Non-Face-to-Face Clinical Work and Billing Policy
Safe & Sound Counselling
Ethical and Clinical Responsibilities Outside Sessions
Therapists have an ethical and legal duty of care that extends beyond face-to-face appointments. In line with professional codes of ethics, reasonable steps are required to prevent physical, emotional, or psychological harm.
This includes circumstances where client behaviour, communication, or external pressures indicate possible risk, rupture, or destabilisation. In some situations, especially where there is risk, abuse, or unusual circumstances, documentation is required. This is not mere administration; it is part of ethical practice and clinical care, and it can take significant time, work, and effort, often outside normal hours.
This work requires clinical judgement, expertise, reflection, and action, and should not be minimised or devalued.
Some situations also require documentation, follow-up records, summaries, letters, reports, and other written material needed to support safe and ethical care. These are different from case notes, which do not warrant an extra charge.
The Reason
The therapist must be attuned to subtle shifts in communication or presentation, especially in trauma-affected or vulnerable clients, where the therapeutic alliance can become fragile or disrupted.
The responsibility to maintain safety, respond to rupture, and preserve therapeutic integrity may require professional time and care even outside scheduled sessions. This may be billable. It is never intended to generate income unnecessarily, and the amount charged is often modest compared with the time and effort involved.
Rupture, Responsibility, Transference, and Triangulation
Non-face-to-face clinical work can occur due to transference, projection, or avoidant behaviour. Therapy-interfering behaviours can also result from triangulation involving other parties such as billpayers, third-party funders, or partners/ex-partners.
In these cases, reflection on tone shifts, review of notes, and outreach to explore the circumstances may be necessary, particularly if something does not add up. The therapist has an ethical responsibility to the community as well.
Emotional volatility or shutdown may require containment and understanding of contributing factors, potentially resulting in time spent on exploration and investigation, often via text, email, or phone.
In accordance with the PACFA Code of Ethics and the ACA Code of Ethics, practitioners have an ethical responsibility to act in the client’s best interests and to maintain the therapeutic relationship, even when this requires action outside scheduled appointments. This may include drafting follow-up messages, reviewing client communications, documenting clinical events and ethical decision-making processes, and updating care plans as clinically indicated.
The counsellor may occasionally need to spend time outside office hours on a unique or complex presentation. If there is an event or suspicion that could cause harm, whether physical, emotional, financial, psychological, or legal, investigation or work may be required. Permission cannot always be obtained in advance, which is why it is requested in the consent forms.
Every counsellor has ethical obligations. It is possible to avoid these fees, and clients are encouraged not to be put off. At the same time, the time spent on a case comes at a cost, and that cost may arise from another person’s actions. The price paid by the counsellor can extend far beyond finances and can affect family time, self-care, other income, and health.
Responsibilities Involving Third Parties – Letters, Reports, and Advocacy
Where needed, contact may be made with family members, funders, or professionals (for example, NDIS, Victim’s Assist, doctors, psychiatrists, support coordinators, schools, or lawyers) to advocate for the client’s care, provide correct information, share progress updates and context, advise of risk factors, or make specific client requests.
These actions are not administrative. They require careful thought, clinical judgement, and expertise, especially in contexts involving high scrutiny, disbelief, or suspicion.
The preparation of letters, reports, summaries, or meetings can require significant time and effort and should not be underestimated.
The language and level of precision must be tailored to each professional, and there can be legal and ethical implications for each document bearing a professional signature.
This policy applies to both clients and any third parties involved in the therapeutic process.
Clinical vs. Administrative Tasks
Administrative work (not billable)
- Booking, rescheduling, or cancelling appointments via text, email, other media, or in person.
- Sending invoices, receipts, or logistics-related forms.
- Uploading routine documents such as case notes, completed forms, or standard session resources.
- Brief responses to logistical queries.
Clinical work (billable)
- Substantive or therapeutic communications via email, text, WhatsApp, or similar platforms, including reading lengthy reports or emails.
- Therapeutic analysis or ethical risk assessments.
- Follow-up related to transference, projection, or sudden withdrawal.
- Rupture repair, especially where third-party input or influence is involved.
- Emotional containment.
- Updating treatment plans or direction based on out-of-session changes or communication when it exceeds a reasonable amount.
- Writing reports, emails, and letters that require significant time and focus.
- Meetings about or on behalf of the client (for example, legal, medical, or NDIS-related).
- Creating tailored therapeutic resources or service packs upon request or when offered to the client.
- Documenting ethical reasoning where there is ambiguity and increased risk.
- Consulting on ethical dilemmas that go beyond routine supervision.
- Reiterating policies that have already been agreed upon, either implicitly or explicitly, in signed paperwork.
- Unreasonable amounts of time spent following up on payments or defending work done, especially where third-party payers are involved.
- Work done to advocate for the client’s needs, especially when it is already provided at a reduced rate.
If an action is taken for the safety of the client, participant, or dependent, is crucial to their wellbeing, or offers therapeutic benefit, and includes professional judgement, advocacy, or support of the therapeutic relationship, it may be considered billable.
