What does a telehealth therapy SOAP note include compared to an in-person note?

A telehealth therapy SOAP note includes the same core elements as an in-person note — Subjective (client's reported experience, presenting concern, mood and affect as observed), Objective (clinician's observations, behavioral indicators visible via video, any standardized measure scores), Assessment (clinical formulation, progress toward treatment goals, diagnosis status), and Plan (interventions for next session, homework, treatment-plan adjustments). Telehealth-specific documentation additions include: the modality (audio-only vs. video), the platform used, the client's location state (relevant for interstate licensure compliance), whether the session met the visual and audio quality standard required for the modality billed, and any technology-related disruptions and their clinical significance.

Can telehealth therapy be documented with PSYPACT state-line compliance notes?

TherapyDraft generates the note draft; the clinician's documentation of PSYPACT compliance — which state the client was physically located in, the specific licensure authority covering that state, whether the session meets the definition of 'telepsychology' under PSYPACT guidelines — is added by the clinician during the editing step. TherapyDraft's template for telehealth sessions includes a prompt for the client's state of location and the modality used, which the clinician fills in before finalizing the note. PSYPACT documentation requirements vary by member-state update and should be verified against current guidance from the Psychology Interjurisdictional Compact Commission.

Topic · AI SOAP notes for telehealth therapy

AI SOAP notes for telehealth therapy sessions drafted on your Mac — no third-party audio processor added to your session data chain

Q: Does TherapyDraft work for telehealth therapy sessions?

Yes. TherapyDraft works for telehealth sessions with the same workflow as in-person sessions. After the video call ends, the clinician records a brief audio summary of the session — using the Mac's built-in microphone or an external recorder — or saves the video platform's local recording file. TherapyDraft loads that audio, transcribes it locally using Whisper.cpp, and drafts the SOAP, DAP, BIRP, or GIRP note using the local model. No audio is uploaded to any cloud service. The session content stays on the clinician's Mac from recording to EHR paste.

Q: Is using a cloud AI scribe during a telehealth session a HIPAA concern?

Using a cloud AI scribe during a telehealth session introduces a second vendor into the session audio chain. The video platform (SimplePractice Video, Doxy.me, Zoom for Healthcare) already processes the audio for the call — that is unavoidable with any real-time video. Adding a cloud AI scribe adds a third-party that records, transcribes, and retains the session audio independently of the video platform. This creates a second vendor archive, a second BAA requirement, and a second independently subpoenable record. The therapist's HIPAA obligations extend to every subprocessor in the chain; the BAA with the AI scribe vendor does not eliminate the vendor's ability to produce its own records in response to legal process. TherapyDraft eliminates the second vendor entirely — the audio is processed after the call on the clinician's own Mac.

Q: What are the state-line HIPAA considerations for telehealth therapists?

Telehealth therapy across state lines involves two independent layers: the interstate licensure question (is the clinician licensed to practice in the client's state?) and the data custody question (where is the session data processed, and which state's laws govern the data). The major cloud AI scribe vendors process data on infrastructure distributed across multiple jurisdictions — often undefined in the BAA — which means the session data may be subject to the legal process rules of any jurisdiction where the vendor's servers are located. This is distinct from the clinician's licensure compliance. TherapyDraft's local processing means session data is processed on the clinician's Mac, in the jurisdiction where the Mac is located — typically the clinician's own state, not a cloud vendor's data-center jurisdiction.

More than 70% of outpatient mental health visits in 2026 occur via telehealth. The video platform already processes session audio for the call — that is unavoidable with any real-time video connection. Adding a cloud AI scribe to a telehealth workflow introduces a second vendor into the session audio chain: a second party that records, transcribes, and retains the session content independently of the video platform, with its own BAA, its own data-retention policy, and its own response to legal process. TherapyDraft drafts SOAP, DAP, BIRP, and GIRP notes for telehealth sessions from audio processed entirely on the clinician's M-series Mac, after the call ends. No second vendor is added to the chain.

TL;DR

TherapyDraft is a local AI note-drafting tool that runs entirely on the clinician's M-series Mac. For telehealth sessions, the workflow is post-call: the clinician records a local audio summary after the video call ends, or saves the platform's local recording, and TherapyDraft transcribes and drafts the note locally. No telehealth session audio reaches any cloud AI subprocessor. There is a 10-session free trial at no cost; paid plans start at $39 per month.

Why telehealth therapy already has a complex data chain

In-person therapy has a simple data chain from a note-drafting perspective: one clinician, one client, one room. The session content is in the room. The clinician's documentation of the session is created by the clinician after the session, and no third party processes the session audio unless the clinician specifically introduces one.

Telehealth therapy already extends that chain. The video platform — SimplePractice Video, Doxy.me, Zoom for Healthcare, Google Meet for Healthcare — processes the session audio in real time on the platform's infrastructure. This is necessary for the video call to function. The platform is a business associate; the clinician's BAA with the platform governs this processing. Most telehealth platforms serving the mental health market have well-developed HIPAA programs, and this is a widely understood and accepted part of the telehealth workflow.

