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COVID-19 Information-APPIC FAQs

Published on Monday, March 23, 2020

FAQ #1. What is APPIC doing in response to the COVID-19 crisis? APPIC is working with the APA, CPA, ASPPB and the training communities in the Council of Chairs of Training Councils. This is a constantly changing situation and APPIC is drafting responses that training programs and trainees might find helpful. Contact APPIC Central Office if you have specific questions and need clarification. There are no specific facts or answers to questions about reduction in time/hours/clinical experience at a site.  APPIC will continue to update this information as it develops.   APPIC encourages programs to continue to meet their requirements while increasing flexibility, creativity and innovation to ensure that all trainees meet the expected competencies set by the training program.

FAQ #2. What can training programs do to ensure continuity of care for patients and clients while supporting trainee well-being? Training programs should have leave policies in place; APPIC is encouraging programs to be flexible as the crisis evolves. This is a unique and evolving situation. Programs are strongly encouraged to continue trainees on staff and continue their stipend even if they are not on site.  Interns and postdocs need to be sure to connect with their Training Director and for interns, their home doctoral program DCT to discuss their options.

FAQ #3. How do programs provide continuity of care? Telehealth is up and running at many sites. This is a good way for trainees to continue obtaining their clinical experience at practicum, internship and postdoc settings. Telehealth is being added to the AAPI and for practicum students.  Those hours can now be added under intervention hours.   HIPAA regulations are being modified and relaxed regulations by CMS and are allowing personal devices to be used but check with your insititution/training program to ensure you are following their guidlines and regulations.

FAQ #4. What if a training program has no telehealth capabilities and interns are classified as essential employees to provide care to clients and patients? APPIC strongly encourages programs to begin and expedite telehealth capabilities. HIPAA compliance is being reviewed and CMS has already released relaxed standards for HIPAA compliance including the use of personal cell, smartphones, tablets or even land line phones to allow patient contact.  Check with your local training director on what initiatives are being put in place what accommodations are available and remember these are likely to continue to change. 

FAQ #5. What training activities can continue even if trainees are not onsite? Trainees can continue participating in learning activities even though they are not on site. They can meet together by Skype, Zoom or their phone to discuss readings, participate in didactics, telesupervision for patient care, and managing professional issues such as self-care and self-awareness during this crisis.

FAQ #6. As a trainee, I have been "ordered" to not participate in face to face activities with patients by my graduate school, even to the point of being "released"  by the doctoral program from the site. What do I do? Practicum students are under the direction of the graduate school and would be best to coordinate any reduction in patient care or  release with the graduate program. Continuity of care for clients and patients would likely include some effort on the part of the trainee, typically through their onsite clinical supervisor. Interns should discuss their options with their Training Director and/or HR prior to leaving the site or at least by phone or email. Communication needs to occur between the DCT, TD and the intern. Postdocs are not under the direction of a doctoral program and are usually employees that are subject to the policies set by the site. Consulting with the Training Director should occur before choosing to leave or not appear to a training site in a manner contrary to policy/procedures.

FAQ #7. What if I am so immobilized and in fear that I just cannot be present at my training site? There are leave policies in place for most training sites or doctoral practicum training sites. Follow those policies as much as possible. Balancing one's anxiety and responsibility as a health service provider can result in conflict. Seeking support and mentorship can be very helpful, and consultation with the Training Director about any potential options is critical.

FAQ #8.  HHS HIPAA Guidelines Latest Update 3-17-2020:  https://www.hhs.gov/hipaa/for-professionals/special-topics/emergency-preparedness/notification-enforcement-discretion-telehealth/index.html

FAQ #9.  Can APPIC tell me how best to work with trainees to balance safety concerns and managing their distress?  Some are angry that they are required to be on site when all they want to do is leave.  Is there an answer to this concern?  There is no perfect answer as trainees and sites will continue to evolve in what is required and what is supported, as well as how CDC and local governmental guidelines evolve in different jurisdictions.  Programs across the country are utilizing a range of responses to this situation, ranging from total site closure to trainees continuing to deliver care. 

FAQ #10.  If there is a disruption in my training year will my site extend the opportunity to complete the program?  This is another evolving situation and normally APPIC supports an extension for those that can not control some variables (medical illness; family leave), though programs/institutions may also have limitations with respect to what they can offer, particularly if extensions would be lengthy (e.g., paying trainees, office space if the training year overlaps, supervision resources, etc.).  Sites and trainees are encouraged to work together on mutually beneficial solutions and are welcome to consult with APPIC about specific circumstances.

FAQ #11.  I have been accepted for an internship that begins on August 1.  Will the disruption in the training year delay my start?  This is difficult to predict at this time.  APPIC recommends you reach out to your training director to express any concerns and inquire about any anticipated need to modify the training year. 

