News

Dear Colleagues

Although current UK Government guidance does not extend to including either specific advice or necessarily a prohibition on the provision of ‘talking therapy’ services conducted in private practice, and the GHR cannot therefore provide a definitive answer as to whether or not face-to-face therapy is permissible, our cautious view would be that the resumption of face-to-face therapy (i.e. with the physical presence of both therapist and client) could nonetheless be on the near horizon.

Indeed, if you open the link at https://www.gov.uk/government/publications/further-businesses-and-premises-to-close/further-businesses-and-premises-to-close-guidance and scroll down under the item ‘Businesses and venues that must remain closed to members of the public’ to ‘Retail’, ‘Exceptions’, you will note that the following businesses are now exempt from closure subject to all required safety measures being in place: Dental services, opticians, audiology services, chiropody, chiropractors, osteopaths and other medical or health services (including physiotherapy and podiatry services), and services relating to mental health. (A further Government note to this states: “Services which involve healthcare need to take into account any advice or guidance issued by regulators, the relevant professional body, Chief Professional Officers, or the NHS, as appropriate”).

Although it does therefore appear that therapists (presumably working within a clinic setting) might well be entitled to offer face to face sessions, what is less clear, given the prohibition on allowing visitors (in our case, clients) into your home, is whether this exception would extend to therapists working from a home-based office.

Working from home wherever possible has been promoted by Government since the Covid-19 outbreak began, but relying on this to justify face to face working with clients from your home might not yet be sufficient, unless deemed to be absolutely essential for the continued wellbeing of the client. However, given the recent further relaxation of ‘lockdown’ requirements, some practitioners may nonetheless decide to do so on their own volition regardless.

For those that do make that decision, as the over-riding factor must be your own safety and the safety of your clients, together with the safety of the family members of both parties (and others who both you and they may come into contact with), there is much that must be taken into consideration before such a resumption should be contemplated, and we list below some very basic questions that would need to first be addressed:

Are both myself and the client fully able and willing to engage in sessions by remote means rather than face-to-face

Have either I or members of my household displayed any of the publicised symptoms of the onset of coronavirus within the last 14 days

Do the particular needs of the client out-way the risks involved in face-to-face therapy

Have I fully taken account of both the client’s age and any known pre-existing health issues 

Has the client fully considered the inherent risks in travelling both to and from my practice location

Have I ensured that all required safety measures are in place (i.e. hand cleansing facilities both before and after each session; correct social distancing throughout entire session etc.)

Have I made provision for the possibility of the client falling ill during the session and consequently requiring assistance

Has consideration been given to the possible contagion risk arising as a consequence of client use of the toilet facilities 

Have I considered the ramifications should I subsequently test positive for the virus (e.g. contact tracing by the NHS could oblige me to reveal the identity of clients and thus compromise issues of confidentiality)

Have I contacted my insurance company to confirm that my professional indemnity and (if working from home) household policies fully cover me for providing therapy to clients during the current pandemic 

Have I contacted Public Health/my Local Health Authority to gain confirmation that I can return to face to face work and to obtain guidance on my social distancing and sanitising procedures

Beyond the above essential considerations, the Complementary & Natural Healthcare Council (www.cnhc.org.uk), in which the GHR is a Verifying Organisation for those who wish to register within its Hypnotherapy Section, has issued recent guidance to its Registrants (many of whom are registered within the GHR) entitled “COVID-19 guidance for Registrants: Preparing to return to work (29 May 2020)” which may be viewed at https://www.cnhc.org.uk/sites/default/files/News/COVID19_PreparingtoWork_v2.pdf

and consideration of its content (essentially a ‘risk assessment’ overview), whilst not all of which is necessarily relevant to hypnotherapy practice, should nonetheless provide significant assistance to you when the time comes.

Consequent to the above, because the GHR acknowledges the possibility that some practitioners may decide to resume face to face sessions on their own volition, we would stress  that it remains the personal responsibility of each practitioner who may be considering doing so to both review and consider the foregoing most carefully before proceeding.

It is also imperative that you personally contact your Insurers to enquire what their view may be in regard to maintaining full cover under your policy should you decide to re-commence face-to-face sessions.

N.B. The GHR has been in communication with its four preferred Insurers (i.e.Towergate, Howden, Balens and Holistic) on this issue and we set out below their respective most recent responses:

Towergate

“At this moment in time the government have not issued advice as to whether this work can now be restarted on a face to face basis therefore we would say that if the counsellor can work from home then they should.

If they feel it is necessary to undertake face to face sessions they must absolutely follow guidelines in respect of social distancing etc. and in the event of a claim be able to demonstrate that they adhered to guidelines.

Claims will be assessed on an individual basis so it is down to the individual to decide if they need to carry out client sessions face to face.”

Howden

“Thank you for your email. Our policy will continue to cover face to face work providing that government guidelines and any guidelines set by associations such as yourselves are met.”

Balens

“I can confirm that Balens will continue to insure the activities noted on the schedule of insurance providing the policy is active and has not been cancelled. Unfortunately, it is outside of Balens remit to advice whether practitioners can or cannot practice. From an insurance perspective providing they follow government guidelines and where relevant the advice of their professional association or governing body and that this is evidenced where appropriate the policy will respond (within the standard terms and conditions of cover).

I appreciate this does not answer all the questions raised below but hopefully will help to understand the insurance aspect.”

Holistic

“Thank you for your email. Yes, you are correct in thinking that if one of our policyholders works outside of the law in any way then the policy will not meet any related claims.

We understand that you may be wondering if you can return to work, we do not have a definite answer to this question. You will need to contact Public Health, your local Authority or maybe your MP who may be able to offer advice and guidance for your specific circumstances and for your locality.”

N.B.2 There are regional differences in guidance issued by the devolved parliaments within the UK and significant differences in directives issued within other countries world-wide which should be taken into account by Registrants whose practice locations might be affected by such differences

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