_________ Frederic G. Reamer, PhD, Professor Emeritus, School of Social Work, Rhode Island College, Providence, RI. Copyright © 2023 Authors, Vol. 23 No. 2 (Summer/Fall 2023), 375-391, DOI: 10.18060/26358 This work is licensed under a Creative Commons Attribution 4.0 International License. Social Work Boundary Issues in the Digital Age: Reflections of an Ethics Expert Frederic Reamer Abstract: Throughout social work’s history, practitioners have faced challenging boundary issues. Boundary issues occur when social workers encounter actual or potential conflicts between their professional duties and their social, sexual, religious, collegial, or business relationships. Today's social workers face a wide range of boundary challenges that are unprecedented because of practitioners’ and clients’ widespread use of digital and other forms of internet-enabled technologies. This article presents a typology of boundary- related challenges arising out of social workers’ and clients' use of technology; reviews and applies emerging ethical and practice standards; and discusses risk-management protocols designed to protect clients and social workers. The author offers practical recommendations to protect clients and practitioners, including compliance with state-of- the-art ethics standards related to technology use and development of a comprehensive social media policy. Keywords: Dual relationships, ethics, professional boundaries, technology, values Throughout social work’s history, practitioners have faced challenging boundary issues. For many decades, social workers have navigated boundary dilemmas involving self-disclosure of personal information to clients, living and working in small communities, responding to clients' social invitations and gifts, hiring former clients as employees, and performing favors for vulnerable clients, among others. Over time, the profession has produced increasingly comprehensive ethical standards pertaining to dual relationships and potential conflicts of interest (Reamer, 2021a; Zur, 2017). Boundary issues occur when professionals encounter actual or potential conflicts between their professional duties and their social, sexual, religious, collegial, or business relationships (Reamer, 2021a). Today's social workers now face a wide range of boundary challenges that are unprecedented because of practitioners’ and clients’ widespread use of digital and other forms of technology. Digital technology has transformed the ways in which social workers are delivering services to clients, including distance counseling using video, live chat, avatars, smartphone apps, and text messages, among other tools; communicating with clients using social media and social networking sites (e.g., Facebook); searching online for information about clients (e.g., Facebook, Google, and LinkedIn); storing sensitive information (e.g., in the cloud); permitting clients to access their electronic records remotely; and being the subject of online searches by clients (e.g., when clients seek personal information online about their service providers). These phenomena have created new forms of boundary issues that could not have been imagined by earlier generations of social workers (Banks et al., 2020; Freddolino et al., 2022; Pascoe, 2021). Following are several (disguised) examples drawn directly from the author’s experience as an expert witness in social work litigation and licensing board cases. about:blank ADVANCES IN SOCIAL WORK, Summer/Fall 2023, 23(2) 376 • A clinical social worker in private (independent) practice communicated with several of her clients via text messages and email. Some messages concerned administrative matters, such as scheduling; others included clinical content, especially when clients contacted the social worker remotely during a crisis. The social worker received an increasing number of electronic messages on her personal smartphone account from clients after traditional working hours, sometimes late at night and on weekends. The social worker wondered whether communicating with clients outside of traditional working hours was introducing boundary issues in his relationships with them. • A clinical social worker at a mental health center provided services to a woman who was involved in a protracted child custody dispute with her estranged husband. Over the course of several counseling sessions, the client reported instances when her husband allegedly abused her and was arrested by the police. The social worker noted several inconsistences in the client’s version of these events and considered looking online for information about these incidents to verify the clients’ reports. The social worker reflected on whether it is ethical to conduct an online search for information about clients without their knowledge or consent. • A clinical social worker was active on a Facebook group whose members advocated in the local community for women’s reproductive rights. Over time, the social worker developed meaningful online relationships with several group members. On occasion, the social worker shared information with members of this Facebook group about her personal journey, including the fact that, during her college years, she had an abortion. One of the Facebook group members learned of the social worker’s clinical practice after conducting a Google search on her, reached out to her online, and asked to become a client to process some “personal relationship issues.” The social worker wondered whether it is appropriate for her to provide clinical services to