Counseling Policies and Procedures

Please see here for my technology and security policies and procedures. These policies and procedures outline my HIPAA compliancy practices, the technology I use, and the security measures I have in place to protect your privacy.

Federal and State laws protect your confidentiality (See 42 U.S.C. 290dd-3 and 290ee-3 for Federal laws and 42 CFR Part 2, 491.0147 FL). Michelle Robin Gould, LMHC, NCC, BC-TMH and the Michelle Robin Gould Corporation will not share information with any person outside of the Michelle Robin Gould Corporation without your written permission, except as required by law. Information obtained from minors is not generally shared with parents without permission. This practice does not treat minors and only confers with minors when there is a family session or an adult client requests a collateral meeting with family members.

You assume full responsibility for the safety and security any records that are provided to you by Michelle Robin Gould, LMHC, NCC, BC-TMH and the Michelle Robin Gould Corporation once they leave the practice. For your protection, it is the policy of this practice to require written authorization for the release of records, whether the request is to release records to you or to a third party. If you would like your records sent via postal mail, there may be associated fees for postage, copy costs, and preparation time. I strongly recommend that records be transmitted electronically, as this is the safest method of sharing confidential information. I protect the electronic transfer of information by using HIPAA-compliant technology when sending records. Please see my technology and security policies and procedures for details about your rights under the Health Insurance Portability and Accountability Act (HIPAA), a better understanding of the act, and a description of the tools and processes I have in place to protect your privacy and security.

Exceptions to Confidentiality

Psychotherapy is confidential, with some exceptions under the law. Contents of the therapy sessions, whether verbal or written, may not be shared with another party without your written consent or the written consent of your legal guardian. The following is a list of exceptions and limitations regarding confidentiality.

Your records are not confidential:

• When you file with your insurance company.

• When you initiate a lawsuit against a practitioner.

• When you threaten to harm yourself or others.

• When you are in need of immediate medical intervention.

Emergent Situation

I may share limited information in the event of a medical emergency or in the event of a specialized court order signed by a judge.

Standard of Care

HIPAA law allows consultation with another practitioner when such consultation is for the welfare of the client. When at all possible, I will seek to secure written permission from you before such communication occurs.

Duty to Warn and Protect

Federal regulations do not protect from disclosure of information related to a client’s involvement in a crime against property or personnel. Therapists are mandated by law to disclose pertinent information discussed in therapy if the client has an intent or plan to harm another person. As your counselor, I have the option of breaching confidentiality if you report a specific plan or intent to cause serious bodily harm to an identifiable person. If you disclose a plan or threat to harm yourself, it is my duty as your therapist to attempt to notify your family and notify legal authorities. In addition, if you disclose a plan to threat or harm another person, I am required as your therapist to warn the possible victim and notify legal authorities.

Suicide/Self Harm

Depression is common emotion expressed in therapy. But if you are feeling hopeless enough to imply or disclose a plan for suicide during the course of your therapy, I will need to take steps to ensure your safety. This would include notifying the legal authorities as well as making reasonable attempts to notify your family, psychiatrist, or primary care physician.

Animal Abuse

I will report animal abuse, including cases of neglect and hoarding.

Abuse of Children and Vulnerable Adults

As a mandated reporter, I am required under State law to report stated or suspected abuse of a child or vulnerable adult to the appropriate social service and state agencies and/or legal authorities. Vulnerable adults include the elderly, disabled, and incompetent.

Prenatal Exposure to Controlled Substances

In keeping with protecting vulnerable populations, therapists must report any admitted prenatal exposure to controlled substances that could be harmful to the mother or the fetus/child.

Minors/Guardianship

Parents or legal guardians of non-emancipated minor clients have the right to access the clients’ records. This practice does not treat minor clients. Records of adult clients that include mention of minors who were involved in that adult's treatment are considered part of that adult's therapy file and are bound by the confidentiality of the corresponding informed consent agreement.