FAQ #12.  Will telehealth count for psychological interventions and assessment on the AAPI?  Yes, APPIC considers this a necessary option.  APPIC acknowledges that some sites state they are not prepared to provide videoconferencing telehealth services, but telephone contact could be used to ensure continuity of care.  Zoom has a HIPAA version; Skype for Business is HIPAA compliant.  With the relaxation in HIPAA rules, one of those should be manageable at most sites.  There are some sites, inpatient psychiatric units for instance where that might be more difficult.  There are many patients out there that have appreciated the increase in telehealth opportunities and find it extremely useful and convenient not to travel, much less expose other patients or be exposed, even when the patient is symptom free.    

FAQ #13.   I am trying to think of innovative ways besides telehealth that my interns can achieve direct contact hours. My interns participate weekly in case conferences for two hours with me. Is it possible during this time where they are not at their sites due to COVID-19 to let the case conference time count as direct service hours?

Whether and how hours “count” is defined by the entity to which they are being applied (e.g., on the AAPI, for licensure, etc.)  It is important to be aware of the various definitions and regulations concerning training experiences.  Whether or not their will be redefinitions or expanded allowances will depend on the decision of the relevant entity.  APPIC recommends directly contacting the relevant entity to ask these questions, and to review updated statements related to COVID-19 (e.g., ASPPB, APA CoA, etc.)  Telehealth services may be considered direct servce opportunities, though remember to attend to any regulations regarding the proportion of hours that must be in person.  

There are many other ways that interns are learning during this crisis. Interns can use Zoom or other videoconferencing modalities to engage in other learning activities such as case discussion or discussing articles, as well as many other activities to keep the cohort together and learning.  APPIC encourages Training Directors to be creative and to consult with colleagues about additional ideas.

FAQ #14.  What if my university president or administration sends us a memo that all students are to be removed from face to face contact and that we are to "pull" our students from the site?  Does this apply to psychology trainees at an external site?  

APPIC encourages trainees to follow the site's requirements. Please be reminded the intern has a Match agreement with the program and if they decide to follow the home universities order, then the trainee would best be advised to check with the site's HR department so they are not abandoning patients or taking a leave that has not been approved by the site.  Hopefully, most HR departments will be responsive and do what they can to make this work.  There is certainly no guarantee that this will happen at every site and of course this is rapidly changing.  Verify you are authorized not to be on site.  Remember, patients are anxious and telehealth may be what is needed for psychologists and trainees to be of assistance in this national crisis.  

FAQ #15.  My site does NOT have telehealth capabilities and has no plans to do so.  What can we do?  

APPIC encourages your site to revisit this policy.  CMS (Center for Medicare and Medicaid Services) has relaxed the rules on service delivery and will now allow telementalhealth by any cell phone, tablet, laptop or computer as well as land line phones.  

Medicare has temporarily expanded its coverage of telehealth services to respond to COVID-19.  Medicare beneficiaries can temporarily use telehealth services for common office visits, mental health counseling and preventive health screenings. This will help ensure Medicare beneficiaries are able to visit with their doctor from their home, without having to go to a doctor's office or hospital.  

FAQ #16.  What about HIPAA requirements and how patient confidentiality will need to be maintained?  

The Office for Civil Rights (OCR) at the Department of Health and Human Services has released guidance waiving penalties for potential HIPAA violations if providers making a good faith effort to provide health services use apps like Apple FaceTime, Facebook Messenger video chat, Google Hangouts video, or Skype.  Of course, efforts to maintain client/patient confidentiality continues to be a high priority.  HIPAA rules have currently been relaxed but everyone should continue making good faith efforts to maintain confidentiality. 

FAQ #17.  Will there be any consideration to waiving the direct service hour requirement for this year set by my site for successfully completing of  my training program if there is not the opportunity for interns or postdocs to remain at their current placement because of COVID-19 or the site does not have access to telehealth? I have one intern that stated she is not able to extend internship. Additionally, will there be any consideration to modifying the completion hours for internships this year if we continue to have restrictions?

APPIC wants to be clear that the training site is responsible for assessing the competency of the trainee and determining program completion requirements.  APPIC will likely not change its  stated membership requirements, which requires a membership vote. Remember that accreditation and licensure requirements are also importnt to attend to.  Licensure jurisdictions will likely make their own decision that will vary, and as some are written into law, this may be a lengthy process.  

APPIC has no "hour" requirement for trainees beyond supervision and learning activities.  APPIC requires that 25% of the trainee's activities be direct service, and telehealth would certainly help meet this requirement.  APPIC has set a 12 month, full time requirement or 24 month half-time requirement, but that has been extended in the past for some cases and reduced when special circumstances arise (Visa expiration or a short period (1-2 weeks) prior to the 12 months.  Extended or reducing the training experience should be a program decision as programs are responsible for ensuring that all trainees meet the expected competencies set by the training program usually related to the profession wide competencies.  If a program is accredited and is considering modifying it’s program completion criteira, consultation with the accrediting body is important.

FAQ #18.  What if I accepted an internship or postdoc that requires me to cross the border between the U.S. and Canada?