someone with whom she has had a personal Facebook relationship. • At the onset of the COVID-19 pandemic, a clinical social worker began serving clients remotely using video software, which generated novel privacy and boundary issues. During counseling sessions, the social worker often saw the interiors of clients’ homes and, on occasion, met clients’ children, spouses, partners, and pets who entered the room where the client was located and were on camera briefly. On two occasions, the social worker’s four-year-old child wandered unannounced and uninvited into the social worker’s home office and introduced herself to clients who appeared on the social worker’s computer screen. • A social worker in a substance use disorders treatment program was in recovery and participated actively in an online support group. Occasionally, the social worker posted details about her own recovery. She discovered that one of her clients, who was also in recovery, gained access to this online Reamer/BOUNDARY ISSUES 377 support group and read several of the social worker's postings about the practitioner's personal life. The Evolution of Scholarship on Boundary Issues The subjects of boundaries and dual relationships in the behavioral health professions emerged in the 1980s. The pioneering work of Bograd (1993), Brodsky (1986), Epstein (1994), Gabbard (1996), Gutheil (1989), Schoener (1995), and Simon (1992), among others, laid the rich conceptual foundation for contemporary practitioners' thinking about the complex nature of boundary crossings and boundary violations. Since then, behavioral health professionals—including social workers, psychologists, psychiatrists, mental health counselors, marriage and family therapists, psychiatric nurses, and substance abuse counselors—have deepened their analyses of potential and actual boundary challenges (Celenza, 2007; Reamer, 2021a; Syme, 2003; Zur, 2017). Until recently, the scholarly literature on boundaries and dual relationships presumed that the practitioner and client engaged in traditional face-to-face professional encounters and communicated in person. For example, the literature is filled with discussions of sexual boundary violations that developed between clinician and client that had their origins in their intense psychotherapeutic discussions that occurred in the clinician's office (Celenza, 2007; Lazarus & Zur, 2002; Peterson, 1992; Reamer, 2003, 2021a; Syme, 2003). Recently, however, newer forms of boundary crossings and boundary violations are emerging as a direct result of social workers' increasing use of digital and other technology to serve and communicate with clients (Reamer, 2017, 2021b). Practitioners' remote contact with clients, via technology, has created new opportunities for boundary confusion (Reamer, 2021a). As with longstanding boundary issues that first emerged before the advent of digital technologies, these newer forms that have emerged in the digital age have great potential to harm clients and imperil social workers' careers if these lead to boundary confusion and inappropriate dual relationships. Remote, online, and electronic contact— including social workers’ greatly expanded use of distance counseling services—has led to unprecedented uncertainty and ambiguity about the elasticity of professional boundaries, including questions about the appropriateness of electronic communications outside of normal working hours and outside the office setting. According to Drum and Littleton (2014), "because the client and clinician are now capable of communicating through means typically reserved for social and personal interactions with family and friends (e.g., through e-mail, instant-chat, and video conferencing), telepsychology interactions can occur at any hour of the day or night, and both parties can now virtually enter each other’s homes, there is the potential for an increased sense of intimacy between client and therapist which could lead to boundary challenges" (p. 310). Social workers’ use of HIPAA-compliant software may limit social workers’ access to high-risk technologies in the workplace and prevent confidentiality breaches, but it does not necessarily prevent the introduction of complex boundary issues. Current social work services include a wide range of digital and electronic options, including online, telephone, text-based, video, email, and avatar counseling (Barsky, 2017; Barak & Grohol, 2011; Chester & Glass, 2006; Finn, 2006; Graffeo & La Barbera, 2009; ADVANCES IN SOCIAL WORK, Summer/Fall 2023, 23(2) 378 Gutheil & Simon, 2005; Kanani & Regehr, 2003; Kolmes & Taube, 2016; Lamendola, 2010; Lannin & Scott, 2013; Menon & Miller-Cribbs, 2002; Midkiff & Wyatt, 2008; Mossman, 2012; Reamer, 2021a; Recupero & Reamer, 2018; Santhiveeran, 2009; Zur, 2017). Digital and online communications with clients may be appropriate in some contexts (for example, coordination of services in case management and peer support programs) and inappropriate in others (for example, protracted informal evening online chats between a clinical social worker and her psychotherapy client). These newer forms of service delivery provide novel opportunities for boundary challenges. In addition, social workers' and clients' pervasive use of social networking sites and online search engines, such as Facebook and Google, have also created new boundary-related issues. Boundary Issues in the Digital Age: A Typology Novel boundary and dual relationship challenges encountered by social workers in the digital age are appearing in three forms: ethical