Counseling Center Procedures

College of Eastern Idaho Counseling Center Confidentiality Procedure

CEICC Procedure #1 • Updated 02/21/2025

1.0 Overview

Counseling services provided by College of Eastern Idaho are confidential and follow the legal and ethical standards (including specific legislation covered under FERPA) established for licensed counselors, social workers, and marriage and family therapists. It is a privilege to be entrusted with the personal information and experiences of our students, and it is essential that this information remains closely guarded. This applies to both within the campus community as well as without. We strive to cultivate an environment of complete confidentiality for our students (aside from the exceptions outlined below in sections 1.7, 1.8, and 1.9).

1.1 Federal Law

The College of Eastern Idaho Counseling Center (CEICC) operates under FERPA, which governs educational records, including those maintained by campus counseling centers. CEICC is not covered under HIPAA because it is not part of a health clinic, does not bill insurance, and does not engage in electronic health care transactions of any kind. However, counseling records are afforded a higher level of confidentiality within FERPA guidelines, closely resembling HIPAA protections, because they contain sensitive mental health information. Unlike general FERPA-covered records, which may be accessed by school officials with a legitimate educational interest, counseling records are only disclosed with written client consent or under legally mandated exceptions, ensuring the integrity of confidential mental health care. While CEICC is technically covered under the protections of FERPA, these protections do bear a close resemblance to HIPPA standards.

1.2 Storage of confidential data

All therapy notes, assessments, diagnostic information, and other confidential data is stored in Titanium Schedule, a secure data management system. Only CEICC employees have access to Titanium, and no incoming or outgoing data is exchanged between Titanium and any other CEI data management applications. Administrative staff are only able to view limited information within student files, information which is limited to scheduling and other relevant tasks.

Counselors are only able to view the complete file of students that are assigned specifically to them, and the Counseling Director is the only staff member who has access to all data held within Titanium. As is best practice, files and the information contained within are only reviewed when necessary or helpful to the individual.

1.3 Consultations with faculty and staff

The Counseling Director is available for consultations with faculty and staff regarding student behavior. However, no information regarding student counseling data can be provided to any individual unless the student has provided a signed release authorizing disclosure. CEICC is also unable to provide verbal or written verification of student participation in therapy services.

1.4 Faculty/staff requests for student counseling data

Any requests from faculty or staff for information regarding student counseling data will be denied and the requesting individual will be referred to this procedure. Disclosure of student counseling data without a signed release violates ethical guidelines, leaves the clinician and college open to potential lawsuits, and endangers the clinician’s license.

1.5 Student requests for their own records

Students have the right to request their own records at any time. All requests for records by the individual will be fulfilled in a maximum of two weeks. This time frame does not include leave, paid time off, or when the student’s clinician is otherwise out of the office and unavailable.

To ensure accuracy and clinical integrity, the student’s treating clinician must review their own records before release. This allows the clinician to clarify notes, address any potential concerns, and provide appropriate context if needed. If the clinician is unavailable or no longer employed by the college, the Counseling Director will conduct this review before the records are provided.

A fully licensed clinician employed by the college that has been approved by the Counseling Director may also fulfill these requests. This approval is given on a case by case basis, not continuous or overarching.

There are two approved methods of releasing records: in person and fax. Records released directly to a student in person do not legally require a signed release form, however CEICC does require a release be signed as a record and to follow best practices.

Records sent via fax require a signed release form by the student authorizing this action. Students may have another individual pick up their records for them, and this action also requires a signed release form on the part of the student. The authorized individual must present government issued identification to Counseling Center staff to receive the requested records.

Email, mail carrier services, or other means of communication are not secure mediums to share information, and student records may not be shared through these methods.

1.6 External requests for data

Occasionally, records/information requests are submitted by third parties such as medical providers, parents, potential employers, court advocates, etc. Information can only be shared with a signed release from the student. CEICC cannot verify knowledge of the student prior to receipt of a signed Release of Information.

Fax, in-person handoff, and a secure third-party online portal are the approved methods for releasing any information to a third party when applicable. CEICC does not maintain its own portal, but may use a secure third-party portal when provided by the requesting entity.

