(2 DAY WEBINAR) MH Professionals’ Duty to Warn about Risk of Patient-Inflicted Harm in Pennsylvania

CE Type:APAForensic SeriesIACETSW

# of CE's: 6.0

0.6 IACET CE's

CE Type: SW, IACET, APA            # of CE's: 6.0 CE's      0.6 IACET CE's


About This Course

In Tarasoff v. Regents of the University of California, the California Supreme Court held that mental health professionals owe a duty to warn or protect third parties of threats made by individuals they serve. Over the past 45 years, courts and legislatures across the country have adopted rules recognizing similar duties in most of the United States. This includes the Pennsylvania Supreme Court in Emerich v. Philadelphia Center for Human Development in 1998. In July of 2020, the Pennsylvania Supreme Court’s decision in Maas v. UPMC Presbyterian Shadyside significantly modified the boundaries of this duty. This training describes the history of mental health professionals' duty to warn, analyzes the factors that courts consider in reaching decisions on "duty to warn" cases, and highlights important considerations for mental health professionals in responding to the new rule articulated in Maas.

Learning Objectives: 

  1. Describe the history of mental health professionals' duty to warn in the United States and in Pennsylvania specifically.
  2. Describe the legal and factual principles underlying court decisions on duty to warn.
  3. Develop a plan for clinical policy and practice in light of Maas, including communication with legal counsel.


Intended Audience: 

Provider Network


Instructional Level: 



Completion Requirements: 

Participants must attend the entire session, participate in all activities, and submit an evaluation within the 7 days of training to receive credits and a certificate. All CEU certificates and certificates of attendance will be received through the DBHIDS Learning Hub. Once you have completed your evaluation you will have access to your CEU or Certificate of Attendance through your DBHIDS Learning Hub Account.


Credit Statements:

BHTEN is accredited by the International Association for Continuing Education and Training (IACET) and is authorized to issue the IACET CEU.
As an IACET Accredited Provider, BHTEN offers CEUs for its programs that qualify under the ANSI/IACET Standard.  BHTEN is authorized by IACET to offer CEUs for this program.
(0.6 CEU = 6.0 Training Hours)

6.0 CE credit hours for Psychologists awarded.  BHTEN is approved by the American Psychological Association to sponsor continuing education for psychologists.  BHTEN maintains responsibility for this program and its content

Behavioral Health Training and Education Network BHTEN, #1779, is approved to offer social work continuing education by the Association of Social Work Boards (ASWB) Approved Continuing Education (ACE) program. Organizations, not individual courses, are approved as ACE providers. State and provincial regulatory boards have the final authority to determine whether an individual course may be accepted for continuing education credit. Behavioral Health Training and Education Network BHTEN maintains responsibility for this course. ACE provider approval period: 09/22/2021 – 09/22/2022. Social workers completing this course receive 6.0 continuing education credits.

Course Instructors

June 2, 2022

Kirk Heilbrun


Drexel University



Kirk Heilbrun, PhD is currently Professor in the Department of Psychology at Drexel University. He is board certified in clinical psychology and in forensic psychology by the American Board of Professional Psychology. He has a longstanding scholarly and applied interest in violence risk assessment and ethics, as well as a longstanding involvement in doctoral training and continuing professional education.

June 3, 2022

(2 DAY WEBINAR) MH Professionals’ Duty to Warn about Risk of Patient-Inflicted Harm in Pennsylvania