Insurance Providers

This practice operates under a self-pay model and does not accept insurance. If you have out-of-network benefits, you may wish to send a claim to your insurance provider. Upon your request, I will provide a superbill. You will be responsible for submitting the superbill to your insurance company. Your insurance company may request additional information, including types of service, dates/times of service, diagnosis, treatment plan, description of impairment, progress of therapy, case notes, summaries, etcetera. This practice does not file insurance claims. I do not provide any information to insurance companies other than the superbill. If you provide confidential personal health information to your insurance provider or send them records supplied to you by Michelle Robin Gould, LMHC, NCC, BC-TMH and the Michelle Robin Gould Corporation, you are responsible for the safe transmission of those records from you to your insurance provider or any other party.

Informed Consent

You will receive the link to our informed consent agreement by encrypted, HIPAA-secure email once you have made initial contact using this form. By signing the informed consent agreement, you agree to the above assumption of risk and limits of confidentiality and understand their meanings and ramifications. If there is anything you do not understand in my policies and procedures after reading them, please submit any questions you may have via this form.

To protect your confidentiality, privacy, and security, I provide several means of HIPAA-compliant communication. Methods depend on which service package you select and may include:

• HIPAA-compliant forms

• HIPAA-compliant text messaging

• HIPAA-compliant email

• HIPAA-compliant calling

Please see here for more details on the programs I use for HIPAA-compliant communication with counseling clients.

Please do not contact me about counseling services on social media. Social media is not a safe or secure place to discuss confidential information. If you reach out to me there, you forfeit your confidentiality and privacy and assume all legal responsibility for any repercussions. I strongly advise that you use the HIPAA-compliant contact methods I have provided instead. See my social media policy on this page for more details.

This practice is self-pay, also known as private pay or direct pay.

• I do not accept insurance.

• I do not provide superbills for you to file a claim with your insurance.

• I do not participate in contacting or billing your insurance.

• On your informed consent agreement with me, you will be asked to opt out of insurance and acknowledge that you agree to the payment policies of my practice.

I would love to work with you, but if you have insurance and plan to file an out-of-network claim, I am not the clinician for you. You need a therapist who provides superbills, whether they are in-network or out-of-network. My business model does not accommodate the restrictions and administrative demands required when dealing with insurance.

You are under no obligation to accept my policies; you have the option to work with a clinician who accepts your insurance or who provides superbills for out-of-network claims. Please see here for resources to help you locate a provider who can serve your needs.

I do not offer sliding scale fees at this time. Detailed information on my payment policies and procedures, including fee structure, can be found here.

Payment for your initial session will be made via PayPal here. Thereafter, payment will be made in accordance with my payment policies and procedures which you can read here.

Please see my therapy service packages page here for details on your right to a good faith estimate of healthcare costs.

Appointment policies and procedures can be found here.

Cancellation policies and procedures can be found here.

Please see this page for my Notice of Privacy Practices.

One of the inherent risks in working virtually is that people try to pose as other people.

For your protection, and in compliance with the laws governing teletherapy, I use a couple methods of confirming who you are and matching your video presence to your textual and audio communications.

In your initial contact form, you will be asked to provide an identity confirmation passcode that you will come up with while filling out that form. We will refer to that passcode as your IVP (identity verification passcode). You will asked to provide your IVP when we schedule our initial session via encrypted email, when you sign the informed consent agreement, at the beginning of our first video session, in all sessions after that (video, phone, text, email), and on all forms. The IVP will help me verify that the same person who contacted me is consenting to treatment, and that this is the person I'm talking to onscreen. This system is in place to prevent someone from impersonating you.

During your initial video session, I will verify your identity by matching you with your picture ID. You must have a government-issued picture ID ready during this first session. This process protects you from another person posing as you.

In summary, you will need the following confirmations of identity:

• • • An identity verification passcode (IVP) you will establish in your initial session and provide to your counselor for identity verification in all future sessions and on all forms.

    • A government-issued photo ID

Safety during Sessions

To let me know if you are safe or in danger, we will agree on a safe word and a danger word during your first counseling session.

