How to Create a Group Therapy Informed Consent Form for Group Counseling Practices (with Free Template)
This guide walks a group counseling practice owner or group leader through the ten substantive steps of building a HIPAA-aware group therapy informed consent form that satisfies APA Ethics Code 10.03, ACA Code A.9, and the patchwork of state-specific telehealth and mandatory-reporting rules. Each step is one paragraph of working guidance. Estimated time end-to-end: 45 minutes from blank document to signed PDF when using an AI form builder. Formfy is the AI form builder group practices use; the same builder produces the consent form, captures member confidentiality agreement signatures across all members in a single workflow, and stores the audit trail behind a Business Associate Agreement under 45 CFR 164.314.
Before you start, gather seven pieces of information: (1) the group inclusion and exclusion criteria, (2) the group format and meeting cadence, (3) the CPT billing code (typically 90853), (4) the per-session fee and insurance status, (5) the telehealth platform and BAA status if applicable, (6) the state mandatory-reporting statute citations, and (7) the leader license number and supervisor name if pre-licensure. With those seven inputs, the substantive drafting takes under 45 minutes. Without them, the consent cannot be drafted because the scope, fee, and supervision clauses cannot be filled in.
Step 1: Define group composition criteria (diagnoses, age, voluntary vs court-ordered)
Begin by stating exactly who the group is for and who it is not for. Name the inclusion criteria: presenting concerns the group treats (depression, anxiety, grief, addiction, trauma processing, social skills), the age range, and the gender or identity composition (mixed, men only, women only, LGBTQ-affirming). Name the exclusion criteria using DSM-5-TR-aligned categories: active psychosis, active suicidality requiring higher level of care, active substance dependence requiring medical detox, severe personality pathology that disrupts group safety, and cognitive impairment limiting participation. State whether participation is voluntary or court-ordered (DUI groups, batterer intervention programs, court-mandated substance use programs). Court-ordered participation has different consent dynamics: the patient is participating under coercion, which the group leader must acknowledge in the consent and document at intake. State the screening protocol that confirms inclusion and rules out exclusion criteria. State the group format (open, closed, time-limited, ongoing) and the meeting cadence.
Step 2: Disclose HIPAA group confidentiality limits (45 CFR 164.502)
HIPAA 45 CFR 164.502 sets the boundaries on use and disclosure of protected health information. Critical group point: HIPAA covers the practice (a covered entity) but does NOT cover the other group members. Group members are not covered entities. The clinician is bound by HIPAA to protect what they hear; other group members are bound only by the voluntary member confidentiality agreement, which has no enforcement mechanism beyond removal from the group. The consent form must state this distinction explicitly: I understand that the group leader is bound by HIPAA and state confidentiality law; other group members are bound by the member confidentiality agreement, which is voluntary, and that I cannot guarantee what other members will or will not disclose outside the group. State that group records are maintained as a single chart with group session notes; individual disclosures within the group may be summarized in the group note. State the limits of confidentiality that apply to the group leader: mandatory reporting, court orders, imminent danger.
Step 3: Capture member confidentiality agreement with non-enforceability disclosure
The member confidentiality agreement is a voluntary commitment by each group member to keep group content confidential. It is NOT legally enforceable in most jurisdictions because group members are not licensed professionals bound by HIPAA or state confidentiality statutes. The consent form must capture two things. First, the members agreement: I will not disclose the identity of other group members or the content of group discussions outside the group, including with my own therapist absent specific clinical need, with family members, or in social media. Second, the disclosure that this commitment is voluntary: I understand that the only practical enforcement is removal from the group, that the group leader cannot prevent breaches, and that I am ultimately responsible for the level of disclosure I make in group. State the consequence of a confidentiality breach by another member (group leader notification, group discussion, possible removal of breaching member). Document the agreement signature.
Step 4: Document informed consent specific to group format
APA Ethics Code 10.03 specifically addresses group therapy: at the outset of group therapy, psychologists describe the role and responsibilities of all parties and the limits of confidentiality. ACA Code A.9 mirrors this for licensed counselors. Document the elements: the nature of the group format and how it differs from individual therapy, the foreseeable risks specific to group (emotional reactions to other members, breach of member confidentiality, group dynamics conflicts), the foreseeable benefits specific to group (peer support, modeling, normalization of experiences), the leader role (facilitator, not individual therapist for each member), and the limits of individual treatment within group (the leader does not provide individual sessions to group members in most practices). State the alternatives (individual therapy, peer support without clinical leadership). Document the patient understanding that individual therapy goals may not be addressed adequately in a group format. Document the policy on combined individual and group treatment.
Step 5: Reference ASAM levels of care (substance use disorder groups)
If the group treats substance use disorder, reference the ASAM Criteria. The American Society of Addiction Medicine ASAM Criteria, currently in the 4th edition (2023), define six dimensions of assessment and five levels of care: Level 0.5 (Early Intervention), Level 1 (Outpatient Services), Level 2 (Intensive Outpatient and Partial Hospitalization, with sub-levels 2.1 IOP and 2.5 PHP), Level 3 (Residential and Inpatient, with multiple sub-levels), and Level 4 (Medically Managed Intensive Inpatient). Most outpatient SUD groups operate at Level 1 or Level 2.1. State the level of care explicitly so the patient understands the intensity of services and the expected progression. State the criteria for stepping up (relapse, escalating risk) or stepping down (sustained recovery, lower clinical need). The consent should reference 42 CFR Part 2 if the program is a federally assisted SUD program; this is stricter than HIPAA and applies to records that identify someone as receiving SUD treatment.
