Bottom line
Email Counseling and phone discussion are valid as counseling session as long as you have complied with all counseling requirements and the chain of command has approved this type of counseling due to geographical separation or other issue that prevents face to face counseling.
Discussion
If we are talking about performance counseling for an evaluation report. It is mandatory to use the DA FORM 2166-8-1. The use of a DA FORM 4856 is optional and I highly recommend it but it is not a mandatory requirement.
However if there is geographical separation then phone calls can be used as an alternative. See extract below.
You could have a phone conversation, and send an DA FORM 2166-9-1 and DA FORM 4856 scanned to the Soldier in an email. Then review the documents in a phone conversation and state in the DA FORM 4856 that the counseling was conducted via phone while the Soldier reviewed the documentation on the phone with you. Then have the Soldier sign and scan a copy of all documents back to you and put the originals in the mail back to you. When you travel to the location the Soldier is at or vice versa you could simply write in the assessment block of the DA FORM 4856 something like: “Conducted follow-up with Soldier in a face to face discussion as required by AR 623-3”.
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I believe the specifics of your situation need to be evaluated by your chain of command. If you have their support there should be no problem. Face to Face counseling is important and required but there are times in today’s Army when face to face is difficult to achieve based on location and geographical separation. If you do everything you can to properly counsel a Soldier using all possible tools and your chain of command approves your process odds are you will not have a problem.
Now lets discuss event oriented counseling session. They will be conducted on a DA FORM 4856 and may require a continuation of counseling form if it cannot fit on the form alone. In addition for an event oriented counseling to be valid and complete it must have an assessment completed.
You might also want to review the following post:
Can email be used to document counselings?
Can my rater counsel me by phone and email?
On a separate note I would encourage you to read chapter 3 of the new AR 623-3 as it contains step by step instructions that many raters overlook including the requirement for the rater and senior rater to provide copies of their support forms to the rated Soldier.
You may also want to consider buying a copy of The Evaluator (a Book written by me…Sorry could not resist). It has just been updated to comply with the new AR 623-3 and DA PAM 623-3. It is available for presale at: MentorMilitary.com In all fairness it does have some great information in it.
EXTRACTS OF AR 623-3
3–6. Rated Soldier
The rated Soldier (officer or NCO) plays a significant role in counseling sessions and the evaluation process throughout the rating period. In the event of geographical separation, correspondence and telephone conversations will be used as alternatives to face-to face counseling followed by face-to-face discussions between the rated Soldier and the rater at the earliest opportunity.
3-6b(3) End of the rating period. Rated NCOs will not prepare their own final DA Form 2166–9–1A but may provide input to rating officials to assist them with completion of the final DA Form 2166–9–1A. Dates of the initial and follow-up discussions from the working copy of DA Form 2166–9–1A will be reentered with initials on the final copy of the DA Form 2166–9–1A (see DA Pam 623–3 for procedural guidance). The final DA Form 2166–9–1A will be
considered by rating officials in preparing NCOERs
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