The safe word lets me know that you are in a secure and private location, you feel safe discussing your mental health in that location, and you are not being bullied or intimidated into conducting the session with someone else present who is not visible to me.

When you say the danger word, you communicate one of the following:

• You are experiencing a medical emergency.

• You are in immediate physical peril because someone is there with you and has threatened your safety.

• You are in danger because someone is listening or watching your session without your consent and you feel powerless to prevent this.

In all three of the above cases, as soon as you say the danger word, I will provide a plausible and casual reason to pause the session and will immediately contact your local emergency services. By using the safe word, you assert that you are in danger and want me to send help to your location. If you use the safe word fraudulently (i.e. a false alarm), you will be responsible for any legal or financial repercussions.

During your first session, you will provide me with the phone number and location of the emergency service closest to where you will typically be located during therapy. If you plan to have therapy at multiple locations (i.e. home and work), it is important to provide emergency services contact information for each location. Note that it is not practical for me to call 911 for you. Calling 911 automatically routes the caller to the caller's location. If you are in a different city, it will not help you if I call 911. This is why I need to obtain the phone number for your local emergency services.

Because we are meeting online, I cannot perform emergency services that would require my physical presence.

If you are experiencing a physical or mental health emergency between scheduled appointments, please call 911. It is not practical to attempt to manage urgent or emergency situations via text or email. If you are feeling suicidal and cannot reach me immediately and are not willing to call 911, please call the National Suicide Prevention Lifeline at 800-273-TALK (8255), or text the Crisis Text Line (text HELLO to 741741). Both services are free and confidential and are available 24 hours a day, seven days a week.

Client Conduct

To ensure the highest quality, most effective therapeutic experience, please follow these guidelines:

• Conduct yourself the same way in a virtual counseling session that you would at an in-person session. Show up fully clothed, on time, and alone (unless otherwise scheduled).

• Keep your video on during video sessions. If you would like the option for phone or text therapy, please see Tiers 2 and 3 of my service packages.

• Refrain from substance use during or just before your sessions. Some substances can interfere with the effectiveness of your therapy by affecting your reasoning and emotional state.

• Treat your clinician with the same respect you would like to receive.

• Ask questions if you have them. There is no such thing as a stupid or insignificant question.

• Do not be afraid to express feelings of discomfort. Therapy can be uncomfortable. You clinician is well-trained, but mind-reading can lead to misunderstands, so it's important to keep an open and honest line of communication in therapy.

• Please note that due to the limitations of working virtually, I do not provide emergency services. If you are in an immediate crisis, please call 911. If you experience an unexpected emergency during a session, I will follow the emergency protocol we set up during your first session. This will include calling your local emergency number to request immediate service to your location.

• Behavior should be appropriate to the situation. Inappropriate behavior includes but is not limited to nudity, verbal abuse, lack of respect for professional boundaries, and either in-person or online stalking activities. In the event of inappropriate behavior, you forfeit confidentiality and I will terminate the session immediately with no refund for the remainder of the session or for that week's retainer.

Clinician Conduct

I will treat you with respect.

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Decision to terminate services is usually a collaborative decision based on readiness. In my professional experience, tapering down toward the end of therapy is a wise practice and helps you transition toward greater independence. I am a big believer in the viewpoint once a client, always a client, and even if we decide that you no longer need therapy at this time, you are welcome to resume therapy with me at a later date.

In the event that therapy with me does not seem to be helping you, I may recommend referral to another clinician who can better suit your needs. This recommendation will terminate your services with me. I will do my best to make it a smooth transition for you from my services to services with your next clinician.

You have the right to terminate services at any time, though you are still financially responsible for services you have received, and for any scheduled services you do not cancel with at least 48 hours notice.

Other reasons for termination include inappropriate behavior, repeated no-shows or repeated last-minute cancellations, failure to remit payment including chargebacks, and permanent move to another state (see travel policy).

