My T has told me she has a friend that saw a therapist who used to not do face to face things, and always do the "Freudian" type approach of sitting kind of behind/to the side. The patient has always wondered if he was paying attention/sleeping. One day, he started snoring. She walked out and told the receptionist she better wake him for the next patient.

My T has never fallen asleep. I have seen her tired/yawning, but never to the point that I really worried that I may lose her sleepy-by land.