judgments, ethical mistakes that do not involve misconduct, and ethical misconduct (Herlihy & Corey, 2015; Reamer, 2021a; Zur, 2017). Although these patterns have been addressed previously in the context of traditional in-person professional relationships between social workers and clients (Reamer, 2021a), they have not been applied in-depth to social workers’ digital and remote or virtual relationships with clients. Ethical judgments In some instances, competent, principled, and well-meaning social workers find themselves faced with ethical decisions about whether and how to use technology in their relationships with clients, in light of potential boundary challenges. In these scenarios, social workers recognize that technology has the potential to enhance their delivery of services to clients—especially among those clients who have crises, live in remote geographic areas, cannot meet in person during a pandemic, or struggle with severe disabilities that limit their ability to travel. These practitioners must make deliberate ethical decisions about how to use technology in ways that maintain clear, ethical professional- client boundaries. Here are several (disguised) examples based on the author’s work as an ethics consultant and expert witness in licensing board cases and lawsuits filed against social workers: • A clinical social worker provided counseling services to a couple that was experiencing marital tension. One of the clinical issues the couple identified was their chronic distress about their lack of sexual intimacy. The social worker, who specialized in sex therapy, considered sending the couple an email message containing links to a number of websites that offer advice on ways to enhance sexual intimacy. The clinician was unsure about whether it was appropriate for her to send clients an online message containing sexually explicit material. The clinician realized that the clients would be able to forward the social worker's message to others electronically, and that other recipients might misunderstand the nature of the relationship and the purpose of the message. Reamer/BOUNDARY ISSUES 379 • A social worker terminated counseling services he had provided to a client who was coping with the death of his teenage daughter. Fourteen months after the termination of services, the social worker received a Facebook “friend” request from the former client. The social worker was unsure about whether it is ethical to become Facebook friends with a former client. • A social worker counseled a sixteen-year-old teen who was struggling with depression and sexual orientation issues. During one session, the teen talked with deep emotion about the intense distress in her life. Later that night, around 10:30 p.m., the social worker decided to search the client’s Facebook site to see whether there was any evidence of suicidal ideation in the teen’s online postings. The social worker was concerned about several postings, sent the client private Facebook messages inquiring about the client’s emotional state, and exchanged online messages with the teen for nearly two hours. Ethical Mistakes Some competent, principled, and well-meaning social workers have found themselves accused of inadvertent technology-related errors that created boundary problems in their relationships with clients. Some of these errors, which do not involve blatant misconduct, have led to licensing board complaints and lawsuits filed by disgruntled clients or third parties. Here are several actual examples: • A social worker received an unsolicited Facebook request from a client who had sought treatment for her struggles with depression. The client had searched for the social worker’s Facebook site and discovered several of the social worker's postings about his recent divorce. The social worker thought he understood how to use Facebook's privacy settings to limit access to such postings to his closest friends. However, the client was able to access many of the social worker's postings about his personal relationships. Before the social worker blocked the client's access to his Facebook site, the client had sent the clinician a series of flirtatious, intrusive, and intimate Facebook messages about the social worker's personal life. Because of these boundary complications, the social worker decided to terminate the clinical relationship, against the client's wishes, and refer the client. The client became enraged and filed a licensing board complaint alleging that the social worker had abandoned her. • A social worker employed in a public child welfare agency provided services to a mother who allegedly neglected her children. The social worker was frustrated with the mother who, according to the social worker, frequently cancelled appointments and did not follow through with the social worker’s recommendations. One evening the social worker vented her frustration with this client on the social worker’s personal Facebook site. The social worker did not identify the client by name, but did include some case-related details. Shortly thereafter, the mother conducted an online search for information ADVANCES IN SOCIAL WORK, Summer/Fall 2023, 23(2) 380 about the social worker. The mother came across the social worker’s Facebook site, access to which was not limited, and read the social worker’s comments about the mother’s case. The mother was incensed and filed a licensing board complaint against the social worker alleging a breach of confidentiality. Ethical Misconduct As in all professions, some social workers—a