• In the case of inappropriate behavior (i.e. nudity, lack of respect for professional boundaries, threatening therapist safety), termination will be immediate and there will be no refund. I will send an email confirming the reason for termination. In the event of a threat to my safety, I will involve the appropriate authorities (please see conduct policy).

• If you fail to show up for an appointment, I will reach out twice via text and email with an attempt to reschedule. If you do not respond to these two attempts at contact, I will close your chart and send you an email that I have done so.

• Last minute cancellations and no shows may lead to termination if they become habitual. In the case of repeated no-shows or repeated last-minute cancellations, you will be notified of intent to terminate and given the opportunity to close out services in a final, prepaid session.

• A chargeback is when you receive a service and reverse the charge on your original payment method (e.g. credit card). This is a fraudulent practice and will be treated as such and reported to the appropriate authorities. Chargebacks are a violation of your informed consent agreement.

• If you move out of the state in which I am licensed, I will be happy to coordinate the smooth transfer of care with your new therapist in your new location, with your written permission.

Termination of services terminates your access to your private therapy and training website, the and the HIPAA-compliant texting app. You will be able to reach me with questions via the forms on my contact page.

I am currently licensed in the state of Florida only. By law, any client for whom I provide mental health counseling services must be located in the state of Florida at the time of service, regardless of whether that service takes place in person or online.

This means that if you are an existing client and you go on vacation outside of Florida, your services with me will not be available during that time, and any advance payments you have made will apply to future sessions. It is best if you let me know in advance when you are going to be out of state so we can find you services at that location, should you want them, and so I can suspend payments for the time that you will be out of state.

If you are a Florida resident but currently working, traveling, or vacationing out of the state, I cannot provide counseling services for you until you return to Florida. If you reside in another state and would like me to look into licensure in your state, please complete this form.

If you are an out-of-state resident but are physically located in Florida, I can offer counseling services for you while you are in the state.

If you are traveling to another state or will be moving to another state, I can look into applying for licensure in that state; however, I cannot guarantee the license will be granted. It is up to the state boards to grant licenses to practice, and this process does take time. If you anticipate the need to request that I pursue licensure in another state to accommodate your move or travel, please keep in mind that this process takes time, and let me know as far in advance as possible to increase the likelihood that I can meet your needs. If you will be travelling or moving to another state and would like me to look into licensure in that state, please complete this form.

I follow the codes of ethics of the American Mental Health Counselors Association (AMHCA), the American Counseling Association (ACA) and the National Board for Certified Counselors (NBCC).

When I do not think my practice is the right fit for you, or if I do not have space in my schedule, I refer out to several colleagues I have either worked with directly or have studied under. These are clinicians I trust and they are located in Palm Beach County, Florida. They will let you know if they are currently working in-person, online, or both.

If you are not local to my area, I will reach out to my professional network and provide the names of three clinicians who might be right for you in your area. Please understand that I may not have worked with these clinicians and that you will be responsible for determining if they can meet your needs. Finding clinicians with particular specialties may take time.

If you are in immediate need and cannot take the time to go through the screening and intake process that is standard for mental health counseling, I suggest contacting a service that is more crisis-based. Call 911 for emergencies, 211 (from most states) for referrals to local services, NAMI for mental health resources and referrals, and SAMHSA for substance-use related referrals.

This is a private practice, not an integrated treatment program. I am happy to confer with family, significant others, other professionals you see to coordinate your care, with your permission, but integrated care is outside the scope of my practice.

Marketers and outreach professionals, please note that while I appreciate your emails to let me know of the services you represent, I will not include them on my website if I have had no direct experience with them and I will not respond to requests for backlinks. If you would like to introduce yourself and your organization, please fill out the appropriate form on this page.

Because I am transparent about being a person in long term recovery, I have encountered clients who ask if they can contact me for social recovery support after they leave treatment. The answer is no. There are two camps on this issue. One camp believes that once a certain amount of time has passed, it is acceptable to have a personal relationship with a client - to be a friend, a recovery sponsor or support, a coworker, a boss, a romantic or intimate partner, etcetera. The other camp believes once someone is a client, they are always a client. I am of the once-a-client-always-a-client camp. Once you are a client, our interactions will always be that of therapist and client.

