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

Looking for specialized legal and ethical training during COVID-19? You may be interested in the following.

To assist behavioral professionals seeking other evidence-based telehealth training to help deal with COVID-19, TBHI is honored to offer you these CME and CE-accredited programs at 50% off from the convenience of your desktop or digital device: 


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4 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.

  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

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