Purpose
This policy outlines the procedure for therapists at Rula to send their own informed consent and private practice paperwork to clients using encrypted email, in compliance with HIPAA and agency standards. The goal is to ensure clarity for clients, maintain legal and ethical compliance, and safeguard client information.
Scope
This policy applies to all 1099 independent contractor therapists who wish to use their own informed consent forms and related documents in addition to Rula’s informed consent when working with clients at Rula.
Policy Guidelines
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Use of Therapist-Provided Informed Consent Forms
Therapists are permitted to send their own informed consent forms and private practice paperwork to clients in addition to Rula’s informed consent. These documents must:- Be specific to evidence-based practice modalities.
- Align with ethical and legal guidelines governing mental health services.
- Clearly differentiate themselves from Rula’s standard informed consent forms.
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Communication with Clients
When sending their documents, therapists must provide clients with a clear explanation via encrypted email that includes:- The purpose of the documents.
- A statement clarifying the difference between the therapist’s private documents and Rula’s documents, and that both are required to be signed prior to initiating services with that therapist at Rula.
- A statement indicating that all signed documents will be securely incorporated into the client’s chart at Rula, in compliance with HIPAA regulations.
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Email Encryption and Delivery
All communications involving the therapist’s documents must be sent using encrypted email to ensure the security and confidentiality of client information.- Emails should include the following:
- A brief cover note explaining the attached documents.
- Instructions for clients on how to review, sign, and return the documents securely.
- Emails should include the following:
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Submission of Signed Documents
Once the therapist receives the signed forms from the client, the therapist is responsible for:- Forwarding the signed documents to Rula Support for secure upload into the client’s chart.
- Verifying that the signed versions of both the Rula informed consent and their informed consents are present in the chart prior to starting treatment
- Ensuring submission is done promptly to maintain compliance with Rula’s record-keeping policies and procedures.
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Rula as Custodian of Records
- Rula is the official custodian of all client records. As such:
- All client-related documents, including therapist-provided consents, must be stored within Rula’s record management system.
- Therapists are not permitted to retain sole custody of any client documents outside of Rula’s system, in accordance with HIPAA regulations.
- Rula is the official custodian of all client records. As such:
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