The notion of privacy on social media is a myth. Social media sites have very poor security and zero confidentiality. Please do not make contact with me using any social media messaging systems such as Facebook Messenger, Instagram Direct Message, or Twitter Messaging. I do not watch social media apps for important messages from clients, and responding to you there will compromise your privacy.

Please refrain from creating reviews of clinical services online. Online reviews are visible to the public and would therefore would put your confidentiality at risk.

In the interests of client privacy, it is not ethical for me to solicit or post reviews from clients, though you may see comments or reviews from colleagues. If you are a client and you follow my business pages on social media, I caution you that it can compromise your privacy to follow or "like" those pages, and it will jeopardize your confidentiality to leave comments or reviews on those pages. They are public forums. To protect your privacy, I do not respond to reviews or comments about my services on my public pages. Those pages are provided for information purposes and not for interaction.

If you wish to let me know how you feel about your experience with my services, please feel free to send feedback on this HIPAA-compliant feedback form. Please do not message me on social media. Social media messaging is not secure and will expose your personal health information to data mining. Please understand that to protect your safety and security, I cannot respond to any counseling-related private messages on social media. If I receive inquiries there, I will direct you to my website where you will find HIPAA-compliant forms for contacting me.

To prevent harm, I do not accept friends or former friends as counseling clients. There can be some confusion about what constitutes a "friend" on social media. Distinguishing between personal social media accounts and public business accounts sets clear boundaries and averts misunderstandings. Facebook provides a good example of this difference. A Facebook profile is personal. A Facebook page, however, is always visible to the public and its purpose is to conduct business. Most social media platforms allow users to create personal or business accounts.

My business presence on social media consists of business pages on Facebook, Twitter, Instagram, Pinterest, and LinkedIn. You are most welcome to follow me on my business accounts for inspiration and motivation, though if you are a client, I will not follow you back. Understand, however, that because social media business pages are public, you instantly abdicate your confidentiality by following them or interacting on posts (likes, comments, shares). In recognition of this risk, I do not interact personally or clinically on those platforms, though I may respond to comments in a general sense.

If you follow me on a public page, you are not considered a "friend" because these are business accounts. But if we are "friends" on my personal Facebook profile and you inquire about counseling, I will have to refer you to another clinician. To maintain boundaries between personal and professional relationships, I do not accept social media friend requests from current, past, or potential clients. This is not a rejection; it is an ethical boundary, and it is for your protection.

Another environment that is not traditionally referred to as social media, but which I believe falls into this category, is virtual recovery meetings. They are social, the use of media makes them possible, and they are decidedly personal in nature. As a clinician, I do not engage in personal relationships or activities with clients. This means I do not attend recovery meetings with clients. As I've said in my professional boundaries policy further up on this web page, once you are a client, our interactions will always be that of therapist and client. If I log in to a recovery meeting and see you there, I will leave immediately, just as I would leave an in-person meeting.

I will do my best to help you if you experience technical difficulties with the platforms I use. If your questions are outside the scope of my skills or access, it may be necessary for me to direct you to the technical support teams of the specific products you're having trouble with. Please keep in mind that many problems can be solved with patience and a few basic troubleshooting steps. To save you from wasting your counseling time and financial investment on technical support, please try these troubleshooting steps before reaching out:

1. Update. Most of the time, software doesn't work properly because it's not up-to-date. It's similar to your car not functioning properly if the maintenance is not kept up-to-date. Check that your operating system and browsers are up-to-date. Check that your software applications are up-to-date, especially those we use for your video sessions.

2. Enable cookies and popups.

3. Clear cookies and browser history, or perform a disk cleanup.

4. Enable microphone and camera access for conferencing programs.

5. Use a different browser.

6. When all else fails, restart your computer. You'd be amazed at how often this fixes whatever technical issue you're facing.