Adding a cloud AI scribe to the telehealth workflow adds a third participant to the data chain. The AI scribe service either captures the session audio from the clinician's microphone feed (live capture), receives a recording file from the video platform (post-session), or listens to a live audio stream of the session. In every case, the AI scribe creates an independent record of the session — a vendor archive with its own data lifecycle, its own retention schedule, and its own obligations and vulnerabilities under legal process.

The question is whether this second vendor archive is worth the workflow convenience it provides, and whether the BAA with the cloud AI scribe adequately covers the risks it introduces. For clinicians who practice in high-sensitivity specialties, with high-conflict clients, or in jurisdictions with active legal demand for mental health records, the second vendor archive is a meaningful additional exposure — not a theoretical one.

The two-vendor problem and what TherapyDraft does instead

TherapyDraft's post-call workflow sidesteps the two-vendor problem entirely. The clinician does not capture session audio through TherapyDraft during the telehealth call — doing so would require the app to process live audio while the session is occurring, which is the pattern that creates the second-vendor problem. Instead:

The telehealth session occurs on the video platform as normal. The video platform's BAA covers this processing.
After the call ends, the clinician uses TherapyDraft in one of two ways: records a 3–5 minute verbal summary of the session into their Mac's microphone, or loads a local recording file saved from the video platform (some platforms offer local recording options that do not upload to the platform's cloud).
TherapyDraft processes that local audio using Whisper.cpp running on the Mac's Neural Engine. The transcript is generated locally. The note is drafted locally. No audio or transcript is uploaded anywhere.
The clinician edits the draft and pastes the finalized note into the EHR.

The session audio that reaches any external party is limited to the video platform that operated the call — no additional vendor archive is created for the note-drafting step.

Telehealth SOAP notes: what they document differently

The core SOAP structure — Subjective, Objective, Assessment, Plan — applies to telehealth sessions identically to in-person sessions. The note documents the client's presenting concern, the clinician's observations, the clinical assessment, and the plan for continued care. What changes in telehealth documentation is the set of modality-specific details that billing compliance, telehealth-payer requirements, and interstate licensure compliance require:

Telehealth modality and platform — audio-only vs. video; the platform name. Some payers require the specific CPT modifier (95 for telehealth, 02 for when the client is in a telehealth originating site) and the Place of Service code (02 for telehealth, 10 for patient home). Documentation should support the billing.
Client's physical location state — for interstate telehealth, documenting the client's state of residence or physical location during the session is the foundation for licensure compliance. PSYPACT and similar interstate compacts require evidence that the clinician was authorized to practice in the client's state.
Technology quality and disruptions — if audio or video quality affected the clinical encounter (connection dropped, audio cutout during a significant disclosure, poor video quality that prevented observation of nonverbal affect), the note should document this and its clinical significance. This protects the clinician in any subsequent dispute about the adequacy of the clinical contact.
Client's environment and safety — telehealth documentation often includes a brief note on the client's observed environment (private vs. shared space), whether the client was in a safe location, and any environmental factors that affected the session. This is particularly relevant for high-risk clients.

See the detailed analysis of telehealth therapy notes, HIPAA, and state-line documentation requirements for the full documentation checklist.

PSYPACT, interstate telehealth, and data custody

PSYPACT enables licensed psychologists in member states to provide telehealth services across state lines under a single compact authority. As of 2026, PSYPACT has over 40 member states. For psychologists practicing under PSYPACT, the licensure question is substantially resolved by the compact — but the data custody question is not addressed by PSYPACT at all.

The data custody question for interstate telehealth is: in which jurisdiction's legal framework is the session data held, and what are the legal process rules in that jurisdiction? A cloud AI scribe that processes session data on distributed infrastructure — servers in Virginia, Oregon, and Ireland simultaneously — creates a record that is potentially subject to the legal process rules of multiple jurisdictions. The BAA typically does not specify exactly where the data is processed. The clinician in Massachusetts practicing with a client in Florida has a PSYPACT authorization; they do not have clarity on whether the AI scribe's Virginia-based servers are subject to Virginia's health data laws, federal law, or Florida's.

TherapyDraft's local processing means session data is on the clinician's Mac — in the clinician's state of operation. There is one jurisdiction, one custodian, one data location. See the full analysis of PSYPACT, telehealth, and cloud data custody.

Pricing

TherapyDraft is $39 per month or $349 per year for the Solo plan — unlimited telehealth session note drafts, SOAP / DAP / BIRP / GIRP format options, EHR paste presets for SimplePractice, TheraNest, and TherapyNotes, the inference attestation log, and one-shot template matching from your own example telehealth notes. The 10-session free trial requires no credit card. Full pricing breakdown is on the pricing page.