I have had therapy sessions over the phone as well. It's still protected. However, what's on a voicemail may not be. I simply do not know.

What I do know is that when a client expresses some concern over a practice, then I do think the therapist should say *something* about it. Either "I can't change it" or *something*.

It may turn out that voicemail is an unusual case that isn't covered by HIPAA, I don't know, but some response, I think, should come from the therapist.