8.2 Clients Receiving Services Elsewhere & Client Transfers

8.2 Clients Receiving Services Elsewhere & Client Transfers

Exam Focus: Task 34 — "evaluate nature of clients' relationship with other treatment providers to prevent confusion or duplication of services." Two knowledge statements: ethical standards regarding accepting clients who are receiving services from other providers (K91) and ethical standards regarding client transfers (K92).

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The Rule and Its Reason

ACA A.3 (Clients Served by Others) states that when counselors learn that a client is in a professional relationship with another mental health professional, they request consent from the client to inform the other professional and strive to establish a positive and collaborative professional relationship.

Note what the standard does not say. It does not prohibit concurrent treatment, and it does not require the counselor to decline the client. The risk being managed is clinical, not territorial:

• Conflicting treatment plans — one clinician working toward exposure while another counsels avoidance.
• Split alliances — the client uses one clinician against the other, and neither has the full picture.
• Duplicated or contradictory interventions — two safety plans with different instructions.
• Incomplete risk information — the client discloses suicidal ideation to one provider only.
• Payer problems — most insurers will not reimburse two providers for the same service on the same day.

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The Intake Sequence

1. ASK at intake: "Are you currently working with another therapist,
   counselor, psychiatrist, or program?"  Ask again if the picture changes.
2. CLARIFY the other provider's role, modality, frequency, and goals.
3. DISCUSS with the client why coordination matters and what will be
   shared.  Address the client's reasons for seeking a second provider.
4. OBTAIN a written authorization that complies with Civil Code 56.11
   (14-point type or handwritten, stand-alone, specific parties,
   specific information, purpose, expiration date, right to a copy).
5. COORDINATE: define roles in writing so each provider and the client
   knows who does what.
6. DOCUMENT the conversation, the client's decision, and the coordination.

If the client refuses consent to contact the other provider, the counselor cannot make the contact — California's Confidentiality of Medical Information Act does not contain an exception for professional courtesy. The counselor then decides clinically whether treatment can proceed safely without coordination, discusses the risks with the client, and documents. For a low-risk client seeing a career coach, proceeding is usually fine. For a high-acuity client whose psychiatrist is making medication decisions without information, the counselor may reasonably decline to begin, explaining why.

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When Concurrent Treatment Is Appropriate

Concurrent care is common and often indicated. What makes it ethical is role differentiation:

What is generally not appropriate: two clinicians providing the same individual psychotherapy for the same problem at the same time, without either knowing about the other.

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Transfers

A transfer moves an existing case to a new clinician. A referral sends a client to an additional or alternative provider. Transfers carry continuity duties:

1. Explain the reason honestly — a counselor's relocation, a change in the client's needs, an agency policy, the end of an associate's registration.
2. Give reasonable notice and hold a closing or transition session where feasible.
3. Provide concrete options, not a directory search, with verified availability and relevant expertise.
4. Transfer records with authorization, including a clinically useful summary of course of treatment, risk history, and current safety plan.
5. Provide bridging coverage for the gap between the last session and the new clinician's first.
6. Document the rationale, notice, options offered, the client's response, and the transfer date.

An abrupt transfer of a client in acute crisis without notice, referrals, or coverage is abandonment under ACA A.12 and supports a BBS unprofessional-conduct allegation under BPC § 4999.90.

California-specific transfer trigger: an APCC who reaches the end of a registration period, changes employers, or loses a supervisor must transfer clients. The associate cannot simply keep seeing clients while unsupervised, and the supervisor shares responsibility for ensuring an orderly transfer.

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Vignettes

Vignette 1 — The undisclosed second therapist. In session six, a client mentions she has also been seeing another therapist weekly the whole time. Best answer: explore why, explain the risks of uncoordinated parallel therapy, request written authorization to contact the other clinician, and if the client consents, coordinate roles or agree with the client and the other clinician on a single primary therapist. If the client refuses, assess whether safe treatment is possible and document.

Vignette 2 — The refusing client. A high-risk client with a recent suicide attempt refuses to allow contact with her psychiatrist. Best answer: the counselor cannot contact the psychiatrist without authorization. He explores the refusal, explains why coordination matters for medication and safety, and may decline to continue if he cannot practice safely — arranging referral and coverage rather than abruptly stopping.

Vignette 3 — The relocating counselor. An LPCC is moving out of state in six weeks. Best answer: notify clients as soon as the decision is firm, allocate remaining sessions to closure and transfer planning, provide at least two or three vetted referrals per client with verified availability, transfer records with authorization, and document.