1.7 Responding to Subpoenas and Court Orders

The following steps must be followed upon receipt of a subpoena or a Court Order:

1. Verification: Upon receiving a subpoena, staff must immediately notify the Counseling Center Director and consult the college’s legal counsel to determine its validity and scope.
2. Determine the Type of Subpoena: Subpoenas can be issued either by an attorney (which may allow for objections) or by a judge (which typically requires compliance).
3. Client Notification: If possible, the student should be informed of the subpoena and given an opportunity to provide written consent for record release.
4. Legal Review: No records shall be released without review from legal counsel. If a subpoena is issued by an attorney, CEICC may file an objection or request a protective order to maintain confidentiality. If it is a court order signed by a judge, compliance is generally required.
5. Court Orders: If a court order requires disclosure, only the minimum necessary information will be provided, per state and federal confidentiality laws.
6. Documentation: All steps taken in response to the subpoena must be documented, including legal guidance received, client communication, and records disclosed (if applicable).

No staff member should independently respond to a subpoena without following this procedure to ensure legal and ethical compliance.

1.8 Risk of harm to self

The presence of suicidal risk is viewed with the utmost seriousness, and appropriate and swift action is taken in all situations. The vast majority of situations can be de-escalated by completing a safety plan, and through completing a risk assessment to gather further data regarding the student’s mental state, followed by implementation of appropriate safeguards. Isolated suicidal thoughts without the presence of any other safety concerns do not require additional action such as notification of law enforcement. Multiple concerns must be present before further action can legally or ethically occur.

However, if a student demonstrates to a clinician employed with CEICC that ALL of the following circumstances are present: suicidal ideation (thoughts), intent (a desire to end their life), a plan, access to means (weapons, medication, etc.), an unwillingness to make their environment safe, refusal to develop safety plan with clinician assistance, and refusal to be voluntarily admitted to a behavioral health facility (such as BHC or BHCC); law enforcement and Campus Safety will be notified. This action is a last resort only, will begin with a welfare check for the student of concern, and may result in involuntary commitment to BHC depending on the officer’s assessment of the situation.

In some cases, law enforcement may also be contacted to facilitate transportation to a behavioral health facility, even if the student is willing, to ensure safety during the process. This decision will be made based on clinical judgment, the student’s current risk level, and other logistical considerations.

A representative from the office of the Dean of Student Affairs will be notified if the situation escalates to the point where the police are alerted. Further disclosure of this information requires approval by both the Counseling Director and a representative from the Dean’s office, but in the absence of additional extenuating circumstances, no additional individuals will be notified of the situation without a release of information signed by the student.

1.9 Risk of harm to others

A specific and intentional threat of bodily harm to a CEI student or employee that is directly disclosed to the counselor by the client is a legally and ethically sound exception to the procedure of complete confidentiality. In that case, the individual whom the threat has been made against will be notified, as well as the police, Campus Safety, a representative from the Dean’s office, and any other individuals who are deemed necessary to notify at the discretion of the Counseling Director and the representative from the Dean’s office. This information will be limited to the threat, and if necessary, additional relevant data.

1.10 Faculty and Staff awareness of student suicide risk and other safety concerns relating to mental health

Concerns of suicide risk or other mental health concerns relating to a specific student at times occur in the campus community, outside of CEICC. In this instance, it is strongly recommended for the concerned faculty or staff member to report any concerns directly to Campus Safety well as via the “report a concern” tool on the CEI website. The Dean’s office will review and address these concerns, possibly with assistance from members of the CARE team.

CEICC staff cannot provide direct outreach to students in response to 3^rd party concerns. For additional information, please refer to procedure # 7, Ethical Guidelines for Student Outreach.

1.11 Clarification and pressure to violate ethical and legal standards

CEI employees have the ability to clarify any portion of this procedure with the Counseling Director. However, additional attempts (that do not contain clarifying questions) to pressure any Counseling Center employee to violate FERPA or ethical standards, are subject to a complaint filed directly with Administration or the Human Resources office.

College of Eastern Idaho Counseling Center Provision of Services Procedure

CEICC Procedure #2 • Updated 02/26/2025

2.0 Overview

All services provided through the College of Eastern Idaho Counseling Center (CEICC) are free and available to students who meet the required eligibility criteria. This procedure outlines the standards and limitations of the mental health services provided through CEICC.

2.1 Eligibility for Services

Who is eligible for services through CEICC? Students who are enrolled in at least one credit hour at CEI during the current semester or block are eligible to receive services through the Counseling Center.

