Impaired Provider Policy

Updated
Policy Name:   Impaired Provider Policy
Effective Date: 02/24/2025
Review/Approval Date: 02/24/2025
Revision Date: 07/30/2025; 08/20/2026; 08/31/2026
Approved By:  Medical Director

Purpose:  

To ensure the safety, well-being, and quality of care provided to patients by establishing clear expectations and procedures for identifying, reporting, and addressing situations where a contracted provider may be impaired.

Applicability:  

Therapymatch, Inc., d/b/a as Headway, and its affiliates and subsidiaries (collectively, "Headway," "we," "us," or "our") and all of its associated Professional Corporations (PCs), including but not limited to all current and future PCs.

Definitions:

  • Impairment — Any condition, temporary or chronic, that compromises a provider's ability to deliver care safely, effectively, and in accordance with professional and ethical standards. This includes: (a) substance use or intoxication, including alcohol, prescription medications, or illicit substances that alter judgment or coordination; (b) mental health challenges that impair the ability to maintain professional boundaries or make sound clinical decisions; and (c) physical conditions, including temporary impairments from surgery, injury, or illness, that limit appropriate performance of duties.

Policy:

Headway is committed to delivering quality mental health care and expects all providers to deliver services with full capacity to make sound clinical judgments and uphold ethical responsibilities and standards. Providers must not provide care or attempt to engage with clients if their capacity to do so is impaired. Each provider holds the primary responsibility to recognize and address any conditions that may lead to impairment. Prompt self-disclosure and seeking appropriate support are essential to ensuring the safety and well-being of clients and maintaining the integrity of quality care.

Procedures:

  1. Reporting Impairment
    1. Any staff member or contracted provider who observes or suspects impairment in a provider must report concerns immediately to Headway.
    2. Clients are encouraged to report concerns of provider impairment to Headway whenever possible.
    3. All reports may be submitted via https://care.headway.co/contact.
    4. Reports must include detailed observations to substantiate the concern.
  2. Assessment
    1. Upon receipt of a report, Headway will conduct a thorough review, which may include:
      1. Speaking with the provider in question.
      2. Reviewing additional information submitted as part of the reported concern.
  3. Corrective Actions
    1. Based on review findings, a provider may be immediately removed from Headway's platform.
    2. In the case of removal, Headway will notify the provider's patients and offer support in rematching to ensure continuity of care.
    3. Depending on the nature of findings, Headway will determine whether a report to the provider's licensing board is warranted.
  4. Continuation of Care
    1. Providers are responsible for providing continuity of care and facilitating appropriate referrals for patients if their contractual relationship with Headway ends.

References:

Disclaimer: This document is for educational purposes only and is not intended as professional or legal advice. It may contain errors or missing information, and recent changes in policies, regulations, or payer requirements may not be reflected. Because requirements vary by organization and jurisdiction, please consult legal counsel, the appropriate regulatory or licensing authority or your designated Headway contact for guidance specific to your situation.

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