COVID-19: Telehealth Across State Lines & International Borders?

UPDATED 5-3-2020

COVID-19 has changed many aspects of inter-jurisdictional telehealth practice. Dramatic and sweeping changes are occurring almost weekly. TBHI will keep you up-to-date here and in its professional telehealth training coursework. (For a quick overview in video-training form, register for this FREE Webinar-on-demand.)

As always, formal permission for inter-jurisdictional practice depends on where you hold a license and your profession. Practicing across state, provincial and/or international borders has not only been possible for decades but fully legal, ethical, and clinically sound, IF you understand and follow the rules. 

Traditionally the process involved getting records from your academic institutions, supervisors, licensing board and in some cases, paying fees. Then, waiting for weeks or months for it all to come together before submitting to a foreign licensing board for review. That final review process would often require yet more weeks or months, and more fees before approval to practice telehealth across state lines.

In the time of COVID-19, we have seen dramatic changes.

State-Specific Changes because of COVID-19

Many states have been allowing licensed professionals from out-of-state to serve their citizens by registering with the local state licensing boards. This process is known as “registration” and started decades ago with practitioners requesting permission to physically travel into foreign states to work. This same process has been in place for telehealth practitioners all along. TBHI has offered training in how to legally practice over state lines for more than a decade, with regular updates every two years.

In 2019, Florida took a much more dramatic step for telehealth by allowing any licensed professional in good standing with their own board to register with the state after arranging for a local agent to be their representative. For details, see this TBHI post: Florida Telehealth Out-of-State Registration Application Now Available.

Since COVID-19, more than 40 states allow their citizens to be served by practitioners from other states. To find out if a state is participating in this waiver of state rules for COVID-19, visit the state board of interest for your profession, and look for a “Waiver” or “Affidavit” to sign as an out-of-state licensee. See the Kentucky Department of Professional Counseling for an example. You may also look at this Center for Connected Health Policy’s handout, which outlines recent updates (April 30, 2020) to licensing codes for many states. Their COVID state web page can also be quite helpful.

Check Your Malpractice Insurance

You may want to check with your malpractice carrier to be sure that you are covered if you volunteer to practice over state lines. There may be important malpractice nuances that only your carrier can explain. It is also wise to assume that different carriers will have different nuances.

Physicians & the Interstate Medical Licensure Compact for Telehealth Across State Lines 

For physicians, the Federation of State Medical Boards (FSMB) has been visibly active in developing a Model Act. The act helps physicians gain access to cross-state and provincial licensure and registration through their Interstate Medical Licensure Compact (IMLC). The Compact offers a voluntary expedited pathway to licensure for qualified physicians who want to practice in multiple states.

The FSMB received a grant from the Office for the Advancement of Telehealth (OAT). Then the FSMB crafted a model act that leads to the expedited transfer of documents between states after physicians meet IMLC conditions.

Designed to increase access to health care for patients in underserved or rural areas, the IMLC’s goal was to allow physicians to more easily connect with medical experts through the use of telehealth across state lines.

The IMLC application process is expedited during COVID-19 by leveraging the physician’s existing information previously submitted in their state of principal license (SPL). The SPL verifies the physician’s information, then conducts a fresh background check. Once qualified, the Physician may practice in any number of other Compact states.

Psychology Interjurisdictional Compact (PSYPACT)

Psychologists have also made headway toward inter-jurisdictional practice. Known as the Psychology Interjurisdictional Compact (PSYPACT), the psychologist’s Model Act involves an interstate compact designed to facilitate the practice of telepsychology and the temporary in-person, face-to-face practice of psychology across state lines.

A commission was formed and met in the summer of 2019 to define the Bylaws and Rules and Regulations under which psychologists would be allowed to apply and work in states who formally accept the PsyPACT Model Act as state law. According to the PSYPACT website, to date, 15 states have done approved the PSYPACT, but the PSYPACT Commission has not yet finalized the Rules needed.

ASPPB has acted swiftly to gather information from its member licensing boards and made the results of their work available through their website. The reader is directed to the ASPPB page that describes current COVID-19 activities and the ASPPB commitment to provide COVID-19 updates regularly as they develop.

