I have been losing sleep over AI. Not in a dramatic way, but in the quiet, 2 a.m. way where I start wondering whether I am protecting my clients well enough, whether the tools I rely on are doing something with their information that I do not understand, and whether using AI for my own content is quietly cheapening the work.
If you are a therapist in private practice feeling some version of that, you are not behind and you are not overreacting. Here is where I have landed for now.
Therapists should draw the line with AI wherever client information enters a tool they cannot fully control. That means no client material in general purpose chatbots, even with names removed, and deliberate limits on what goes into HIPAA compliant ones. Beyond privacy, there is no universal line, so audit your own use and treat discomfort as data.
Key Takeaways
- Removing a client’s name is not de-identification. The HHS Safe Harbor method for de-identifying health information requires removing 18 categories of identifiers.
- Psychologists who had never used AI in their work fell from 71% in 2024 to 44% in 2025, according to the American Psychological Association’s 2025 Practitioner Pulse Survey.
- I have never recorded a therapy session, and I only give my HIPAA compliant AI scribe handwritten notes with no identifying details or a summary I type myself.
- There is no published line that settles when AI use in therapist content, courses, or CE materials becomes a problem, so each therapist has to audit their own use.
- EMDR intensives run against the logic of AI: days of time, space, and human connection with one person instead of speed and automation.
Is it safe for therapists to put de-identified client notes into ChatGPT or Claude?
Putting client notes into a general purpose chatbot like ChatGPT or Claude is not safe, even when the therapist has removed the client’s name. Kym Tolson, who hosts the podcast Run Your Private Practice with AI, described how many therapists she talks with still use general tools to write clinical notes, process cases, or build treatment plans, sometimes without removing identifying details at all. Nobody is doing this out of malice. The tools are moving faster than most of us can track.
The problem is that “de-identified” has a specific meaning. Under the HIPAA Privacy Rule, the U.S. Department of Health and Human Services Safe Harbor method requires removing 18 types of identifiers, including names, geographic details smaller than a state, all elements of dates except the year, and any other unique identifying characteristic, as set out in the HHS Office for Civil Rights de-identification guidance published in 2012. A session summary with the name swapped out but the client’s age, town, job, and family story intact does not meet that bar.
On top of that, the companies behind these tools keep changing how they process, store, and access data. A therapist’s control over client information slips a little every time it leaves the therapist’s own hands.
How can a therapist use a HIPAA compliant AI scribe without recording sessions?
A therapist can use a HIPAA compliant AI scribe without recording sessions by controlling exactly what goes into it. I use Berries, a HIPAA compliant scribe, in only two ways. I either upload a photo of my handwritten notes, which never include client names, locations, or identifying information, or I type a quick post session summary and let the scribe organize it into a note. I edit a lot, especially from the handwritten version, and it still saves me time. My notes come out better than they did before.
“I have never recorded my therapy sessions and honestly, even with those HIPAA compliant AI scribes, I’m never going to.”
Dr. Carolyn Solo, PhD, LCSW, Future Template Parent EP 168
Even a tool that is sold as HIPAA compliant is still a tool whose inner workings I cannot see. Keeping the input minimal is the one part of that risk a therapist fully controls.
Can therapists use AI to create courses, content, and CE materials?
Therapists can use AI in content and course creation, but the rules are unsettled and changing. Kym Tolson reported on her podcast that organizations like the APA are taking firm stances against using AI to generate materials for continuing education courses. I have not read those guidelines myself, and any therapist who creates CE content should read the current rules from their own approving body directly rather than relying on a summary.
The harder question is where the line sits for everything else. This episode of Future Template Parent started as voice memos I recorded while driving. I gave those notes to Claude and asked for an outline. Does that make the episode “made by AI”? If a therapist supplies every core idea for a slide deck and asks AI to organize the flow, does it need a label or a digital watermark? I do not know, and I suspect nobody does yet.
“There is no line that we’re gonna be able to be like, aha, this is exactly where it says AI is okay and AI is not okay.”
Dr. Carolyn Solo, PhD, LCSW, Future Template Parent EP 168
Are therapists falling behind if they don’t use AI?
Therapists feel real pressure to use AI because of how quickly the field is adopting it. The American Psychological Association’s 2025 Practitioner Pulse Survey found that the share of psychologists who had never used AI to assist with their work dropped from 71% in 2024 to 44% in 2025, and 29% now use it at least monthly. The same survey found that 67% of psychologists named data breaches as a concern.
