Are Health Coaches Mandatory Reporters?
A mandatory reporter is someone who is legally required to report certain types of harm or abuse to the appropriate authorities where there is reasonable suspicion that such abuse or harm is occurring or where an individual has disclosed to them directly that such behavior is occurring.
The specific categories of harm that trigger a reporting obligation typically include child abuse, elder abuse, dependent adult abuse, and sometimes domestic violence or suicidal ideation. Mandatory reporting laws are enforced to protect vulnerable populations from harm by ensuring that professionals who interact with them report signs of abuse or neglect.
The exact scope of who qualifies as a mandatory reporter is defined by state law and varies significantly from one state to another. So, are health coaches mandatory reporters?
Scope of Practice
Before delving into this I want to make clear that health coaches should not be discussing issues like abuse, domestic violence, suicide, or other serious mental health crises with clients. This is beyond the scope of practice for health coaches. Health coaches are trained to provide guidance on wellness and lifestyle habits, and are not qualified or licensed to deal with these matters. Attempting to provide support on these sensitive topics could not only place your client at risk but could expose you to legal liability.
As a health coach you should establish clear boundaries with your clients regarding the scope of your services. Before even seeing a client it should be clear from your service agreement that you are not a licensed provider. (You can click here for documents that will ensure these boundaries are clear). However, if a client raises issues related to abuse, suicidal ideation, or other serious concerns, as a health coach you should:
Immediately communicate your boundary: Make it clear that this topic is beyond your scope of practice and you are not able to advise the client on these matters or discuss these matters with the client.
Recommend the client see an appropriate mental health professional: It is good to have a referral list of mental health professionals and social services resources available to provide immediate support.
While these topics are beyond your scope, it is still possible they may arise during a coaching session. So what are your obligations if they do?
California’s Landscape
In California, the law governing mandatory reporting is primarily found in the California Penal Code §11165.7 and §11156. These statutes specify who is required to report abuse, focusing on child and elder abuse. Professionals like teachers, healthcare workers, law enforcement, and members of the clergy are amongst the many different professionals who are considered mandatory reporters.
The key term here is "healthcare worker," and while health coaches may play a role in promoting health and wellness, they do not fall under the legal definition of a "healthcare provider" or "healthcare professional" in California.
California defines healthcare providers to include professionals such as licensed physicians, nurses, mental health professionals, and other licensed medical providers. Since health coaches are not licensed healthcare providers (unless they have a separate healthcare license like an RN or LCSW), they are generally not considered mandatory reporters under California law.
Exceptions:
Dual Licensure: If a health coach is also a licensed healthcare provider (for example, a registered nurse, licensed clinical social worker, or psychologist) with an active license, they are bound by mandatory reporting obligations as part of their licensure. It is important to note that while mandatory reporting obligations generally cease when an individual leaves the profession that required them to be a mandatory reporter—for example, a retired teacher—licensed healthcare providers remain mandatory reporters even if they are no longer practicing within the scope of their license.
Employment Context: If a health coach is employed by a facility or organization that designates them as a mandatory reporter under company policy, they may be required to report abuse as a condition of their employment, even if not legally mandated by state law.
Are Health Coaches Mandatory Reporters in Other States?
While most states do not list health coaches specifically as mandatory reporters, some states define mandatory reporter broadly enough that health coaches might be included. Below are a few key state-specific insights:
Texas: Texas Family Code § 261.101 requires any person with knowledge of child abuse to report it. This means that health coaches, along with all other citizens, have a legal obligation to report child abuse if they become aware of it. Unlike California, Texas’s "universal reporting" law applies to everyone, not just specific professions.
Florida: Similar to Texas, Florida Statutes §39.201 require every person in the state, regardless of profession, to report known or suspected child abuse. This means that health coaches, regardless of their professional classification, have a duty to report child abuse.
New York: In New York, mandatory reporters are specified under Social Services Law § 413. While the list includes healthcare providers, social workers, and school officials, health coaches are not explicitly listed. However, as with California, if a health coach is also a licensed healthcare professional, they would be required to report under their professional obligations.
Pennsylvania: 23 Pa. Cons. Stat. §6311 requires "health care professionals" to report suspected child abuse. Health coaches do not typically meet Pennsylvania’s definition of "health care professional" unless they hold a separate, relevant license (like nursing or mental health counseling).
You should always check your state laws to ensure you understand your obligations.
What Do I Do If I am Not a Mandatory Reporter?
If you are not a mandatory reporter, there are still some considerations to make regarding reporting:
Following Company Policy: If you are employed by a company that has internal policies on reporting abuse, you should follow those policies. Many health-related businesses, such as wellness centers and coaching platforms, implement internal guidelines requiring all staff to report abuse, regardless of their status as a legally mandated reporter.
Confidentiality Concerns: While you may feel an ethical obligation to report abuse or mental health concerns, you must balance this with your client confidentiality agreement. If you are not legally required to report, disclosing client information without consent could violate your agreement. You should always review your service agreements and privacy policies before taking action. If you would like the option of voluntary reporting, make sure you outline this in your agreements and ensure your client understands the implications prior to working together.
Voluntary Reporting: In states like California, where health coaches are not mandatory reporters, there is still the option to voluntarily report suspected abuse, for example, a report with Child Protective Services (CPS) or Adult Protective Services (APS) can be filed. However, if you do choose to report, you should be prepared to explain your reasoning and face questioning.
Final Thoughts
As a health coach, you should not be dealing with abuse and mental health matters with clients, as this exceeds your scope of practice. However, you should have a system in place to be prepared if it does come up and understand what your obligations are in your state. Whether you are a mandatory reporter or voluntarily reporting you should ensure your report is based on solid evidence or reasonable suspicion prior to reporting; making a false report could cause serious harm to your client and you could face expensive and detrimental litigation as a result.