7. On a mobile device, enable automatic updates, restart your device once a day, and clear the cache of apps you use regularly every single day.

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Clients are legally entitled to copies of their records. If you would like to request your counseling records, you will need to do so in writing and complete an authorization/release of information form. The form will ask to whom the records are being released and for what purpose. I require written authorization whether you are requesting the records for yourself or a third party. To initiate this process, please send a secure text or email requesting the authorization form. I will send you the form within 24 hours. Once I have received your authorization form, I will do my best to get those records out to you within the week, depending on the page count you have requested, and whether you need additional reports or summaries. Please note that HIPAA law gives me up to 30 days to comply with a records request.

I recommend digital transmission of records via HIPAA-compliant technology. Digital transmission saves time and cost. To send records digitally, my practice uses one of several methods: HIPAA-compliant fax, HIPAA-compliant email, or sharing a Google Drive file with the client. Faxing your protected health information can be secure if both endpoints are HIPAA-compliant and the fax is sent by a HIPAA-secure program that encrypts data in transit. I recommend we limit faxing to recipients who have a HIPAA-secure fax machine or fax program on their end.

Fees for records include creation or conversion of the files into the format to be sent, and preparation of an explanation or summary if requested. Labor for creation or conversion of files is billed at $1 per page. Labor for writing summaries is billed at the clinician’s current posted hourly rate. If paper copies, CDs, or other physical media are requested, there will be additional fees for associated supplies and postage.

Clients are also entitled to copies of policies to which they have agreed. Many policy documents are available on this website for viewing (e.g. Notice of Privacy Practices, Technology and Security Policies and Procedures). All policies and procedures are subject to revision and update. The most recent updates supersede previous versions; policies publicly posted to this website may be considered the most recent updates.

Copies of treatment plans and any signed documents will be made available to clients for viewing via a HIPAA-secure Google Drive folder throughout their treatment at no cost.

If clients choose to download documents containing personal health information, or save these documents to their personal Google Drive, they then assume responsibility for the safety and security of those documents. Please note that personal computers typically are not HIPAA-secure, nor are personal Google Drives (the Drive this practice uses is HIPAA-secure). If you download your records for the purpose of printing them out, I strongly suggest you delete them from your device and clear your recycle bin/trash immediately afterward. Please note that printing via Wi-Fi on a public Wi-Fi network will compromise the safety of your healthcare documents.

This practice has no control over client records once they are transmitted to clients or third parties, including other healthcare providers. If your records are released to you, you will assume responsibility and liability for their safety once you receive them. If you request to have your records sent to a third party, that party assumes responsibility and liability for the safety of your records once they are received. This practice has no way of confirming whether a fax service 0r email service is HIPAA-compliant on the receiving end, so it is a good idea for clients to check into this prior to requesting transmission of records. Note that while I can ask, and you can ask, it is always possible that a third party will say their end is HIPAA-compliant even if it is not. This may be because they are not aware of the intricacies of what constitutes HIPAA-compliant. A program can be HIPAA-compliant and be used in non-compliant ways.

Records will be maintained in HIPAA-compliant cloud storage for seven years. In the event of your clinician's death, retirement, or incapacity, your records will be accesses by a records custodian who will contact you in the event of that your clinician is no longer able to manage your records. This records custodian is either a covered entity and/or business associate and will be responsible for responding to any request of records you may have, and for safely destroying your records after the legal time frames for storing them have been satisfied. They will also contact you at the time of transfer of records, should you authorize transfer. If you are a current client, the same records custodian will assist in providing appropriate referrals for further treatment in the event that I am unable to do so.

