Under PHIA legislation, when the psychologist is an employee, the custodian is either the person responsible for running the group practice or the employer, and not the employee. Normally the consent form for service is signed on the practice’s consent form as well. Therefore, your plan to have a signed form authorizing transfer of files sounds appropriate, provided you discuss this approach with the custodian. Some practices/organizations have put in written policies and practices around clients and their records in the event that a psychologist leaves the practice.
In any event, it is always helpful for the associate to discuss their transition with the existing practice to ensure a smooth transition. And, if clients are following the associate to their new practice, it’s important to have a signed consent form authorizing any files that are being transferred or copied to the practice of the associate.
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