(p. 86) I’m the Boss. Who Needs Policies and Procedures?
You are now the boss—the owner of the practice. You can do things your way. You even can change your mind and decide certain things as you go. Policies and procedures are just for big corporations, right? As the owner of a solo practice, or even a group practice, you are not really a corporation and don’t need complex policies and procedures. That is for a Human Resources Department. You can address issues as they arise, using your judgment in deciding how to respond.
Understanding This Myth
Having policies enables you to respond to different situations consistently and fairly, rather than needing to make a new decision about each situation that arises; something that may be difficult to do when clients are making requests that may be contradictory to good business practice. Policies also make your expectations of your staff clear and explicit. They can even be conditions of employment (e.g., following professional ethics and practice standards).
Policies also can help you more successfully take a customer service-oriented approach to interactions with your clients, which can help increase the success of your practice (Garner & Barnett, 2017). This applies to how you personally interact with clients as well as how the staff in your office and anyone else associated with your practice interacts with your clients to ensure that all actions taken are ethically and legally appropriate (Fisher, 2009). Having written policies is an important part of good customer service, and these policies should focus on providing high-quality clinical and administrative services to clients, while also protecting you and helping to ensure that your business runs smoothly and effectively.
(p. 87) Moving Beyond the Myth
Even if you don’t own the practice and are working for someone else, it is extremely important to have written policies and procedures to guide you, and all those who work with and for you, in the conduct of your practice. That is, you are still responsible for the care you provide (once you are licensed). How you provide the care, assess progress, protect confidentiality and record security, and almost any other clinical and administrative aspect of practice may need a policy to help provide clarity and guidance. It especially makes good sense to develop policies in advance of when they are needed, so that each individual in your practice can respond appropriately and consistently. As you are planning your practice and setting it up, drafting these policies and procedures is something that is important to do. It also can be helpful to have a senior colleague who can serve as a consultant around the policies in order to give you input (what works, what might need to be changed, what have you not considered?). It is also good to periodically (annually) review these policies to make sure changes aren’t warranted.
Clients should be informed of pertinent policies, so they are not surprised by them. Because the counseling and psychotherapy relationship is one that is built on trust, it is important that clients don’t ever feel taken advantage of or deceived. Ensuring that clients know all relevant office policies in advance is essential. This information should be included as part of each client’s informed consent process. It is also important to keep in mind that informed consent is not a one-time event, but rather an ongoing process (Barnett, Wise, Johnson-Greene, & Buckey, 2007). Thus, it is important to review pertinent aspects of the informed consent agreement periodically, because they may be relevant to each client.
A range of policies can make the day-to-day running of one’s practice more effective. Examples include policies on fees and financial arrangements, confidentiality and release of records, participation in social media, giving court testimony, and record retention and disposal. Topics covered by such policies might include:
• When is payment due? Is it at the end of each session? Do you bill clients monthly?
• How is payment accepted? Do you accept credit card payments, or do you only accept payment by cash or check? If you accept payment by check, do you have a policy on returned checks? Does the client pay any bank charges for returned checks? Do you require cash payment or payment by credit card after a certain number of checks are returned for insufficient funds?
• How do you handle outstanding balances and late payments? Do you charge a percentage of the balance owed each month until payment is (p. 88) made? If so, what is that percentage? How large an outstanding balance will you allow to accrue, and what actions will you take when that limit is reached? For example, if your policy is that you only allow a maximum outstanding balance equal to the charges for three sessions, having a policy in place that specifies the options available at that time can prove very helpful (Barnett & Walfish, 2012). For example, will you terminate the client’s treatment with you and refer them elsewhere, such as to a low-cost provider? Or, will you allow the client to continue in treatment while making agreed upon additional payments each month until the balance owed is paid? Ensuring that clients are aware of such policies in advance and reminding clients of them as they become relevant is an essential business practice.
• Do you have a policy on missed appointments and those that are cancelled within a certain number of hours of the appointment time? See Chapter 17 for detailed information on this type of policy.
• Do you have a policy on collecting fees owed to you? Will you send former clients letters requesting payment for fees owed to you? Will you take the client to small claims court or hire a collection agency to attempt to collect the fees for you? Evidence suggests that clients who had previously been very pleased with the treatment they were receiving become quite dissatisfied when confronted by such apparently antagonistic and aggressive methods of fee collection, and then may file ethics or licensing board complaints or malpractice suits (Knapp, VandeCreek, & Fingerhut, 2017). Thus, having a written policy you share with clients in advance should be very helpful, and the use of what may be perceived as aggressive methods to collect fees owed should be carefully considered and perhaps avoided.
