Policy: Provider Personal Email/Phone Use

SUD Specialty Group – CA, Mental Health Specialty Group, P.A., Mental Health Specialty Group NJ, PC, and Mental Health Specialty Group KS, P.A. (collectively, “Group”) contracts with Path, CCM, Inc. d/b/a Rula (“Rula”) for management and administrative support services. Each entity within the Group and Rula may be referenced herein as a company and, collectively, as the Companies. This policy applies to all of the Companies. 

Policy Statement

Mental health providers and clinical staff are strictly prohibited from using personal cell phones, personal email accounts, or any other personal communication platforms for Rula patient-related communications. All patient communications must be conducted through Rula’s provider portal (EHR). Communications between providers about a patient’s care must be conducted via HIPAA compliant email or secured phone line. 

Applicability:

This policy applies to all therapy providers contracted with the Group. This policy does not currently apply to contracted psychiatric providers. 

Definitions

• EHR: Rula’s provider portal which serves as the Electronic Health Record  

• Personal devices: cell phone, landline phone, clinic phone outside of Rula, email address

Policy

A. Scope 

1. This policy applies to all forms of communication involving clients, including but not limited to:

   A. Appointment scheduling or changes

   B.Clinical updates or treatment-related information

   C.General inquiries or administrative matters

B. Rationale

1. Use of personal devices and email accounts poses significant risks to client confidentiality, professional boundaries, and data security. This policy is in place to:

   A. Uphold ethical standards of care

   B. Comply with HIPAA and relevant data protection laws

   C. Ensure proper documentation of all client interactions as a part of the medical record

C. Enforcement

1. Violation of this policy may result in disciplinary action, up to and including the following:

   A. Pausing new referrals 

   B. Investigation by Rula Quality Team

   C. Termination of contractual agreement

D. Exceptions

1. In rare or unavoidable circumstances where a provider must use a personal device to communicate with a patient (e.g., emergency situations or technical issues preventing access to the protected EHR), the provider is required to document the communication in the client’s chart as soon as possible. This documentation must include:

   A. A summary of the interaction, including the date, time, and content of the communication.

   B. The reason why the communication occurred outside of the protected electronic health record (EHR) system.

2. Failure to appropriately document such exceptions may be considered a violation of this policy.

Attachments: None.

Updated October 06, 2025 18:42