As a Grow Therapy provider, a client may come to you looking for you to complete care-related letters and documentation, such as a Leave of Absence (LOA), Family and Medical Leave Act (FMLA), Emotional Support Animal (ESA), or disability forms. These services are not currently billable on Grow Therapy; therefore, we encourage you to consider the options below.
Before you begin
How can I determine if I should complete a care-related letter or documentation for a client?
Due to varying state requirements and the complexity of documentation, we suggest handling each request on a case-by-case basis. Ask yourself the following questions before agreeing to complete the letter or documentation:
How long have I been seeing the client?
Do their diagnosis and symptoms warrant supporting the request?
How will I bill for my time?
(When applicable) Does their insurance allow me to bill the time spent reviewing the request/paperwork with the client?
Is this request better suited for the client’s PCP or specialist?
Do I have a peer or support group I can reach out to if I have questions about this form?
Common letters and forms
Letter and documentation requests add a layer of complexity due to varying state regulations and occasionally, payor requirements. Some states regulate which licenses and what types of providers can complete care-related requests.
Disability paperwork
Because most state disability programs limit certification to medical professionals, providers should understand when they may complete disability forms and when a client must be referred to an appropriate certifying clinician.
Can a therapist complete this paperwork or documentation?
In many states, mental health therapists (e.g., LCSWs, LMHCs) are not authorized to certify most disability claims.
Emotional Support Animal (ESA) letters
An ESA is an animal of a traditional species that is not trained to perform a specific task but, through companionship, alleviates a person’s psychiatric disability. ESA criteria is regulated by the FHA, ACAA, state, and local laws. Review the applicable laws to support ethical practice and use. It is at your discretion whether you fill out an ESA letter. Consult with colleagues if you need more assistance.
Can a therapist complete this paperwork or documentation?
Yes, with some states, like California, having stricter guidelines. It is best practice to review any applicable state or local laws when providing ESA documentation.
Considerations when writing an ESA letter
Determine if a client has a chronic impairment as outlined in the DSM-5.
Determine whether the ESA will alleviate these impairments.
Assess the client's practical and mental abilities to care for the animal.
Write letters only in the states where you are licensed.
You do not need to include a diagnosis or provide excessive details.
Family and Medical Leave Act (FMLA)
FMLA gives eligible employees the right to take unpaid leave for approved medical or family reasons. Their job and health insurance remain protected, and their benefits continue just as they would if they were still at work. Not every employed client qualifies for FMLA. Review the criteria from the Department of Labor to determine if FMLA is an option for clients.
Considerations when completing FMLA paperwork
Does my client qualify for FMLA?
What type of FMLA is my client requesting?
Do I have enough clinical information to support an FMLA request?
Can I complete the requested FMLA documentation?
Would this client be better served if their PCP filled out the paperwork?
Do I have any time constraints that would prevent me from completing FMLA paperwork and responding to any follow-up questions from the organization requesting documentation?
Additional considerations for FMLA
Although the FMLA itself is unpaid, some employers or states offer paid leave benefits, such as salary continuation or short-term disability, that run concurrently with FMLA. In these cases, job protection is provided by the FMLA, while pay is covered by the employer’s internal leave policies or state programs, and may vary by state and employer.
Clients are responsible for understanding the benefits they have and whether they can be used concurrently with FMLA.
Deadlines
The FMLA process may be managed by a third-party administrator on behalf of the employer. They will have specific dates by which the provider certifying FMLA leave must submit the required information. Continued leave may require additional follow-up and documentation submitted by the provider to the third party. Failure to follow the timelines may result in the denial of FMLA leave. It is essential to be aware of the deadlines for submitting FMLA paperwork.
Additional resources
FMLA Frequently Asked Questions from the Department of Labor
Frequently Asked Questions (FAQs)
My client requested a letter (LOA, FMLA, ESA, etc.). Can I bill for that through Grow?
No. Grow Therapy providers are currently unable to bill for these services on the platform.
Can a therapist complete FMLA paperwork?
Under the federal FMLA, therapists are allowed to certify leave for mental health conditions as long as:
They are licensed, and
The condition falls within their scope of practice.
Am I required to fill out letters for my client?
No, you have the discretion to decide whether to provide letters or complete FMLA paperwork. Referring clients to their PCP is an alternative option.
Can I charge separate cash fees for letter writing?
Yes. Charging separate cash fees for letting writing is permitted except for individuals covered by Medicaid or Kaiser NorCal. Providers should include fees for letter writing and disclose them at the time treatment is initiated. Providers are required to identify a system for collecting any fees associated with letter writing outside the Grow Therapy platform.
Providers are encouraged to consult with compliance or legal representation outside of Grow Therapy before establishing a fee system.
What type of letterhead should I use for these requests?
Use your own practice letterhead, as Grow Therapy does not provide letterhead for any documentation requests.
Do clients with specific benefits prevent me from charging for this paperwork?
Charging separate cash fees for letter writing is allowed except for individuals covered by Medicaid or Kaiser NorCal.
How do I release a client’s records if requested for FMLA?
To release a client’s Grow Therapy records, your client will need to complete a Release of Information (ROI) form. Using your provider portal, send a message via the Help Widget. Type “ROI form” and hit send. You should receive the option to download a blank form for your client to complete. The client can then send the completed form to records@growtherapy.com.