distinct minority—engage in ethical misconduct. A disturbing percentage of misconduct cases involve boundary violations of a sexual nature (Celenza, 2007; Reamer, 2015, 2023; Syme, 2003). Social workers' use of technology has expanded the ways in which unscrupulous social workers can engage in sexualized relationships with clients. In some instances, the unethical conduct is limited to online communications. In others, electronic communications are a prelude to a sexual relationship. In some cases, evidence suggests that electronic communications were part of a deliberate, calculated effort by social workers to groom clients for an eventual sexual relationship. Here are several actual examples: • A social worker at a prominent outpatient mental health clinic provided counseling services to clients with co-occurring symptoms (substance use and mood disorders). Most of his clients had trauma histories that contributed to their challenges. Over time, the social worker engaged in sexual relationships with two of his clients. One of the clients disclosed the relationship to the police after the social worker suddenly ended their intimate relationship. The clinician's arrest was publicized in the local media, after which the second client disclosed her sexual relationship with him. The social worker was charged in criminal court and sued by the two clients. During the criminal and civil trials, the prosecutor and plaintiffs' attorneys introduced a collection of "electronically stored information" (ESI), including text messages and email messages between the social worker and his clients that included sexualized content, that provided compelling evidence of the social worker’s unethical conduct. The social worker—who was not aware that his electronic communications left a digital footprint—was convicted, sentenced to prison, lost his professional license, and was found liable for professional negligence. • A social worker provided counseling to a young woman who struggled with symptoms of depression and anxiety. During the course of the counseling the client ended a long-term romantic relationship. The client often talked about her intense loneliness. The social worker told the client that he could help fill the emotional void in the client's life. The social worker began sending text messages to the client, allegedly to check on her well-being. Over time, the text message exchanges between the pair became increasingly informal. On several occasions, the pair met for coffee. Eventually, they began a sexual relationship. The intimate relationship ruptured and the client filed a licensing board complaint. The board revoked the social worker’s license. Reamer/BOUNDARY ISSUES 381 • A social worker worked at a school sponsored by a mental health center. The school served adolescents who had difficulty functioning in traditional high school settings; all of the students struggled with behavioral health issues. The social worker spent most of an academic year counseling an eighteen-year-old student who became clinically depressed following the sudden death of his mother due to brain cancer. Over time, the social worker and student developed an intense emotional connection; at times the social worker shared with the student details about her marriage and children. The social worker encouraged the teen to text her for support when he was feeling despair. One day, the teen sent the counselor a text message in which he shared his "loving" feelings toward her. The social worker responded with her own text message that told the teen how much she cared about him and how special he was. Gradually, the social worker and teen spent time together away from the school and, eventually, engaged in sex. The teen's father disclosed the relationship to the school's director after discovering inappropriate text messages on his son's phone, including several graphic, explicit photos that the social worker and teen had exchanged ("sexting"). The principal fired the social worker and notified her licensing board. The licensing board revoked the counselor's license. Boundary Dynamics in the Digital Age Research suggests that, historically, there are several dynamics in boundary challenges that arise in social work and behavioral health (Herlihy & Corey, 2015; Reamer, 2021a; Zur, 2007, 2017). These include boundary issues related to intimate interactions between practitioners and clients; practitioners' own emotional and dependency needs; personal benefits to practitioners; practitioner altruism; and unanticipated circumstances. More recently, these dynamics—which can lead to inadvertent ethical mistakes, challenging ethical decisions, and ethical misconduct—have become evident in emerging boundary issues in the digital age. Intimacy Many dual relationships between social workers and clients involve an intimate component. The most extreme cases involve sexual contact (Celenza, 2007; Lazarus & Zur, 2002; Peterson, 1992; Pope & Bouhoutsos, 1986; Syme, 2003). Other intimate encounters include having physical contact (such as hugging or caressing), providing counseling services to a former lover, and accepting very personal gifts from a client. However, in the digital age, newer forms of intimate contact between social workers and clients are possible. These include online and other electronic messages and website postings (for example, on social networking sites) that contain very personal, intimate, and sexual content and images. Algorithms used by online social networking platforms may generate intimate-sounding