Step 6: Disclose group billing CPT codes (90847 conjoint, 90849 multi-family, 90853 group)
Group billing uses three primary CPT codes that often confuse patients. CPT 90853 (Group psychotherapy, other than of a multiple-family group) is the standard group therapy code; it is billed once per patient per session, typically for 45 to 60 minute groups with 5 to 10 members. CPT 90847 (Family psychotherapy with the patient present) is conjoint family therapy with one identified patient; it is NOT a group therapy code despite being used in family work. CPT 90849 (Multi-family group psychotherapy) covers multiple identified-patient families meeting together, common in adolescent SUD and eating disorder programs. State which code applies to the group, the typical session length, the per-session fee, and the insurance billing approach. Note: insurance reimbursement rates for 90853 are typically 30 to 50 percent of individual therapy rates. State whether the practice is in-network and which networks. State the No Surprises Act good faith estimate obligation under 45 CFR 149.610 for self-pay patients.
Step 7: Address dual relationships in group settings (APA 3.05)
APA Ethics Code 3.05 addresses multiple relationships and is particularly relevant in groups where members may know each other before joining or develop relationships outside group. Document the policy on dual relationships. State that members should disclose any pre-existing relationship with another member at intake (workplace colleague, family relative, acquaintance, romantic relationship). State that the leader will determine whether the group is appropriate or whether the member should be referred to a different group. State the policy on relationships that develop during group: most practices prohibit romantic or sexual relationships between members during the group and for a defined period after, prohibit financial relationships between members and the leader, and require disclosure to the group leader of any relationships that develop outside group. The leader must avoid dual relationships with members under APA 3.05 and ACA Code A.6. State the consequence of an undisclosed dual relationship (removal from group). Document the disclosure obligation in the consent.
Step 8: Establish termination from group and clinical implications
Termination from group has different clinical implications than individual therapy termination because the remaining members are affected by a member departure. State the termination protocol. For voluntary departure: members commit to a defined number of weeks notice (typically two to four sessions) so the group can process the departure. The departing member is encouraged to attend at least one termination session to share with the group. For involuntary removal: the leader may remove a member who breaches the member confidentiality agreement, repeatedly disrupts group safety, or violates the dual relationship policy. The leader will provide written notice and offer referrals to alternative services. State the abandonment prevention obligation under APA Ethics Code 10.10: the leader must offer referrals and not leave the member without alternatives. State the policy on members returning to group after departure (typical practice: a screening session and group consensus). Document fee responsibilities at termination.
Step 9: Address telehealth group considerations
Telehealth groups raise unique considerations. State the technology platform and confirm BAA coverage under 45 CFR 164.314 (Zoom for Healthcare, Doxy.me Group, SimplePractice Telehealth Group). State the patient location requirement: each member must be physically located in a state where the leader is licensed at the time of the session, or in a state with telehealth interstate compact participation (PSYPACT for psychologists, Counseling Compact for LPCs, Social Work Licensure Compact). State the privacy requirement for the patient location: each member must use a private space free from non-member observers, must not record sessions, and must use headphones if other people are in the home. State the policy on attending group from a public location (typically prohibited). State the emergency protocol for telehealth: leader verifies each member address each session, identifies a local emergency contact, and identifies the nearest hospital. State the technology failure protocol (alternate platform, callback, reschedule). Telehealth groups have higher dropout rates than in-person groups; document the attendance expectations.
Step 10: Capture documentation and signature requirements per state law
Documentation for groups varies by state and license type. State the chart structure: each member has an individual chart with intake, consent, treatment plan, and termination summary; the group leader maintains a separate group chart with session notes that summarize group themes, attendance, and any clinically significant individual disclosures. State that individual chart entries are derived from group activity but do not name other group members. State the retention period: HIPAA 45 CFR 164.530(j)(2) requires documentation retention for at least six years; state-specific retention typically ranges from five to twelve years from last contact, longer for minor patients. Capture the e-signature with a tamper-evident audit trail under the federal ESIGN Act and the Uniform Electronic Transactions Act. The platform must operate under a HIPAA Business Associate Agreement under 45 CFR 164.314. Formfy, SimplePractice, TherapyNotes, DocuSign, and Adobe Acrobat Sign sign HIPAA BAAs. The audit trail captures signer name, email, IP address, timestamp, document hash, and consent text. Court orders and subpoenas for group records receive special treatment under HIPAA 45 CFR 164.512(e); consult counsel.
Free template and downloadable PDF
Formfy ships a group therapy informed consent template that maps one-to-one to the ten steps in this guide. The template is editable in the AI form builder: describe the group in plain English and the builder returns a delivery-ready consent form with the e-signature block, member confidentiality agreement section, telehealth section, and ASAM Level of Care section if applicable. Each new group member signs a single link that captures their consent and member confidentiality agreement together. The PDF version is generated automatically when each member signs and stored alongside the audit trail behind a HIPAA Business Associate Agreement under 45 CFR 164.314.
See also: /faq/group-counseling-practices-group-therapy-informed-consent for the FAQ companion hub covering the most common group therapy informed consent questions.
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Start your free trialLast verified: 2026-04-25. This page is informational; it is not legal or clinical advice. Group counseling practices should review state-specific mandatory reporting, telehealth licensure compact participation, 42 CFR Part 2 application to SUD groups, and abandonment-prevention rules with counsel and their licensing board.