Is it legal to use a photo of an insurance card as proof of insurance?

Even if she had the card, the card can't be used as "proof" that a person still has insurance. It only proves that a person had insurance when the card was issued. The coverage could have ended later.

She can use the photo of the card for anything that she could do with the actual card, if she still had it, but not as proof that she is still covered now.

If the counselor needs to know that she is still covered now, then the counselor will need to confirm that with the insurance company.

Sure. It's the information that's important, not the physical card. I've had providers give me a hard time, but it's rather ridiculous if they do, especially if you have physical ID.

That is up to the discretion of the care provider your roommate chooses. She should ask them before she schedules her first appointment.

Why doesn't she just call her insurance company and have them send her a new card?

No. Why doesn 't she just call her insurance agent and ask for a replacement? Good thing she does not build rockets.

She can use the photo and they will call to confirm that coverage is active. They don't have to accept it, but the likely will.

Yes, it's "legal." It's up to the provider whether it will accept it.

Yes, it's legal. She can also log in to her account, or print out the file.

Not in my region. It just gets the vehicle impounded

and a three day limit to submit the actual document

Possibly as long as the provider can get a copy for their billing records.

Not always. if her card has a magnetic strip on the back, nothing else will do.