As part of your counseling service packages, you will receive supplemental resource handouts and workbooks. Where indicated, counseling clients may download copies for personal use. Downloading, distributing, and altering these materials in any way is a copyright violation that can result in litigation and fines. These are copyrighted materials for your use only and cannot be shared, distributed, altered, or used for any other purpose on penalty of legal or financial repercussions. Please keep in mind that if you download materials that contain personal information, you take responsibility for the safety and security of that information. I recommend that you complete workbooks and therapeutic exercises within the HIPAA-compliant platform I provide to protect your safety and security. Should you choose to download them, please keep them in cloud storage that is password-protected and requires two-factor authentication for access.

Please note that access to your learning materials and therapy and training website is intended for you only. These materials are proprietary intellectual property and are subject to U.S. and International Copyright Law. Counseling materials are intended for the personal use of clients of Michelle Robin Gould, LMHC, NCC, BC-TMH and/or the Michelle Robin Gould Corporation. Payment for counseling service packages does not entitle or grant clients licensing rights to intellectual property. Counseling and learning materials may not be further retained or further disseminated without express written permission.

Materials created by other entities and supplied to counseling clients by Michelle Robin Gould, LMHC, NCC, BC-TMH or Michelle Robin Gould Corporation in the course of therapy have been purchased by or licensed to Michelle Robin Gould for use with clients. Clients may use these materials for personal use only and may not share, distribute, alter, or use these materials for any other purpose on penalty of legal or financial repercussions.

Requests for letters confirming the need for emotional support animals (ESA) will be decided on an individual basis and will be determined based on therapeutic history and current state of mind. They will not be provided without a thorough evaluation.

What are Emotional Support Animals (ESAs)?

“Emotional support animals (ESAs) are animals that provide emotional support and comfort for individuals with disabilities, thus enabling those individuals to function in daily activities. They are not service animals (animals that are trained to perform certain tasks to help individuals with disabilities engage in activities of daily living)" (Norton, 2018). Unlike service animals, the only situation in which federal law requires others to allow you to have your ESA with you is for housing. Certain types of animals are excluded; this issue is beyond the scope of the mental health counselor and is between the person with the ESA and the person who represents the dwelling in which they live.

ESAs are not longer covered under the ACAA (Air Carrier and Access Act), and ESAs are not covered under the ADA (Americans with Disabilities Act).

It is beyond the scope of a mental health counselor to assess the animal's training, but it is within our purview to request documentation of that training when evaluating clients for ESA letters.

What You Need to Know

To obtain an ESA (emotional support animal) letter, which documents the need for an emotional support animal (ESA), you need to be under a clinician’s care. I do not write ESA letters for clients I am seeing for the first time. Your first therapy appointment is the start of treatment and consists of an initial evaluation for therapy. An ESA evaluation is a different kind of evaluation. If I have no prior therapeutic relationship with you, it is not ethical for me to provide you with ESA documentation. It may take longer than one appointment for your diagnosis/diagnoses to be clear. Assessments measures will be required to determine need, and this takes time. If I have not been seeing you for therapy for at least three months, I will not consider writing an ESA letter for you.

The ESA evaluation time is separate from your initial treatment evaluation. An ESA evaluation may take two to four hours, not including administration of psychological assessments, which may take another two hours. Additional time is needed for collection and review of records (e.g., medical records, school records, public records, work-related records, etc.), along with collateral interviews (i.e. family members, partners, employers, therapists/counselors, teachers, etc. who may have helpful information about your difficulties with functioning).

The cost of the ESA evaluation is $1050, which includes the clinical interview, administration and interpretation of some psychological tests (exception: disability assessment), collateral interviews, review of relevant records, and writing a letter documenting the need for the ESA (if deemed appropriate). There will be no refund if I conclude that the legal, clinical, and ethical requirements for writing an ESA letter have not been met. Please note that ESA letters for airlines automatically expire after one year.