APPIC has been working with APA, APAGS, and CPA on improving communication and factual information about the ability of psychology trainees to cross the border.  APPIC will continue to support those that need advice about crossing the border, but until the COVID-19 situation is better resolved, crossing the boarder will likely be difficult. If an intern is unable to present to an internship site, please remember that  APPIC requires a request to be released from the match agreement.  Both Postdocs and interns should continue to stay in touch with their future placement sites, and interns should also remain in contact  with their home doctoral program if you are an intern.  

FAQ #19.  Can supervision be provided by telehealth?  

Telesupervision is often considered equivalent to face to face supervision, but some regulatory bodies may have specific limits (<50%). Regulartory boards may consider modifications or exceptions to this, but such decisions would be at their discretion.     

FAQ #20.   Most of our sites are busy developing telehealth capabilities to improve patient care while helping to ensure staff safety. One question that has come up is whether it is permittable to have an intern provide telehealth from their own home. There are obviously many things to consider (confidentiality, crisis situations, not having a supervisor in the next room, etc.). Some of our supervisors are not comfortable with this arrangement and do not want to risk their license while other are more flexible. Is this something that APPIC/APA would allow?

Flexibility and creativity are working for many sites.  Relaxation of HIPAA regulations and many states relaxing the rules for providing telehealth is occurring.  There are many considerations when delivering telehelath, including confidentiality, visibility of what is in the background, etc. Telehealth guidelines available from APA may be helpful to reference..There is great variability among sites as to how telehealth is being employed, with some doing so from home.  This is a decision for individual training programs and their host institutions to make.

FAQ #21.  If some sites within my consortium internship move toward allowing interns to work from home, but other sites cannot (for instance in-patient or primary care), how might that be handled?

The difference across settings is definitely a challenging issue.  You may wish to discuss with all sites in the consortium to articulate how they are following current CDC guidelines in their individual setting.   The program could also consider options for potential flexibility, including re-ordering rotations, on-site modifications, or the option of delaying their training and extend the internship or find an alternate telehealth opportunity for them that will keep them moving forward.

FAQ #22.  With several states putting stay-at-home orders in place, has there been any discussion of allowing telepsychology across state borders?

There has been a significant change in telehealth requirements, and changes are ongoing and frequent. Currently, it appears that these rules have been relaxed but of course this is a jurisdictional regulatory concern and it is best to check with your particular State Board of Psychology regarding current regulations and any modifications that have been made.  Most telehealth requirements for health care have been extended across state borders and not restricting those services, but again, it is best to check with the state board and if a trainee that is not licensed it would be important that your supervisor is clearly aware of the situation and agrees to continue their supervision.  There are some telehealth informed consent documents available on the APA website that may also be useful to review.
 

FAQ #23.  What do I do if as a trainee do not feel safe going to work at my training site?

APPIC encourages trainees to be sure to consult with their HR department, TD and DCT before making a final decision about what they need to do.  It is important that trainee's safety is the priority and that if a site is requiring trainees to report that CDC guidelines are followed for social distancing, PPE is available when patient contact at a site where COVID-19 is present and trainees are considered a priority to ensure their safety when those guidelines are "not" possible.  Telehealth, telesupervision and teletraining is in the works at most sites but it will take time to get these up and running.  When trainees do not feel safe, it is important that their concerns are addressed by the training site given their level of "authority" in a training site may be limited to feeling powerless to speak up.  Trainees may want to review filing a grievance, not out of punishing the site, but because their concerns are not being addressed and this mechanism may protect them from retailiation and it is highly unlikely your TD is going that way but in a crisis, rumors and misinformation are rampant.  TDs for the most part are doing their best to protect the safety of trainees even though it may not be readily apparent, it is highly likely happening as quickly as possible behind the scenes.  Communication is important and fanning the flames with rumors and innuendos, do not help.  Please be kind to each other.  

FAQ #24.  I am curious if, given the unprecedented situation, we could shift our hour requirement to meet the licensing board where we reside - and if so, can you provide any guidance as to how to ensure I am providing appropriate notification to maintain our membership with APPIC?

APPIC does list a minimum for school psychology trainees.  This does not apply to clinical or counseling trainees who are not located in a school setting.  APPIC does not mention an hours requirement for clinical or counseling internships.  APPIC does have a requirement for 12 months, full time or 24 months, half time.  APPIC defers to the internship program to be flexible during this unprecedented time.  It is the program's responsibility to ensure that ALL of your successful trainees meet the expected competencies set by the program.  Most licensing boards do not have an hours requirement, but some do.  APPIC requires programs to ensure their graduates are eligible for licensure in the jurisdiction in which the program resides, so this question may be asked of the state board.  However, it is doubtful they can answer that if it is in a regulation or law regulated by the legislature.  I would expect, but cannot guarantee that a state board would be flexible.  I anticipate the state board would, but given we have no idea where this situation is going, will it be another 2 weeks, 2 months, 12 months?  Once the peak has passed and does not resurge, I think there will be more answers.  In the meantime APPIC is being supportive and trusting of programs to do the right thing, keep trainees safe, continue the training program in some form that allows safety through telehealth, virtual meetings, etc.  

I'm sorry there are no hard and fast answers and APPIC trusts the training programs to make the best decision for the situation that is facing them.