messages among parties with similar interests and shared contacts (based on artificial intelligence), even when they are not initiated directly by a social worker or client. In addition, remote service provision using video may provide social ADVANCES IN SOCIAL WORK, Summer/Fall 2023, 23(2) 382 workers with opportunities to peer inside of clients’ homes and meet clients’ family members and acquaintances who happen to wander onto the screen during an otherwise private and confidential discussion. Clients may have an opportunity to peer inside a social worker’s home when practitioners serve clients remotely from their residence. This access may provide clients and social workers with information about each other’s personal lives that would not have been revealed during traditional in-person meetings; this can lead to boundary ambiguity and confusion (recognizing that such information sharing might also personalize their professional relationship in a positive way). Emotional and Dependency Needs Some boundary issues arise from personal issues in social workers’ own lives. What many of these circumstances have in common is that they are rooted in the social worker’s emotional needs, such as those stemming from childhood trauma, marital or relationship issues, health challenges, aging, career frustrations, or financial and legal problems. These various stressors can impair social workers’ judgment, which may lead to inappropriate dual or multiple relationships and boundary violations. Historically, one common manifestation has been social workers' inappropriate self- disclosure to clients during face-to-face counseling sessions (Barglow, 2005; Farber, 2006; Knox & Hill, 2003; Roberts, 2005; Stricker & Fisher, 1990). Although limited and judicious self-disclosure may be appropriate for therapeutic purposes, research suggests that social workers’ self-disclosure can be a prelude to sexual relationships with clients (Celenza, 2007; Gabbard, 1996; Gutheil & Simon, 1995, 2005; Reamer, 2021a; Simon, 1995; Syme, 2003). In the digital age, these disclosures are sometimes embedded in text messages, email messages, and online social networking exchanges between social workers and clients; some of this content may be introduced intentionally by the users, some may be generated by algorithms used by online social networking platforms, and some may be the product of default privacy settings that encourage the disclosure of information to known and unknown parties based on interest or proximity. The unique informality of online and digital exchanges can exacerbate boundary confusion and risks in ways that are less likely in traditional office-based encounters. Personal Gain Some dual relationships entail a personal benefit for social workers. Examples include social workers who receive services (for example, house painting or computer repair) or favors from a client (for example, use of a client's vacation villa). Social workers who communicate online with clients inappropriately may also experience personal gain, particularly when those online interactions are for social workers’ self-serving purposes, such as obtaining online advice from a client who has specialized knowledge (for example, medical advice) or linking clients electronically with products sold online by social workers (for example, herbal products or self-help manuals written by the social worker). Altruism Reamer/BOUNDARY ISSUES 383 Some boundary issues arise because of social workers’ sincere altruistic inclinations. Most social workers are dedicated, caring, and principled professionals who would never knowingly exploit clients (Reamer, 2023). Ironically, social workers who are extraordinarily kind and humane may unwittingly foster challenging dual and multiple relationships by engaging in informal online and other electronic communications with clients. Digital communications that begin quite innocently, perhaps to provide clients with emotional support and access outside of traditional office hours (including late-night online exchanges), can sometimes lead to intimate or other inappropriate exchanges. On occasion, altruistic gestures made electronically may be misinterpreted by clients and create boundary confusion. For instance, this can arise when social workers use short-video software such as TikTok or Instagram Reels to educate the public and clients on topics related to mental health, bystander interventions, sexual health, and relationship management (Javaid, 2023). Unanticipated Circumstances During the course of a career, many social workers encounter unanticipated, sometimes unavoidable, dual relationships. These are especially common when social workers live and work in small communities, such as rural areas or on military bases. Digital technology has produced novel and unprecedented opportunities for such inadvertent encounters. In one case, a social worker sought advice online from parents of children who struggle with a particular childhood disease. In her online posting, the social worker shared considerable personal details about her parenting struggles. Coincidentally, one of the parents who responded to the social worker was a current client. In another case, a social worker who specialized in treatment of anxiety symptoms posted several websites with resources for anxiety management. Unbeknownst to the social worker, several of the hyperlinks were hijacked and sent users automatically to pornography websites. Some users concluded that the social worker knowingly directed them to these websites. What