To obtain an ESA letter, you must have a mental or emotional disability that matches the criteria outlined in the DSM5 (Diagnostic and Statistical Manual of Mental Disorders). Having a mental or emotional disability may be different from having a mental health diagnosis. Disorders and disabilities are not synonymous. A diagnosis of disability must be based on a clinician's evaluation; a client's claim of disability is not sufficient for provision of an ESA letter. A determination of disability will need to be conducted before an ESA letter can be considered. If you have a prior diagnosis of disability, you may ask your previous clinician to provide me with documentation of your diagnosis and symptoms. It will be necessary for me to assess the current presence of those symptoms as a component of the ESA evaluation. A disability assessment requires additional psychological tests and associated costs. If a disability assessment is needed, I will provide you with an oral and written good faith estimate of the cost of such tests.

Need must be established (as opposed to want). It must be clear how the ESA contributes to managing your disability-related impairment. Your reasons for requesting an ESA letter must be related to the animal’s role in managing your disability. If you are requesting the letter simply because you want to circumvent a landlord or housing complex’s no pet policy, or because it is inconvenient or expensive to board your pet when you travel and you want to take your pet with you, it is not ethical for me to provide the requested documentation.

Should I provide an ESA letter, there may be time restrictions or other limitations as dictated by your case.

Consent and Understanding

If you decide to request an ESA letter evaluation with the Michelle Robin Gould Corporation, you will be asked to sign an informed consent agreement and financial responsibility contract before starting the evaluation process.

Each of the above policies and procedures is available to current clients in individualized HIPAA-secure Google Drive folders that limits access to each client. As a client, you will have permission to view and download them. Please note that if you download these documents, you are responsible for the safety and security of any documents you download. Please remember that these documents are copyrighted material for your personal use only and cannot be shared or distributed (please see the copyright policy on this web page for details).

If you are viewing documents in Google Drive on your mobile device, they are best displayed when you select print layout. To turn on print layout, click the three dots on the top right and select print layout from the dropdown menu.

If you are using your device’s default PDF reader, you may find that edges are cut off and text and images are in the wrong places. Please download Adobe Acrobat here so you can read these materials clearly. This is the free version of Adobe Acrobat and it is available for desktop and mobile devices.

Policies and procedures are subject to revision and updated regularly. All downloads indicate the most recent date they were updated. The most recent updates supersede previous versions. Website content is updated along with downloadable content.

If you are a current client and you would prefer to have a copy of your signed documents mailed to you by USPS instead of or in addition to digital transmission, please let me know. Associated document preparation and postal charges will apply (please see the records request policy on this web page for details).

If you are a current client who has already completed the intake process and/or met with me via teleconferencing, and you have a grievance, please give me the opportunity to rectify the situation. You may notify me of a grievance via the HIPAA-secure, encrypted email address you were given at the start of therapy.

If you were a potential client and you were not happy with the contact and/or screening process, please contact me via this form and give me an opportunity to address your concerns.

If you feel there has been a health information privacy or security violation, you have the right to file a complaint with the U. S. Department of Health and Human Services. Please see here for complaint requirements and processes. These complaints have serious ramifications. I take extensive precautions to protect your privacy and security. To make sure there has not been a misunderstanding, please consider speaking to me about your concerns prior to filing a complaint. I will do everything I can do resolve the issue.

General Copyright Policy

Please note that all materials on this website are the copyrighted intellectual property of Michelle Robin Gould. These materials may not be shared, distributed, altered, or used for any other purpose on penalty of legal or financial repercussions. These materials are proprietary and are subject to U.S. and International Copyright Law.

Copyright Policy Regarding Client Materials

Payment for counseling service packages does not entitle or grant clients licensing rights to intellectual property. Please note that access to your learning materials and therapy and training website is intended only for the personal use of clients of Michelle Robin Gould, LMHC, NCC, BC-TMH and/or the Michelle Robin Gould Corporation. Counseling and learning materials may not be further retained or further disseminated without express written permission.

Materials created by other entities and supplied to counseling clients by Michelle Robin Gould, LMHC, NCC, BC-TMH or Michelle Robin Gould Corporation in the course of therapy have been purchased by or licensed to Michelle Robin Gould for use with clients. Clients may use these materials for personal use only and may not share, distribute, alter, or use these materials for any other purpose on penalty of legal or financial repercussions.