Individuals enrolled in Workforce Training and Continuing Education (WTCE) courses or College and Career Readiness (CCR) courses are not eligible for services. We are unable to verify enrollment for these courses, and the variable length of these courses (some as short as one day) creates a barrier to providing ethical and evidence-based treatment.

Summer Semester: Students enrolled in the upcoming Fall Semester of the same year are eligible to request and receive services over the summer, even if they are not enrolled in a summer course. These services are available throughout the summer season and are not restricted to the official summer semester dates.

2.2 Availability of Services

In most cases, students can obtain services within the same week they request them. However, students with limited availability may experience a longer wait time. Counseling services are available in person or via Zoom. Walk-in appointments are accepted when counselor availability and daily caseloads allow. High demand for services and potential waitlists may impact availability.

Hours of Operation:

Fall/Spring Semester: Monday–Friday, 8:00 AM – 5:00 PM

Summer: Monday–Friday, 7:30 AM – 4:00 PM

Due to the small size of our department, there may be occasional closures or limited availability when staff are out due to illness, time off, or responsibilities in other areas of the college. While we make every effort to remain open and available to students, there may be times when same-week or walk-in appointments are not possible. We appreciate students’ understanding, and encourage scheduling appointments in advance whenever possible to ensure consistency and availability.

2.3 Short-Term Definition

Previously, a session limit was in place to maintain the integrity of the short-term services offered by CEICC. However, research has demonstrated that session limits do not significantly affect utilization and can even be counterproductive.

To ensure students receive the appropriate level of care based on their individual needs, there is not a limit on the number of sessions a student may receive. This approach allows for greater flexibility in treatment planning, reduces barriers to care, and aligns with best practices in collegiate mental health. By focusing on clinical necessity rather than predetermined limits, we can better support student well-being and retention.

The definition of short-term counseling remains flexible and is determined by multiple factors, including:

• The student's individual needs
• Progress in therapy
• Overall campus-wide demand for services

2.4 Frequency of Services

Students may receive counseling:

• Weekly
• Every other week
• Monthly
• On an as-needed basis (per student request)

CEICC is unable to accommodate appointments more than once per week. Students who require or prefer a higher level of care may request referrals to external mental health providers.

2.5 Services We Provide

CEICC provides free, individual counseling services to eligible CEI students upon request. These services are:

• Short-term
• Often solution-focused
• Always person-centered
• Eclectic in approach, tailored to fit each student

In addition to individual counseling, CEICC also offers some group therapy services and outreach events. However, individual therapy remains our primary offering.

While CEICC primarily provides individual counseling services to students, we also offer consultation services to faculty and staff. These consultations focus on supporting student well-being, as well as addressing concerns related to student mental health. Faculty and staff seeking mental health services for themselves are encouraged to utilize resources available through CEI’s Employee Assistance Program (EAP) or other external providers. Human Resources can provide additional information to employees seeking information on resources for their own mental health.

2.6 Services We Do Not Provide

CEICC is unable to provide the following services:

• Letters for emotional support animals (ESA)
• Verification of disability for accommodations
• Family or marriage counseling
• Evening or weekend sessions
• Emergency transport
• Sessions held outside of the Counseling Center/Annexed Counseling Center spaces
• Financial assistance (students needing financial support should contact the Center for New Directions or dial 2-1-1 to connect with a Navigator at Idaho Department of Health and Welfare. CEICC does not guarantee funding from these resources.)

2.7 Termination of Services

Counseling services are re-evaluated at the end of each semester, and students may request services again as needed. This periodic review helps prevent complacency or dependence, empowering students to take charge of their own treatment. When students re-engage with services, their goals are re-evaluated to ensure continued progress and alignment with their needs. This brief pause allows for reflection and encourages students to practice the skills they have developed in counseling.

Immediate Termination:
Any student who poses an imminent safety risk to campus or their counselor will be immediately terminated from counseling services and provided a referral to a community mental health provider.

Extenuating Circumstances Exception:
Students who are currently receiving counseling services and unexpectedly withdraw mid-semester may continue services for up to one month after separation from CEI. A referral for options for counseling in the community will be provided.