Participation in Insurance and Managed Care
• Do you participate as an in-network provider for any insurance companies? If so, how do you verify each client’s coverage, their deductible, and their copayment for each session? How do you address treatment needs when the limits of a client’s insurance coverage are reached? Do you offer financial options for clients so they can continue their treatment even when their insurance coverage is exhausted, such as a sliding fee scale, or do you refer them to other providers who may be more low cost for them?
• If you do not participate as an in-network provider for a client’s insurer, are you an out-of-network provider (if their insurance allows for this) and if so, what are the implications of this for the client? Do you provide each client with a completed superbill or insurance form at the end of each session, which they can submit to their insurer for reimbursement? (p. 89) Does this include a diagnosis for the client (something required by insurance companies to process a claim)?
• What are your fees for the various services you offer? These can include psychotherapy, assessment and psychological testing, providing copies of records, telephone consultations, time spent responding to client e-mails, court testimony fees, and so on. You may charge a specific fee by the amount of time you spend, regardless of the actual service provided, or you may charge different fees based on the services provided; for example, psychotherapy versus court testimony.
• Do you plan to ever increase your fees over time? Your business expenses such as rent, utilities, insurance, and staff salaries and benefits increase over time, so why wouldn’t you periodically increase the fees you charge? Your policy on fee increases should be clearly stated in the informed consent process, so that clients can anticipate fee increases and plan their treatment and other expenses in their lives accordingly. Some clinicians increase their fees on the first of the year each year, and others only increase their fees periodically with new clients.
• If your practice operates with a sliding fee scale this should be clearly stated and discussed with clients from the outset. It will be important to explain your policy and the criteria for qualifying for a reduced fee. It also should be stated what types of documentation, if any, are required to qualify for a reduced fee. Some clinicians base the fee they charge on the client’s income and utilize copies of paychecks or tax filings as proof of each client’s income. Others base the fee reduction on a discussion with the client that includes consideration of income as well as other expenses, such as the number of children the client has and whether the client has a spouse or partner’s income, or is a sole provider.
Requests for Records and Releases of Information
• Do you have a written policy that addresses the steps you will take when you receive a request for a client’s records from a third party, as well as for when clients request that some of their treatment information be released to a third party? These situations may not always be straightforward and dilemmas may arise. Having a list of steps to go through to guide our decision-making and the actions to take can be extremely helpful.
• Do you have a form that individuals will complete and submit to you to make a written request for treatment records or treatment information? Responding only to written requests that include sufficient information (p. 90) to make an informed decision is an example of a policy to have in place. Other examples include ensuring that the requestor has the authority to authorize the release of the information, ensuring that requested materials or information will meet the objectives of the request (e.g., if a brief treatment summary will suffice, it would be inappropriate to release the entire treatment record), and ensuring that the client understands the likely consequences, both positive and negative, of the anticipated release of records or treatment information, thereby helping the client to make an informed decision.
We hope we have established the importance of having a variety of policies that guide how you will function in your practice, how you will respond to client requests, and how you will manage your practice internally. By reviewing all relevant policies as part of the informed consent process and providing clients with copies of the policies (or access to them on your website), and then reviewing them with clients on an ongoing basis when the need arises, it is hoped that conflicts and hard feelings that otherwise may adversely impact the treatment relationship can be avoided. It also is important to ensure that all policies are consistent with the dictates of your profession’s code of ethics as well as with your licensing law and accompanying regulations.
Barnett, J. E., & Walfish, S. (2012). Billing and collecting for your mental health practice. Washington, DC: American Psychological Association.Find this resource:
Barnett, J. E., Wise, E. H., Johnson-Greene, D., & Buckey, S. F. (2007). Informed consent: Too much of a good thing? Or not enough? Professional Psychology: Research and Practice, 38, 179–186.Find this resource:
Fisher, M. A. (2009). Ethics-based training for non-clinical staff in mental health settings. Professional Psychology: Research and Practice, 40, 459–466.Find this resource:
Garner, T. A., & Barnett, J. E. (2017). Customer service for private practitioners. In S. Walfish, J. E. Barnett, & J. Zimmerman (Eds.), Handbook of private practice: Keys to success for mental health practitioners (pp. 297–307). New York, NY: Oxford University Press.Find this resource:
Knapp, S. J., VandeCreek, L. D., & Fingerhut, R. (2017). Practical ethics for psychologists: A positive approach (3rd ed.). Washington, DC: American Psychological Association.Find this resource: