Overview

Remote therapy sessions via video or phone. Documentation must note the modality used, participant locations, technology issues, and compliance with state telehealth regulations. When using the GIRP Notes format in telehealth settings, documentation requirements and best practices differ from other environments based on specific operational, compliance, and billing needs.

This guide provides setting-specific guidance on how to apply the GIRP Notes structure while meeting the unique compliance, billing, and operational requirements of telehealth practice. Understanding these distinctions ensures your documentation meets regulatory standards and operational expectations.

Environment & Documentation Considerations

  • Document the telehealth modality used (video, phone, audio-only) in every note; some insurers or state regulations mandate this for claim processing and compliance verification
  • Privacy and safety considerations differ: document whether client was in a private location and could speak freely; note if session had to be rescheduled due to privacy concerns
  • Technology issues and their clinical impact must be noted: if video connection dropped during a sensitive disclosure, if client was in a public space affecting openness, if audio quality impaired clinical assessment

Compliance & Regulatory Considerations

  • State telehealth licensure laws vary; document compliance with state-specific requirements (e.g., geographic limitations, informed consent for telehealth, in-person assessments)
  • Federal DEA regulations for prescribing in telehealth settings require specific documentation of identity verification and prescriber-patient relationship establishment; if prescribing, note these elements

How to Document GIRP Notes for Telehealth

Goals

Document current treatment goals, client's goals for this session, and progress toward established objectives

When documenting Goals in telehealth sessions, clearly define the patient's targeted outcomes while considering the unique constraints and opportunities of remote care. Specify objectives that are measurable and achievable within the virtual setting.

  • Identify specific behavioral or symptom targets adapted for telehealth delivery.
  • Set goals that incorporate the patient’s technological capabilities and access.
  • Include objectives that address improving engagement through virtual platforms.
  • Define measurable progress indicators suitable for remote monitoring.
  • Establish goals related to enhancing patient self-management in a telehealth context.

Intervention

Record specific interventions applied to address identified goals and advance treatment

This section should detail the therapeutic techniques, clinical observations, and modalities utilized during the telehealth session. Document how interventions were adapted or delivered through the virtual format.

  • Describe the use of telehealth-specific tools, such as screen sharing or digital worksheets.
  • Note clinical observations of patient affect, behavior, and environment via video or audio.
  • Document application of remote therapeutic techniques, such as guided self-reflection or virtual cognitive exercises.
  • Record any technical issues encountered and their impact on intervention delivery.
  • Specify adaptations made to traditional interventions to suit remote engagement.

Response

Note the client's response to goal-focused work, progress indicators, and barriers to goal achievement

Document the patient’s reaction and clinical progress as observed during the telehealth session, including any diagnostic impressions influenced by the remote format. Evaluate engagement and symptom changes noted through virtual interaction.

  • Assess patient’s verbal and nonverbal responsiveness during the virtual session.
  • Evaluate progress toward goals within the telehealth context.
  • Note any changes in symptom presentation observed remotely.
  • Document patient feedback regarding the telehealth experience and intervention efficacy.
  • Include clinical impressions that consider limitations or advantages of telehealth assessment.

Plan

Specify action steps, revised goals if needed, and timeline for goal achievement

Outline the next steps tailored for ongoing telehealth care, including treatment adjustments, homework assignments, scheduling, and referrals. Ensure plans accommodate the virtual delivery model.

  • Schedule follow-up telehealth sessions with consideration of patient’s availability and technology.
  • Assign telehealth-appropriate homework or self-monitoring tasks.
  • Modify treatment approaches based on telehealth session observations and patient feedback.
  • Plan referrals to local in-person services if telehealth limitations impede care.
  • Outline contingency plans for technical difficulties or patient access issues in future sessions.

Tips for GIRP Notes for Telehealth

1. Connect to Diagnosis

Always connect your observations back to the relevant diagnostic criteria for Telehealth. This shows clear clinical reasoning and justifies the treatment plan in the Assessment and Plan sections.

2. Track Treatment Progress

Document how the client responds to specific interventions over time. Note changes in symptoms, behavioral patterns, and functional status. This is especially important for demonstrating treatment efficacy and meeting insurance requirements.

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Further Reading

  • HHS HIPAA — Provides essential guidelines on privacy and security requirements critical for telehealth documentation compliance.
  • APA Documentation Guidelines — Offers detailed standards for clinical documentation, including note structure and ethical considerations relevant to GIRP notes.
  • CMS Documentation Requirements — Outlines federal requirements for clinical documentation that impact telehealth billing and compliance.

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