is known as DNS (domain name server) hijacking is a type of malicious attack in which an individual redirects queries to a web-based domain name server by overriding a computer’s settings. This can be achieved through the use of malicious software or by modifying a server’s settings. Emerging Ethical Standards In recent years, social workers have embarked on development of rigorous and comprehensive standards pertaining to practitioners' use of technology to serve and communicate with clients. A number of these standards specifically address potential boundary crossings and violations. Recognizing the profound impact that technology is having on social work practice, in 2013 the Association of Social Work Boards (ASWB) board of directors appointed an international task force to develop model regulatory standards for technology and social work practice. ASWB developed these new ethics- related standards in response to requests from regulatory bodies around the globe for guidance concerning social workers' evolving use of technology and the ways in which ADVANCES IN SOCIAL WORK, Summer/Fall 2023, 23(2) 384 regulatory standards might be updated. The ASWB task force included representatives from prominent social work practice, regulation, and education organizations throughout the world. The group developed model standards, a number of which focus explicitly on boundary issues (Association of Social Work Boards, 2015). These model regulatory standards state that social workers who choose to provide "electronic social work services" shall, for example, "communicate with clients using digital and other electronic technology (such as social networking sites, online chat, email, text messages, and video) only for professional or treatment-related purposes and only with client consent" (standard 4.03); "refrain from soliciting digital or online testimonials from clients or former clients who, because of their particular circumstances, are vulnerable to undue influence" (standard 4.09); and "refrain from accepting 'friend' or contact or blog response requests from clients on social networking sites. Exceptions may be made when such contact is an explicit component of a treatment or service-delivery model and meets prevailing standards regarding the use of digital technology to serve clients" (standard 4.10). These model standards are now influencing the revision of licensing and regulatory laws around the world. In 2015, NASW appointed a task force to determine whether changes were needed in its Code of Ethics to address concerns related to the use of technology. The last major revision of the code was approved in 1996. Since 1996, there has been significant growth in the use of smartphones, tablets, email, texting, online social networking, monitoring devices, video technology, and other electronic technology in various aspects of social work practice. In fact, many of the technologies currently used by social workers and clients did not exist in 1996. In 2017, NASW adopted a revised code that includes extensive technology-related additions, a number of which specifically address boundary issues (National Association of Social Workers, 2017). Examples of boundary-related standards include "social workers should avoid communication with clients using technology (such as social networking sites, online chat, e-mail, text messages, telephone, and video) for personal or nonwork- related purposes" (standard 1.06[e]); "social workers should be aware that posting personal information on professional web sites or other media might cause boundary confusion, inappropriate dual relationships, or harm to clients" (standard 1.06[f]); and "social workers should be aware that personal affiliations may increase the likelihood that clients may discover the social worker's presence on Web sites, social media, and other forms of technology. Social workers should be aware that involvement in electronic communication with groups based on race, ethnicity, language, sexual orientation, gender identity or expression, mental or physical ability, religion, immigration status, and other personal affiliations may affect their ability to work effectively with particular clients" (standard 1.06[g]). Also in 2017, following unprecedented collaboration among key social work organizations in the United States—NASW, ASWB, Council on Social Work Education, and Clinical Social Work Association—the profession formally adopted new comprehensive practice standards, including extensive ethics guidelines that focus on social workers' use of technology (National Association of Social Workers, Association of Reamer/BOUNDARY ISSUES 385 Social Work Boards, Council on Social Work Education and Clinical Social Work Association, 2017). These transformational comprehensive standards address a wide range of compelling ethical issues related to social workers' use of technology, focused especially on practitioners’ use of technology to provide services to clients remotely, record sensitive information in electronic records, and communicate with clients electronically between appointments. A significant number of these state-of-the-art standards focus explicitly on boundary issues in the digital age. Examples include, "social workers who provide electronic social work services shall maintain clear professional boundaries in their relationships with clients" (standard 2.09); "social workers who use social media shall develop a social media policy that they share with clients" (standard 2.10); "social workers shall consider the