That page also provides links to these COVID-19 related documents, which may be of use to the reader:

Other Movement by Counseling and Other Behavioral Professions for Telehealth Across State Lines?

During COVID, professional counselors may want to check the American Counseling Association’s blog for details about the interstate practice. TBHI is not aware of activity along these lines by any other associations, even during the COVID-19 crisis. So, if you can help shed light on these issues with regard to your profession, please comment below. We will update this page as more information is available.

Your TBHI Professional Training Options

TBHI specializes in teaching you how to relax when delivering telehealth.  It offers you a step-by-step learning path of online training that helps you be legally and ethically compliant, clinically proficient, and able to handle even the most difficult of clinical scenarios. Take advantage of COVID discount pricing to learn how to sit back and enjoy your telehealth experiences, rather than struggling with ZOOM fatigue and clinical uncertainty. All courses are evidence-based, available 24/7 through any device and most count toward legal and ethical requirements for licensure. Two micro certifications are also available.

    1. Telehealth Group Therapy  — Exciting, highly interactive telehealth learning experience designed to get answers to your questions about legally and ethically managing telehealth group therapy. Digital class will allow you to connect with colleagues ahead of time to ask questions and share answers. Distinguished faculty will lead you through telehealth group therapy theory and exercises.
    2. Telehealth Clinical Best Practices Workshop — Live, interactive webinar, w/ 4 CME or CE hours to discuss preventing and handling complex clinical issues.
    3. Course Catalog
    4. Micro Certifications to give you a broader range of legal and ethical grounding, and allow you to distinguish yourself as a TBHI-credentialed professional on your websites, in social media, directories and other areas.

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21 comments on “COVID-19: Telehealth Across State Lines & International Borders?

  1. I am a Licensed Professional Counselor (Texas) and I am living in France. Is it possible to do counseling sessions while I am here?

    • Cathy – Kudos to you for wanting to help. You may want to start by contacting your board in Texas, as well as the board(s) for your profession in the state(s) that you’d like to serve. If you seek insurance reimbursement, you may also want to check with the payor(s) too. There are many waivers right now, but it is always best to talk directly to the boards and the payors.

      You may also want to re-read the blog above because it is regularly updated with new information that might be of help.

      • I practice telehealth for pediatric sleep medicine in CO. My husband and I would like to get in our RV and travel around the country. I can’t see why it would be a problem to use my “mobile office” to see patients. After all, I am licensed in CO and I am treating my patients who reside in CO. What do you think?

        • D. Neal, the major problem would be consistency of bandwidth. There are workarounds, and you will need to know them well. Many hotels and campgrounds say they have internet connections, but they usually are not strong enough if they work at all. It is possible though.

  2. I am a LCSW in Florida and. I was able to contact the social work board in SC so that I could see one of my patients there and was given authorization for 60 days

  3. In Florida any licensed health professional can get a certificate to do teletherapy. This legislation was passed last year. There’s no charge or renewal fee. You have to have your board submit a paper verification form and you need to have a place in Florida where they can send stuff if someone complains against you. Both of these are small fees. It took me a couple of weeks to get it and that was before the pandemic. I suspect that other states will want to adopt this model in the future, especially now. No special training required and only licensed people in good standing. You can not also do a physical practice in Florida.

    Karin Wandrei, LCSW
    Florida Out-of-State Telehealth Provider #45

    • Karin,

      Thank you for your comment. Yes, Florida has led the way with its 2019 progressive and wide-sweeping legislation. Many states have adopted an even more minimalistic “affidavit” process during COVID, and I hope thy follow Florida’s lead after COVID. It would be interesting to see the outcome data related to Florida’s progressive experiment. Let us know if you hear any related news.

    • Robert,

      Licensed professionals generally can offer services in the US, but there are limits by licensing boards that you may want to investigate and document. Also, other issues may be involved. For example, billing for Medicare is illegal from aboard. Enjoy your travels!

  4. Hello Dr. Maheu, I am a psychologist in Oregon. A client of mine is moving to Taiwan for 3 years, and has requested we continue therapy while overseas. Is it possible to treat someone living in Taiwan while I’m living in the US? I have tried reaching out to the local board here without much luck as well as to the APA.