The pressure shows up in marketing too. A therapist I coach went from lots of calls to almost none, and part of the reason is that people increasingly find therapists through AI search instead of traditional search. I recently attended a workshop on showing up in AI search from Danielle Swimm of The Entrepreneurial Therapist, and it was genuinely intimidating. It feels like a runaway train: crank out blog posts, freebies, and webinar slides with AI, or get left behind.
That same coaching client offered a perspective I think every ethical therapist needs. Therapists are not using AI to sell cheap, exploitative products made at the expense of other people’s livelihoods. Therapists are using it to help people find ethical, life changing therapy. Therapists are also dealing with protected health information, so we cannot hand ourselves a blank check. But we can hold ourselves accountable without carrying the blame that belongs to corporations who never ask these questions at all. It is the same pattern as therapists blaming themselves for being “inaccessible” for not taking insurance, while insurance companies that go months without paying providers face no such scrutiny.
Why are EMDR intensives a counterweight to AI?
EMDR intensives are a counterweight to AI because they do the opposite of what AI is built for. AI is designed to speed things up by taking the person out of the process. An EMDR intensive slows everything down and puts one person at the center for days: extended time, dedicated space, and sustained human connection with a single therapist.
“AI is all about speeding up, doing things faster. Intensives force us to slow down. They prioritize time, space, human connection. That is the opposite of what AI provides.”
Dr. Carolyn Solo, PhD, LCSW, Future Template Parent EP 168
For a therapist marketing intensives, coaching, or EMDR consultation, the therapist is the product in the best sense. A therapist’s personality, presence, and way of being with people is what clients choose. ChatGPT has only been in the mainstream since late 2022. The core value intensive therapists offer existed long before it, and it does not need to compete with it.
How can a therapist audit their own use of AI?
A therapist can audit their own AI use by pausing each time they reach for a tool and asking one question: is this something I really want to do this way, or would I rather do it the analog way? That pause is the whole audit. It does not require logging every task or building a spreadsheet. It requires noticing.
Doing more by hand will take more time. I am choosing that trade in some places, and I may go back to writing a few bullet points before I record instead of asking for a polished outline. The point is to make the choice on purpose instead of accepting AI as the status quo.
“If something feels icky, listen to that.”
Dr. Carolyn Solo, PhD, LCSW, Future Template Parent EP 168
A therapist’s discomfort is clinical-grade information, and therapists are trained to take it seriously in everyone except themselves.
The Bottom Line
The one firm line I would draw for any therapist in private practice is around client information: keep it out of general tools, and keep what goes into compliant tools as minimal as possible. Everything else, from AI outlines to AI marketing, is a judgment call that each therapist has to keep making as the tools change. Stay educated, stay intentional, and trust the part of you that notices when something feels off. The people building these tools would prefer we stop asking. Keep asking.
Frequently Asked Questions
Can therapists use ChatGPT to write clinical notes?
Therapists should not put client information into a general purpose chatbot like ChatGPT to write clinical notes, even with the client’s name removed. Removing a name does not meet the HHS Safe Harbor standard, which requires removing 18 categories of identifiers. A HIPAA compliant scribe used with minimal, non identifying input is a safer option.
Is removing a client’s name enough to de-identify a note?
No. Under the HIPAA Privacy Rule’s Safe Harbor method, de-identification requires removing 18 types of identifiers, including geographic details smaller than a state, dates other than the year, and any unique identifying characteristic. Most session notes carry details that could identify a client even without a name.
Do HIPAA compliant AI scribes require recording sessions?
No. Some HIPAA compliant AI scribes can record sessions, but they do not have to be used that way. I never record. I give my scribe either a photo of handwritten notes with no identifying details or a short summary I type after session, and it organizes the note from that.
Can therapists use AI to create CE course materials?
The rules are changing. Some organizations, reportedly including the APA, are taking firm positions against using AI to generate CE course materials. Any therapist who creates continuing education content should read the current guidelines from their own approving body directly before using AI in that work.
Listen to the full conversation: Future Template Parent EP 168, Dr. Carolyn Solo, PhD, LCSW, on AI, client privacy, content pressure, and why EMDR intensives run the other way. Listen on Apple Podcasts.