implications of their use of personal mobile phones and other electronic communication devices for work purposes" (standard 2.11); and "social workers who work with communities and organizations shall ensure that they maintain appropriate boundaries when they use technology" (standard 2.19). The onset of the COVID-19 pandemic led to some temporary modification of federal rules concerning use of non-HIPAA compliant technology to enhance practitioners’ ability to serve vulnerable people when face-to-face services are not advised for public health reasons (U.S. Department of Health and Human Services, 2021). This policy change may lead to more elastic online boundaries in practitioners’ relationships with clients. For example, in 2020 the federal Office for Civil Rights in the U.S. Department of Health and Human Services, which oversees HIPAA compliance, promulgated a policy that stated “OCR will exercise its enforcement discretion and will not impose penalties for noncompliance with the regulatory requirements under the HIPAA Rules against covered health care providers in connection with the good faith provision of telehealth during the COVID-19 nationwide public health emergency. This notification is effective immediately. A covered health care provider that wants to use audio or video communication technology to provide telehealth to patients during the COVID-19 nationwide public health emergency can use any non-public facing remote communication product that is available to communicate with patients. OCR is exercising its enforcement discretion to not impose penalties for noncompliance with the HIPAA Rules in connection with the good faith provision of telehealth using such non-public facing audio or video communication products during the COVID-19 nationwide public health emergency. This exercise of discretion applies to telehealth provided for any reason, regardless of whether the telehealth service is related to the diagnosis and treatment of health conditions related to COVID-19.” Although this rule modification has expired, it provides a compelling example of shifting norms related to technology use. Implications for Practice: Risk Management in the Digital Age Social workers who violate boundaries in conjunction with their use of digital and other technology, whether unintentionally or intentionally, can cause great harm to clients and expose themselves to the risk of litigation, licensing board complaints, and criminal charges. Disgruntled clients may file a lawsuit against their social worker alleging ADVANCES IN SOCIAL WORK, Summer/Fall 2023, 23(2) 386 professional negligence or file a licensing board complaint alleging violation of ethical standards adopted by the board. In extreme cases, social workers may be charged in criminal court because of their conduct involving boundaries. Criminal codes in a number of jurisdictions consider sexual relationships between a mental health professional and client a felony. Social workers' sexualized email messages, text messages, postings on social networking sites, and other electronically stored information may be introduced as formal evidence against them. Social workers who engage in unethical conduct involving digital and other electronic communications fall into two groups (Reamer, 2021a; Zur, 2017). First, some social workers find themselves immersed in boundary confusion unwittingly and without malice. Their elastic sense of boundaries leads them to engage in informal, chatty, seemingly innocuous online and electronic communications with clients. These may include after- hours exchanges that resemble messages shared between friends about personal challenges, social events, recreational activities, restaurant visits, vacations, and family intrigue. These practitioners often have the capacity to learn from their boundaries-related mistakes, especially when their attention has been heightened after being named as a defendant in a lawsuit or a respondent in a licensing board complaint (Reamer, 2023). With the benefit of competent ethics consultation and continuing education—which are frequently required as elements of a licensing board resolution—these social workers are often able to gain impressive insight and move on to productive careers once they resolve the formal complaint. The second group, however, includes a much more challenged and challenging group of social workers. These practitioners are exploitative and use clients to meet their own needs. Nontherapeutic and unprofessional electronic exchanges with clients are often a deliberate, calculated, and self-serving effort to groom vulnerable clients, luring them with cleverly worded, seductive messages of endearment, support, and praise (Reamer, 2023). Some social workers who groom clients via online and digital exchanges struggle with impairment. Research on impairment among professionals suggests that many struggling practitioners do not seek assistance, and colleagues who are concerned about them may be reluctant to share their concerns (Kilburg et al., 1988; Reamer, 2021a; Sonnenstuhl, 1989). Some impaired social workers may find it difficult to seek help because of their mistaken belief in their competence and invulnerability; they believe that an acceptable therapist is not available or that therapy would not help; they prefer to seek help from family members or friends or work problems out by themselves; they fear exposure and the disclosure of confidential information; they are concerned about the amount of effort required and about the cost; they have