluations until normal school routines have returned for all students. We ask that Texas adopt similar guidelines during this delicate and uncertain time. Our goal as school psychologists is to consider the best interests of the students and families we serve, while not abandoning their social, emotional, academic, and mental health needs. We have an ethical responsibility to maintain the highest standard for professional practices in educational and psychological assessment.” Click Here for Full Statement From TASP
NASP has addressed this with the following statement. “Interns are still expected to obtain a minimum 1200 hours during their internship experience.This is critical because many states base their credentials on completing a 1200 internship; it is risky to assume that states will waive this requirement. However, the NASP Program Accreditation Board and National School Psychology Certification Board have agreed to require a minimum of 800 hours in direct, field-based supervised experiences, with a minimum of 400 hours in a school setting. Programs may employ flexibility on the remainder of hours. Programs have discretion as to how many nonschool hours spent on such internship tasks as writing reports, making phone calls, researching and creating service delivery plans, planning inservices, etc., may be counted toward the 1,200-hour minimum. Should schools remain closed for the remainder of the year, some interns may still have opportunities to interact with pre-K–12 students and engage in school psychological services, even if in a nontraditional capacity. For those in districts without such opportunities, we encourage graduate programs to identify other ways to ensure that all students who complete the program develop the required knowledge and skills that align with program goals and objectives. These activities may include book studies, structured utilization of various NASP resources (e.g., Communiqué, Online Learning Center sessions, NASP podcasts), case study reviews, independent study of particular areas of competency, school-wide prevention planning, district-wide data analysis and program evaluation, and so on. Programs will determine which activities are most appropriate for their students. Again, interns should still accrue 1200 hours - recognizing that a minimum of 800 hours must be field-based, supervised contact hours (with 400 hours minimum in a school setting). Programs may consider similar activities to support completion of practica, which also remains entirely up to each individual program.” Click Here for Full Statement From NASP
The APA has addressed this by providing a full checklist of considerations to be made when providing teletherapy. CLICK HERE to access the full checklist. Below are the technological considerations that should be made prior to providing teletherapy. -Does the patient have technology resources for a videoconference – e.g. webcam or smartphone? -Consider patient’s comfort in using technology – can they log in and effectively use the technology? -Is your technology platform consistent with HIPAA-compliant practices? -Do you have a Business Associate Agreement (BAA) for that technology vendor? -Do you and the patient have adequate internet connectivity for videoconferencing? -Did you discuss with the patient how to log in and use the technology? -Are you using a password-protected, secure internet connection, not public or unsecured WiFi? What about your patient? (If not, it increases the risk of being hacked.) -Did you check that your antivirus/antimalware protection is up-to-date to prevent being hacked? What about your patient? -To improve eye contact, position your camera so that it’s easy to look at the camera and the patient on screen. -Check the picture and audio quality. Can you see and hear each other? Make sure nobody is muted. -Do you have a back-up plan in case of technical difficulties? In case of a crisis situation? What contact information do you have? Do you know the local resources (e.g. emergency room) where the patient is? -Confirm that nobody will record the session without permission. -Turn off all apps and notifications on your computer or smartphone. Ask patient to do the same.

Closing Thoughts

We will continue to update this webpage as new information comes in. Please contact Support@schoolpsych.com if you see any corrections or updates that need to be made. As a way to support school psychologists during this time, all Schoolpsych.com webinars are 40% off.

During these unprecedented times, it is critical to advocate and care for the safety and wellbeing of our students. Savannah Armijo, Ed.S., recommends the following. “There should be a resource provided to students so that they can talk to someone if their safety is at risk. It may not need to be the school psychologists, but they may want to advocate for providing an option for these students that are at home with mental health or safety concerns.”

Rebecca Branstetter Ph.D. provides words of encouragement to school psychologists at this time. "This is the time school psychologists can show our schools that we are so much more than testing machines. It's our moment to be the calm in the storm, the collaborator and advocate for our students, and innovators of virtual universal SEL and mental health supports."

40% OFF

As a way to support school psychologists during this time, all Schoolpsych.com webinars are 40% off.

40% OFF

As a way to support school psychologists during this time, all Schoolpsych.com webinars are 40% off.

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