3.0 Overview

Occasionally, Title IX concerns arise on campus. Under Title IX, in two party disputes, both the complainant and the respondent have the right to access all services available on campus, including therapy services. This document outlines the procedure that will be followed in the event that there is a two-party dispute in which both parties are seeking counseling services.

3.1 Provision of services

Occasionally, Title IX concerns arise on campus. Under Title IX, in two party disputes, both the complainant and the respondent have the right to access all services available on campus, including therapy services. This document outlines the procedure that will be followed in the event that there is a two-party dispute in which both parties are seeking counseling services.

Efforts will be made to provide services in a timely manner, in keeping with standard Counseling Center practices.

3.2 Clinician assignment

The Counseling Director, clinicians employed with the Counseling Center, interns completing hours with the Counseling Center, and other trained professionals on campus are all options for students who fall under this procedure.

3.3 Conflict of interest

Conflicts of interest are sometimes a factor when arranging therapy services for a student. A conflict of interest in this context is defined as one of the following:

• Clinician is meeting with the opposing party if it is a two-party dispute
• Pre-existing relationship between the student and the clinician.
• Complaint filed by the student against the clinician

3.4 Interns

Dependent on various factors, interns may be utilized in Title IX cases to provide therapy. This is on a case by case basis, at the discretion of the Counseling Director, with input from the Dean of Students.

3.5 Additional trained professionals

Occasionally, licensed clinicians employed by the College in staff or faculty roles, but not presently employed in Counseling Services as Counselors, may be used on a case-by-case basis in emergency situations if authorized in advance by both the Director of Counseling Services and the Dean of Students. These professionals will be licensed by the State of Idaho and would only be used in the exceptional cases as previously stated in section 1.3.

3.6 Lawsuits

It is an unequivocal conflict of interest for a therapist employed with the college to begin meeting with a student who has indicated legal action against the college. This is to not only protect the therapist, but to also ensure the student is able to obtain unbiased and fair services

In these cases, the student will be referred out to a therapist in the community, and CEI would reimburse the agency directly for the reminder of the 12 sessions the student is qualified to receive. Payment for additional sessions beyond the 12 would be the student’s financial responsibility.

4.0 Overview

Communications and collaborations between the Director of the Counseling Center and the Dean of Student Affairs occur for various reasons, always with the purpose of the safety of CEI’s campus at and the student body at large in mind. This procedure outlines these communications and collaborations to protect all parties involved.

4.1 Provision of services

Confidentiality is a central tenant in providing ethical counseling services, and is a priority in the CEI Counseling Center. The only instance in which this can be breached are when immediate and imminent harm to self or others is indicated. In these cases, the Dean of Student Affairs will be informed of the risk. There are no other cases in which it is appropriate for the Dean of Student Affairs to request or access confidential student information.

More details on confidentiality can be found in CEI Counseling Center Procedure #1, Confidentiality.

4.2 General referrals

Just like all members of the falcon family, the Dean of Student Affairs has the option to refer current students to therapy. This aspect is not any different in this role than any other position, and can be completed either through directly walking over to the Counseling Center, showing the students how to schedule online, or providing the student with the contact information of the Counseling Center.

4.3 Conduct concerns

Occasionally, students are referred to the Counseling Center from the Dean’s Office for conduct concerns. For therapy to be mandated as part of a conduct plan, a consult must first occur with the Counseling Director to determine appropriateness of this intervention, as well as specific desired outcomes. These referrals must always be made with the intent of providing additional specific support to the student, and not as a punitive measure.

The Dean of Student Affairs will be notified by the clinician completing these therapy sessions of the status of the student’s completion of this requirement. This communication will occur one of two ways:

• either through a letter written by the clinician that the student has been seen for therapy, given directly to the student.
• an email sent by the clinician, to the Dean of Student Affairs, written and sent in the presence of the student, with the student cc’d on the email.

This communication will be included in the student’s file in Titanium by the clinician completing the session(s) for record keeping purposes.

4.4 Consult

As stated above, when the Dean of Student Affairs would like to refer a student to the Counseling Center for mandated conduct related meetings, a consult must first occur with the Counseling Director. This is to determine appropriateness of this intervention, as well as desired outcomes. This can be in the form of a phone call or an in-person meeting.

For a student to be mandated to attend conduct related sessions, both the Counseling Director and the Dean of Student Affairs must both give approval.