a spouse or partner who is unwilling to participate in treatment, or they do not admit the seriousness of the problem; or they believe that they should be able to work their problems out by themselves. Licensing boards and professional associations that discipline social workers who violate boundaries (including digital and online boundary violations) sometimes encourage or require them to enroll in therapeutic programs designed specifically to treat impaired practitioners (Schoener, 1995; VandenBos & Duthie, 1986). Reamer/BOUNDARY ISSUES 387 On occasion, social workers become aware of a colleague's inappropriate use of technology in their relationships with clients. For example, they may receive reports from clients about a colleague’s inappropriate online conduct during a prior counseling relationship with that social worker or from third parties who know of social work colleagues' salacious Facebook postings. According to current ethics standards in social work, when feasible social workers who learn of colleagues' unethical online conduct should approach them for frank discussion about the behavior and its implications, as mandated by the NASW Code of Ethics (standards 2.08 and 2.10). Social work supervisors, especially, should broach these issues when they arise and address them directly, using what Sonnenstuhl (1989) describes as "constructive confrontation" (p. 533). One practical way to reduce the risk of boundary problems arising out of social workers' and clients' use of technology is for practitioners to develop a social media policy that practitioners review with clients. Social media policies inform clients about their social worker's professional use of social networking sites, email, text (SMS) messaging, electronic search engines, smartphone applications, blogs, business review sites, and other forms of electronic communication (Kolmes, 2010). A typical social media policy informs clients that their social worker cannot be their "friend" on social networking sites (such as Facebook or LinkedIn) and why this is important in order to maintain clear professional boundaries. Such policies also set limits on practitioners' and clients' use of text messaging and emails. Further, social workers should develop keen instincts about when they should consult with knowledgeable colleagues and supervisors about ambiguous boundary challenges, especially those related to sexual boundaries. Practitioners’ malpractice insurers and, for NASW members, NASW’s Office of Ethics and Professional Review and chapter offices also can offer practical guidance. When necessary, social workers should consult an attorney who specializes in defending social workers in malpractice and licensing board matters. Conclusion Boundary challenges in social work have existed throughout the profession’s history. The widespread use of digital technology has introduced novel and unprecedented opportunities for boundary challenges. Informal, casual, and spontaneous online and digital communications between social workers and clients—in the form of text messages, email messages, online postings, and instant messages on social networking sites—can lead to a loosening of what would otherwise be firm boundaries in the professional-client relationship. The fact that digital and other electronic communications can occur so easily outside of customary work hours and the controlled context of office-based services can lead to uncertainty and confusion about the nature of their relationships. Some social workers engage in extracurricular electronic communications with well- meaning intent, perhaps to enhance clients' access to services and to offer emotional support to clients during times of crisis. What may begin as truly innocent communications may lead to boundary ambiguity and, ultimately, inappropriate contact, both in person and remote. In extraordinary instances, unscrupulous social workers use online and electronic ADVANCES IN SOCIAL WORK, Summer/Fall 2023, 23(2) 388 communications with clients as a manipulative tool, and as a calculated grooming strategy designed to seduce clients. To enhance social workers’ understanding of boundary challenges in the digital age that can lead to ethical mistakes, nuanced ethical judgments, and ethical misconduct, social work educators can add content on boundary issues in the digital age to curricular offerings on ethics and field placement supervision. Further, continuing education programs can feature presentations on these emerging and challenging issues. In addition, it is imperative that social work scholars undertake empirical research on boundary issues in the digital age, focusing especially on various manifestations, social workers’ ability to recognize these issues when they emerge and understanding of pertinent ethics standards, and practical strategies designed to prevent boundary confusion and violations related to technology use. The digital age has brought with it many impressive benefits for both clients and social workers. Digital technology has greatly expanded clients’ access to services, broadened social workers’ service delivery options, and facilitated out-of-office communication. Yet, these developments have also generated unprecedented boundary-related risks and challenges. To protect clients and themselves, social workers must be alert to potential risks, earnest in their efforts to learn about the responsible use of technology, and diligent in their efforts to prevent boundary confusion. 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