Logging Telehealth Hours (California Trainees and AMFTs)

Given the current pandemic there are a lot of questions about logging telehealth hours.  Below is the latest information on these topics that is specific to MFT Trainees and AMFTs.

How do I log telehealth hours if I plan to submit my application under the Option 2 (old requirements)?
The Option 2 requirements have a category maximum for telehealth and therefore you must log telehealth hours in that category.  If you provide individual counseling, group counseling or diagnosis/counseling with couples, families and children via telehealth, they should be logged in the telehealth category.  Under Option 2 telehealth hours may not be logged in any other category.  On Friday, May 15 the BBS hosted a Facebook Live event and confirmed that you must continue to follow the aforementioned approach to logging hours in order to remain in compliance with the regulations.  Furthermore, the category maximum for telehealth (375) will continue to be enforced.  If the BBS grants a waiver on either of these issues we will notify you.

What if I am unable to complete my 3,000 total hours and/or 500 CFC hours as a result of the inability to log CFC hours now that I am exclusively providing telehealth?

On Friday, May 15 the BBS hosted a Facebook Live event and stated that if you are unable to complete the Option 2 requirements by December 31, 2020 as a result of these issues you should post-mark your application by that date (the deadline for submitting under the old requirements).  The BBS will review your application and you will receive a deficiency letter.  You will have one year from the date of the deficiency letter to submit additional hours and you will still be evaluated under the Option 2 requirements.  You must post-mark your application by December 31 or you will lose the ability to choose Option 2.

How do I log telehealth hours if I plan to submit my application under Option 1 (new requirements)?
The Option 1 requirements do not require hours to be logged under the category of telehealth because there is no maximum for that category and the category of telehealth is not reported separately on the Option 1 forms.  Whether you provide counseling face-to-face or via telehealth, the hours should be logged under individual counseling, group counseling or diagnosis/counseling with couples, family and children.  Although the telehealth hours should not be logged under the category of telehealth for purposes of tracking hours for the BBS, please note that there are some states that require a breakout between face-to-face and telehealth hours when applying for licensure.  For purposes of license portability we recommend using the Notes field in TYH to indicate which hours are telehealth in case you ever need to report these hours separately at some point in the future.  In addition, if you are a Trainee, your College or University might require you to be able to separate face-to-face hours from telehealth hours.  NOTE:  If you plan to submit your application on or after January 1, 2021 you must use the Option 1 requirements.

What if I am uncertain whether I will submit my application under Option 1 or 2?
You should follow the guidance above for the Option 2 requirements (telehealth hours must be logged under the category of telehealth) and you should continue to use the Option 2 forms.

What if I am also logging APCC hours?
The LPCC Option 1 requirements, which all APCCs should use, do not require hours to be logged under the category of telehealth because there is no maximum for that category and the category is not reported separately on the Option 1 forms.  Although the hours should not be logged under the category of telehealth for purposes of tracking hours for the BBS, please note that there are some states that require a breakout between face-to-face and telehealth hours when applying for licensure.  For purposes of license portability we recommend using the Notes field in TYH to indicate which hours are telehealth in case you ever need to report these hours separately at some point in the future.

Can I provide services via telehealth?
Yes!  All trainees and associate marriage and family therapists are permitted to perform services via telehealth with clients who are located in California under the supervision of their supervisor.

Am I required to receive face-to-face supervision?
As a result of a waiver issued by the BBS, trainees and associates are not required by law to meet with their supervisor in-person during this state of emergency.  You may gain your required weekly direct supervisor contact via two-way, real-time videoconferencing.  The BBS recently clarified that this waiver is active from March 4, 2020 (the date of the Governor’s initial state of emergency declaration) forward.

Do I still need to submit original forms with wet signatures when submitting my application?
The BBS has always required original forms with wet signatures to be submitted with the application for licensure.  The BBS hosted a FB Live session on Friday, May 8.  During this session they stated that scanned forms will be accepted during the COVID-19 pandemic.   What does this mean?  You can email your experience verification form to your supervisor for a signature and he/she can sign it, scan it and email it back to you.  It is unclear when/if the BBS will revert back to requiring wet signatures but for now you can submit scanned documents.