4.5 General discretion

Both the Counseling Director and the Dean of Student Affairs have the authority to bar students from receiving therapy services through the CEI Counseling Center.

Both the Counseling Director and the Dean of Student Affairs have the authority to bar students from receiving therapy services through the CEI Counseling Center.

In these cases, if the student is seeking services they will be provided with a list of providers in the community by either the Dean of Student Affairs or the Counseling Director.

4.6 Scope of practice

Scope of practice of the Counseling Center must to be considered when referring students for any type of services. Full details regarding the Counseling Center’s scope of practice can be found in the “Provision of Services” procedure.

5.0 Overview

The CEI Counseling Center is committed to providing accessible and free services to our students, practicing responsible allocation of the resources provided to the department, and providing a reasonable and sustainable workload for our employees.

5.1 General requirements

Consistent with other institutions of Higher Education in the State of Idaho, it is expected that full time employees will complete a median amount of 25 direct student hours per week.

Additional responsibilities will affect this number, clinicians with additional responsibilities will have adjusted caseloads. More details can be found in section 1.3.

5.2 Scheduling

Clinicians employed with the Counseling Center have the latitude to schedule their own appointments, including setting their own placeholders for online scheduling through the Titanium Web Component.

Availability for full time employees is expected to be throughout the work week, at varying times of day. Schedules and availability will be set on a case by case basis for part time employees.

It is expected that clinicians will take a lunch break each full day of work, as well as utilize allotted breaks. Reasonable time can be blocked off at the end of the work day/start of the following day to complete documentation.

5.3 Additional responsibilities

Clinicians with additional responsibilities will have adjusted caseloads. These responsibilities include (but are not limited to) leadership responsibilities, software oversight, walk-in meetings/questions, providing clinical supervision, campus committees, community partnerships, and presentations/workshops.

Caseloads will be adjusted on an individual basis, dependent on the time commitment of the specific responsibilities assigned. Caseloads are determined by the Counseling Director. Clinicians are encouraged to address any concerns with their caseload and subsequent adjustments with the Counseling Director.

5.4 Schedule Deviations

Schedule deviations occur for various reasons both institutional and personal. Weekly clinical capacity will be adjusted to reflect time out of the Counseling Center. It is not necessary or expected to “make up” hours spent away from direct student care.

College of Eastern Idaho Counseling Center Services for Minors Procedure

CEICC Procedure #6 • Updated 11/18/2024

6.0 Overview

This procedure outlines the process for providing counseling services to any students under the age of 18. In accordance with the 2024 Idaho state legislation of Senate Bill 1329, as well as House Bill 538, parental consent is required for unemancipated minors to receive any type of medical service. Mental health counseling falls under this category.

6.1 Scope

This procedure applies to all students under the age of 18 seeking counseling services. This includes high school students under the age of 18 participating in concurrent enrollment programs at College of Eastern Idaho, as well as students who have fully graduated high school and are under the age of 18.

6.2 Service Requests

High school students enrolled in concurrent enrollment programs are encouraged to first seek counseling services within their high schools, if available.

If mental health counseling services are not offered at the student's high school, or if the student is fully graduated from high school, the following process will apply:

a) The student must obtain an Addendum to Informed Consent from the Counseling Center website or from a Counseling Center staff member.

b) The student's parent or legal guardian must complete and sign the form.

c) The signed form must be returned to CEICC either in person by the parent/guardian with ID presented, or via email address with ID and completed form attached. The email address display name must match the name on the parent/guardian ID.

This form must be completed before mental health services can be provided to anyone under the age of 18 by CEICC.

6.3 Emancipated Minors

Students under the age of 18 who are legally emancipated minors are able to consent to services under SB 1329, and are also able to define their own preferred name and pronouns under HB 538.

Due to these factors, legally emancipated minors who have completed high school or high school equivalency, or who attend a high school that does not offer mental health counseling are categorized differently than their unemancipated peers.

If a minor student meets the criteria outlined in the paragraph above, they are able to access mental health services through CEICC after providing verifying documentation of their emancipated status.

Examples of qualifying documentation include a court order, marriage certificate, or other equivalent legal documentation.

Documentation must be submitted to CEICC and verified before services can begin. Once verified, emancipated minors may consent to their own counseling services without parental involvement.

