COVID-19: Can you practice teletherapy across state lines?

One of the many factors complicating our clinical work in the COVID-19 environment is cross-jurisdictional licensure.  During the age of COVID-19 can you continue teletherapy across state lines if your client now resides in a state where you’re not licensed?  If you’re a pre-licensed clinician (postdocs, interns, externs) who recently moved to another state, what services can you continue to provide?  And what do these circumstances mean for pre-licensed supervision hours?

As you may know, when a client and clinician are located in different states, each state has jurisdiction over the therapeutic relationship. Of course, multiple states means multiple regulatory systems, many of which are in flux during this time. In some cases due to the COVID-19 emergency, states have eased requirements, allowing all licensed mental health clinicians in good standing to practice teletherapy across state lines. In other cases, states require clinicians to apply for permission to practice in-state. And, in a number of other states, clinicians continue to be required to be licensed where they’re located and where the client is located.

To help navigate these waters, we’ve prepared a chart summarizing licensure requirement changes for medical and behavioral health providers on a state-by-state basis. We also included a link to each state’s COVID-19 resource page.

Changes to Licensure Requirements for Out-of-State Providers

State Medical Health ProvidersBehavioral Health Providers Citation  State Health UpdatesAdditional Information
AlabamaYesYesEmergency Declaration Resource Page Emergency Services Code
AlaskaNoNoEmergency DeclarationResource Page
ArizonaYesYesEmergency DeclarationResource Page
ArkansasNoNoEmergency DeclarationResource Page
CaliforniaYesYesEmergency Declaration Resource Page FAQ Trainees & Telehealth
ColoradoYesYesDepartment of Regulation Affairs Guidance Resource Page
ConnecticutYesYesExecutive Order Resource Page
Delaware YesYesDepartment of Health Order Resource Page
District of ColumbiaYesYesEmergency Declaration Resource Page Waiver of Licensure
FloridaYesYesDepartment of Health Emergency Order Resource Page
GeorgiaYesNoEmergency Declaration Resource Page Emergency Temporary License Application
HawaiiYesNoEmergency Declaration Resource Page
IdahoYesNoBoard of Medicine Declaration Resource Page Emergency Temporary License Application
IllinoisYesNoEmergency Declaration Resource Page Out of State Temporary Permit
IndianaYesYesEmergency Declaration Resource Page
IowaYesNoBoard of Medicine Emergency Declaration Resource Page
KansasYesYesEmergency Declaration Resource Page Temporary Permit Application
KentuckyYesNoExecutive Order Resource Page Medical Licensure Instructions
LouisanaYesYesEmergency Declaration Resource Page
MaineYesNoExecutive Order Resource Page Emergency Temporary License Application
MarylandYesYesHealth Care Executive Order 
Resource Page
Emergency Temporary License Application
Mass-achusettsYesYesEmergency Declaration Resource Page Emergency Temporary License Application
MichiganNoNoExecutive Order Resource Page
MinnesotaNoNoEmergency Declaration Resource Page
MississippiYesNoEmergency Declaration Resource Page Board of Medicine Declaration
MissouriNoNoEmergency Declaration Resource Page
MontanaYesYesEmergency Declaration Resource Page Emergency Temporary License Application
NebraskaYesYesExecutive Order – Healthcare WorkersResource Page
NevadaNoNoEmergency Declaration Resource Page
New HampshireYesYesEmergency Declaration Resource Page
New JerseyYesYesAttorney General Guidance Resource Page Emergency Temporary License Application
New MexicoYesYesEmergency Declaration Resource Page
New YorkYesNoEmergency Declaration Resource Page
North CarolinaYesYesEmergency Declaration Resource Page
North DakotaYesYesEmergency Declaration Resource Page Emergency Services Code
OhioNoNoEmergency Declaration Resource Page
OklahomaNoNoEmergency Declaration Resource Page
OregonYesNoExecutive OrderResource Page Emergency Medical License Information
Penn-
sylvania
YesYesEmergency Declaration Resource Page
Rhode IslandYesYesEmergency Declaration Resource Page Emergency Temporary License Application
South CarolinaYesNoMedical Guidance Resource Page Emergency License Application
South DakotaNoNoArticle re: SD State Emergency Declaration Resource Page
TennesseeYesYesEmergency Declaration Resource Page
TexasYesNoEmergency Declaration Resource Page Licensing for Out of State Providers
UtahYesYesMental Health Emergency Declaration Resource Page Emergency Temporary License Application
VermontNoNoEmergency Declaration Resource Page
VirginiaYesNoEmergency Declaration Resource Page
WashingtonYesYesEmergency Declaration Resource Page Emergency Health Practitioner Application
West VirginiaYesNoEmergency Declaration Resource Page
WisconsinNoNoEmergency Declaration Resource Page
WyomingYesNoEmergency Declaration Resource Page Emergency Licensure Application

The Shrink Space team will do their best to keep this chart up to date. Last updated 03/30/20.

For more resources on supporting your clients during the transition to online therapy, read our post on preparing for teletherapy.

Interested in joining us in our mission to improve student access to mental health care? Click here to join our free directory. Please don’t hesitate to contact us with any questions.

P.S. We are interested in hearing how clinicians are managing the transition to teletherapy during the COVID-19 emergency so that we can find more ways to help. Please consider completing this five minute questionnaire here. If we receive a large sample size, we plan to share these results with our TSS community. We’d love to hear your feedback.

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