Complex Cases and Additional Professional Work
When cases are complex, additional work such as analysis, treatment planning, clinical formulation, case review, and similar professional tasks may also be billed where appropriate.
Misunderstandings and Disputes
If there has been a misunderstanding or oversight entirely on the therapist’s part, the situation and actions will be reviewed, reflective practice undertaken, supervision sought, and full accountability taken for any oversights, with all related costs absorbed.
Should feedback from clients or any involved third parties be perceived as unfair, unreasonable, misinformed, or misaligned with the therapist’s experience or impression, the communication will be reviewed, self-reflection undertaken, and supervision sought for objectivity. The therapist’s position will then be respectfully communicated to the client or the third party involved.
Findings will be provided, and all those involved are respectfully asked to review the information presented, self-reflect, and attempt to understand the situation from the perspectives of all parties.
Please remember:
- Fairness is a key goal in every decision-making process.
- Distress can create blind spots and may lead to misunderstandings, mistrust, miscommunications, projection, or transference.
- Misunderstandings or miscommunications can occur, especially when third-party funders are involved.
- Certain organisations have complicated and sometimes unclear requirements for securing and processing funding.
It is understandable that this can be frustrating for third-party payers, especially parents, who may have limited knowledge about the purpose of payments. Full transparency is aimed for; however, this must be balanced with the client’s right to confidentiality, in compliance with privacy laws and ethical responsibilities.
Therapists often fulfil various roles for clients to ensure their needs are met and their safety is prioritised. These include advocate, case manager, support person, system navigator, crisis manager, researcher, interpreter, recruiter, and mediator between clients and third parties.
While this policy is not about assigning blame, if a situation arises that affects the therapist’s workload substantially and through no fault of their own, some or all costs may need to be passed on to the client.
Where advocacy, coordination, or support has been provided to secure services, support, or documentation, cooperation is respectfully requested in ensuring fair compensation and recognition for the therapist’s time and labour. This may include communicating with third-party funders, acknowledging the scope of the work undertaken, or assisting in resolving disputes when needed.
Therapeutic care is a collaborative effort, and so is sustaining the services that support it.
Please keep this document accessible for reference prior to escalating concerns and to minimise unnecessary disputes. Communication should always be polite and respectful.
Numerous policies clearly outline the requirements for working with this practice. Engaging in these services implies implicit consent, and signing paperwork provides explicit consent.
Unacceptable Behaviours
Aggression, intimidation, coercion, deliberate attempts to triangulate, manipulate, control, or confuse and distort reality are not tolerated and may result in immediate termination and escalation. Repeated reiteration of agreed-upon policies is considered unnecessary and may be billable.
Weaponised bureaucracy, bad faith claims, and financial abuse will not be tolerated and will be reported, disputed, or escalated legally, depending on what is appropriate.
Billing and Transparency
When non-face-to-face clinical work is undertaken, it is billed at the standard or after-hours session rate (an extra $20/hour), depending on when it occurs. These charges are not penalties; they reflect the professional time, care, and emotional labour required for work deemed necessary for the client’s wellbeing.
Additional work is not intentionally sought for its own sake or for financial gain. Often, substantial time is absorbed, and the full extent of the time and work performed is not always charged. The goal is to maintain fairness, boundaries, and sustainability within the practice. Charges are transparently recorded in clinical notes and invoices.
The signed Payment Policy, Terms and Conditions, or Credit Card Authorisation provide explicit consent to allow billing for the rare instances when these costs may occur. Where possible, verbal consent is sought or advised in advance, although this may not always be feasible in urgent or complex situations, especially when the scope expands more than initially expected.
This document and the Code of Conduct should also be read and referred to as part of informed consent, as they explicitly cover this billing practice. If an unusual situation arises or more time is required than expected, full transparency and an explanation will be provided via email, text, or in person, and on the invoice.
Where third-party payers are involved, consent must be provided by the client (if not a minor) regarding the extent of any disclosure.
Third-party payers may refer to this document for further clarification. As mentioned, only clinical work is charged for, much of which occurs in specific scenarios.
Lastly, it is entirely possible to utilise these services and never incur these types of fees.
Final Notes
Non-face-to-face clinical work is common in complex therapy, particularly when trauma, neurodivergence, systemic harm, or relational issues are involved.
The aim is to offer flexible, affirming, and attuned care, but that care must be delivered sustainably and within professional boundaries.
By understanding this policy, clients are empowered to use sessions for therapeutic work and know what to expect if support or response is needed outside of session.
If there is uncertainty about whether something is billable, please refer to this document or ask for clarification in the next session. Fairness, ethical practice, and transparency are always the guiding principles in decision-making.
While significant time and effort are often provided pro bono, please note that there are limitations regarding the capacity to absorb additional costs, especially if they are unnecessary.
Please refer to this policy for any questions regarding non-face-to-face billing. Thank you for your cooperation and understanding.