Clients experiencing severe mental health symptoms may request documentation to support leave of absence requests related to:
Family and Medical Leave Act (FMLA)
Short-Term Disability (STD)
Long-Term Disability (LTD)
If a client is considering a leave of absence related to their mental health, it is likely an extremely challenging time in their life. They are now faced with the daunting prospect of filing for disability, which will require both advocating for themselves and your support.
Because laws and licensing rules vary by state and license type, it’s important to understand your scope of practice before completing any leave-related paperwork. This is especially important for compliance and quality considerations, ensuring you meet your clients' needs within your scope.
This guide explains:
How to determine whether you can complete leave paperwork
The difference between intermittent and block leave
Kaiser Permanente-specific guidance
Alternatives if you cannot complete the paperwork
Additional ways to support clients
Step 1: Check the Client’s Insurance
First, determine whether the client has Kaiser Permanente (KP) regional market insurance.
If yes → Go to the Kaiser Permanente Regional Markets section below.
If no → Continue to the Scope of Practice section.
Step 2: Confirm Your Scope of Practice
Before agreeing to complete FMLA or disability paperwork:
Review your state licensing laws
Contact your licensing board
Confirm your eligibility to complete this paperwork with your malpractice insurance carrier. You should also review the risks and benefits (for both you and your client) with them.
Discuss your client's needs with them and be clear about how you can best assist them through your scope of practice.
Important note:
In many states (including but not limited to California, Texas, Florida, and New York):
Therapist mental health documentation is NOT sufficient for STD/LTD approval.
FMLA eligibility varies by state and employer requirements.
Because of this, you should always verify current rules with your state licensing board.
If Your License Type Is NOT Allowed to Complete FMLA or Disability Forms
Refer the client to a provider whose license permits completion of disability paperwork, such as MD/DO or Nurse Practitioner (NP).
If Your License Type IS Allowed to Complete FMLA or Disability Forms
Rula providers should complete paperwork using clinical judgment on a case-by-case basis. This help center article covers best practices for most states when completing FMLA/disability paperwork. However, we recommend consulting the state licensure board for the most up-to-date information.
Understanding Leave Types
When supporting an FMLA request, determine which leave type best aligns with the client’s clinical needs. Choosing the correct type ensures that the client receives the right level of support while maintaining compliance with Rula partner requirements.
1. Intermittent Leave
Definition:
Time off taken in separate blocks (not continuous). This is typically used when the client can generally work but needs periodic time off for treatment.
Common Clinical Uses: Weekly therapy sessions, twice-weekly therapy, Intensive Outpatient Program (IOP)
2. Block (Continuous) Leave
Definition:
An uninterrupted leave period. Typically defined by partners as more than two weeks.
Common Clinical Uses:
Stabilization time during a severe mental health crisis
Major depressive episode with significant impairment
Transition from inpatient or residential treatment
Kaiser Permanente (KP) Regional Markets
What Rula Providers CAN Do
Rula providers may complete Intermittent Leave paperwork for KP members if:
The request aligns with clinical need
Time off is for mental health treatment
Documentation supports the need for intermittent leave
What Rula Providers CANNOT Typically Do
Rula providers generally may not complete Block/Continuous Leave requests, especially if the leave exceeds 2 weeks.
These cases must be evaluated at:
The client’s local Kaiser Permanente mental health clinic, where a KP physician must determine clinical justification for processing disability paperwork.
Non-Kaiser California Pathways
If you do not complete FMLA or disability paperwork due to license restrictions, scope concerns, or clinical judgment, refer the client to:
Their psychiatrist (if established)
Their primary care provider (PCP)
A Rula medication management provider for a mental health evaluation using this form.
Important note about option 3:
Please note that a relationship with Rula’s medication management provider is required before any determination of disability can be made. It often takes multiple visits before enough information is gathered to make an appropriate determination regarding disability status, and form completion is not guaranteed.
If You Are Eligible to Complete FMLA Paperwork
Rula providers should:
Use clinical judgment and guidelines from their licensing board.
Ensure clinical documentation supports the need for FMLA, such as documenting increased symptoms and impairment.
Before completing paperwork, obtain written authorization from the client to release information.
Additional Ways to Support Clients
While providers may be ineligible to or may choose not to complete disability paperwork or FMLA certification, providers of any license type can contribute to the leave of absence process by providing a Treatment Summary to the client.
Important to consider:
A treatment summary alone is usually not sufficient for disability approval, but it can help your clients advocate for their leave of absence request.
Before drafting a treatment summary, it's crucial to understand your role in the process:
Before completing a treatment summary, obtain written authorization from the client to release information.
Share only the minimum necessary information in order to protect your client's privacy
Use your discretion to keep documentation accurate, concise, and legally compliant.
Remember, the Clinical Quality Team at Rula is here to support you if you have any questions or concerns!
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