    Any thoughts of advice is very much appreciated.

    Thank you!

    • Jill,

      It most certainly can be frustrating to wait for word from a licensing board. I’d suggest a few things:

      1) Send an email to your board. Colleagues report that email is the fastest way to communicate – but then again, that still can take weeks, and in some cases, months. It is important to do, however, because it establishes that you are seeking the guidance of informed peers.
      2) Also, send the same letter to ASPPB – the Association for State and Provincial Psychology Boards – the association for all psychology regulators. Their CEO was our guest speaker last summer for a webinar here at TBHI. We discussed a variety of issues related to legally practicing over state lines. The fact is, it can most certainly be legal to practice internationally, but you really need to know how to do it. See our quick webinar on-demand on our list of on-demand courses here at TBHI. Be sure to select the one labeled (for psychologists). The list of TBHI’s individually available courses is here. We are available for consultation if you need more specific help.

  5. Hello Dr. Maheu, I am a psychiatric nurse practitioner providing Telehealth to all my patients during the pandemic. Since the pandemic started I have had a few patients that have moved out of Maryland, the State where I have my license. I know there are certain exception guidelines during this pandemic, but another question I had was if I have already established a relationship with these patients in my State can I continue to treat them in their new State?
    Thank you,


    • Lisa, I answered Felicia a few moments ago, so I will paste my response here in case you miss it:

      To practice legally over state lines, licensed professionals in the United States have to inform all involved boards in writing for your particular profession at all times. To my knowledge, there are no exceptions to those rules, but if anyone here knows of one, please comment. It is easy enough to go to the board’s website in a foreign state and either contact them by email or look around to see if you can find their position statement about licensed professionals working in their state with a foreign license.

      During COVID, you do that by going to the board for your profession in whatever state and look for an “affidavit” to sign. The vast majority of states now have approved this simple registration process during the emergency.

  6. I am a Licensed Professional Clinical Counselor in California. A client, an American citizen is temporarily moving to BC, Canada. The BC counselor’s association basically told me to check w my state agency. Any more thoughts on American therapists doing teletherapy with folks situated in Canada?


    • Shelley,

      You went to the association, which probably has nothing to do with licensing. People answering the phone are also not reliable sources because they may or may not know telehealth answers. In Canada, licensing boards are called Colleges. You may want to contact the Collge for your profession in BC and ask them what is needed to work in their province. Send them an email so that you have a written statement. People tend to give information when they have to write it down, and you will then have a document to put into your patient or client file if questioned.

    • Hello Shelley,
      We are in a similar situation. Were you able to find anything out that enables you to continue working with your client who is relocating to BC from California?
      Thank you so much, Verna

      • Verna, You may want to see the responses that other people have obtained above for this type of issue. Bottom line, contact all licensing boards involved, and do it in writing, preferably email. Only they can give you definitive answers, but more than likely, you are fine to practice in most states if you complete an affidavit in the foreign state.

  7. Marlene,

    I am licensed in Maryland for professional counselling. A former client will be returning to Maryland after living abroad in Jordon for a year. She wishes to begin counseling sessions again which due to the pandemic I am providing via a tele-mental health platform. Flight delays have delayed her return to a day or two after our first scheduled session in this renewal of services. Out of an abundance of care, I have searched the web to see if I can find regulatory information regarding the delivery of counseling services to folks in Jordon and I cannot find any relevant information. Before I tell my returning client she must wait until she touches down in Maryland to begin remote counseling services with me again, I wondered if you can direct me to a resource that might inform me of the legality of briefly providing those remote counseling services while she is still in Jordon.

    • Susan, Contact your licensing board in writing. Most board reply to email within a few days. Don’t listen to anyone else but your board. Everyone else is guessing. Only your board knows what they want, and it can be quite different from other boards.

  8. I am a physician licensed in Virginia. I will in Florida during the winter (2 months). I wish to continue seeing Virginia patients during this time. I have not been able to get a straight answer from either Boards and have conflicting answers from colleagues. Does anyone know what I need to do? Thanks.

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