6.4 Confidentiality

Once parental/guardian consent is obtained, or emancipated status is verified, counseling services will be provided in accordance with standard confidentiality practices and ethical guidelines of the social work/counseling professions. 

6.5 Imminent Danger

In cases of imminent danger, staff will follow established emergency protocols to ensure student safety, which may include contacting emergency services or parents/guardians as appropriate.

6.6 Records Storage

Signed Addendum to Informed Consent, and copies of other provided documentation will be securely stored in the student's confidential file in Titanium Schedule (CEICC’s EMR).

College of Eastern Idaho Counseling Center Ethical Guidelines for Student Outreach

CEICC Procedure #7 • Updated 03/13/2025

7.0 Overview

This procedure outlines the ethical and professional considerations relating to potential outreach conducted by CEICC staff to students who have not explicitly requested counseling services. Participation in counseling must be voluntary to ensure ethical integrity, protect privacy, and uphold professional boundaries. This includes, but is not limited to, requests for the Counseling Center to reach out to students as part of general wellness checks, in response to Maxient Reports, CARE Team referrals, or other third-party concerns.

7.1 Scope

This procedure applies to all outreach requests routed to CEICC staff regarding students who have not directly requested services. While CEICC clinical staff may provide consultation and guidance to faculty, staff, and campus teams regarding student concerns, direct clinical outreach to students is limited to situations where the student has provided consent or has initiated contact themselves.

7.2 Ethical and Professional Considerations

While counseling is a resource for students navigating emotional challenges or crises, counseling is more than simply a space to process emotions and experiences. Counseling is an ethical and structured process that requires clear boundaries to be effective and to avoid potential harm. Without this framework, the therapeutic process not only loses its integrity, but may also become unethical or even damaging to those seeking support.

CEICC procedures are structured to follow professional ethical standards, including those set forth by the National Association of Social Workers (NASW), the American Counseling Association (ACA), and the American Psychological Association (APA).

The following ethical principles guide CEICC’s approach to student outreach:

• Informed Consent: Ethical guidelines require that students voluntarily seek services. Outreach to students who have not requested counseling risks violating their autonomy and does not allow for informed consent.

• Professional Boundaries: Unsolicited contact from a mental health professional may be perceived as intrusive or coercive, which can deter students from engaging in services when they are ready.

• Confidentiality & Privacy: While FERPA governs educational records, counseling records are legally entitled to heightened confidentiality protections, closely resembling HIPAA standards. Even when no official record exists, outreach to students who have not requested services may create privacy concerns by implying that their well-being has been discussed or flagged in a way they did not consent to. This could also create confusion about the voluntary nature of counseling, potentially leading students to feel pressured or surveilled.

• Dual Relationships: The role of CEICC staff on multidisciplinary teams, such as the CARE Team, is consultative rather than direct intervention. Unlike other CARE Team members who do not hold clinical roles, CEICC staff cannot ethically engage in outreach that resembles a clinical interaction without consent.

7.3 Alternative Outreach Methods

While CEICC clinical staff cannot complete direct outreach to students who have not requested services, alternative methods exist to ensure students are aware of and are able to access available mental health resources. These include:

• Providing guidance to faculty, staff, and other concerned individuals on how to support and refer students to counseling services.

• Offering general mental health awareness campaigns, educational, and outreach events that inform students of available services.

• Collaborating with non-clinical campus professionals who can ethically engage in proactive outreach when appropriate.

• Encouraging warm handoffs where a trusted faculty or staff member introduces a student to CEICC if the student expresses interest.

7.4 General Outreach

The Counseling Center’s administrative assistant may occasionally conduct general outreach calls or emails to students in response to concerns routed from the Dean’s office or from the CARE team. These outreach efforts serve to provide information on campus resources, including counseling, academic support, and other student services. They are not specific to mental health concerns and are framed as general outreach on behalf of Student Affairs, not the Counseling Center.

Information regarding these interactions cannot be shared with staff outside CEICC. The only information that can be shared is the confirmation that the report was received. Requested contact may not be completed if the student is already actively engaged in services.

7.5 Implementation & Compliance

All CEICC staff will adhere to this procedure and maintain alignment with professional ethical standards. Repeated requests to counseling staff to engage in prohibited types of outreach may result in escalation to administration or Human Resources to ensure adherence to professional standards. Any questions regarding this procedure should be directed to the Counseling Center Director for further clarification.