Understanding Telepractice Licensure Requirements If you have licensure in one state, can you provide telepractice services to a client in another state? Practitioners may have to dig deep to find the answer to this and other questions. Policy Analysis
Policy Analysis  |   December 01, 2014
Understanding Telepractice Licensure Requirements
Author Notes
  • Cheris Frailey, MA, CCC-SLP, is ASHA director of state education and legislative advocacy. cfrailey@asha.org
    Cheris Frailey, MA, CCC-SLP, is ASHA director of state education and legislative advocacy. cfrailey@asha.org×
Article Information
Regulatory, Legislative & Advocacy / Telepractice & Computer-Based Approaches / Policy Analysis
Policy Analysis   |   December 01, 2014
Understanding Telepractice Licensure Requirements
The ASHA Leader, December 2014, Vol. 19, 26-27. doi:10.1044/leader.PA2.19122014.26
The ASHA Leader, December 2014, Vol. 19, 26-27. doi:10.1044/leader.PA2.19122014.26
Audiologists and speech-language pathologists trying to determine telepractice licensure requirements may find the search daunting. States have different laws and regulations—some of which are in flux—and it’s important to stay on top of changes in your state, as well as the states in which your clients live.
What are ASHA’s policies/guidance on telepractice?
ASHA views telepractice as an appropriate service delivery model for speech-language and hearing services. Practitioners follow the same ASHA service delivery guidelines, scope of practice and Code of Ethics requirements that apply to face-to-face services, as well as any applicable state and federal laws. Practitioners must keep up with technology, licensure laws and potential clinical applications as telepractice evolves.
What are the state requirements?
Each state varies in its view of telepractice, and some state licensure boards have not set telepractice requirements. Sixteen states regulate telepractice; two states define it; and two of the 16 states require some face-to-face visits along with the telepractice sessions. License-holders are responsible for monitoring requirements in the states in which they practice. ASHA updates this information once a year.
What should I do if a state does not have telepractice requirements?
In the many states that are silent on telepractice regulations or licensure, ASHA recommends contacting the licensure board for information on requirements for practitioners who live in or out of state. If the state licensure board can’t provide an answer, ASHA recommends getting a license in the practitioner’s state and in the client’s state. Those who bill Medicaid and private insurance typically need a license in order to bill. Licensure requirements and state board contacts are updated annually.
What if the client lives in more than one state?
If a client lives in more than one state and receives services in both locations, the practitioner should obtain a license in both states. The practitioner needs to verify if Medicaid or the insurance carrier allows reimbursement if the client is out of the originating state (the state in which the client pays taxes).
What if the client requests services while on vacation?
Clients may request to receive telepractice services during their out-of-state vacations. Some states do not require a license if the client receives fewer than 10 sessions or is in the state for fewer than 30 days. Contact the state licensure board to determine if a license is required, and document the date, time and name of the person from whom you receive the information. Again, Medicaid and private insurance may not reimburse if the practitioner has not been treating the client via telepractice or if the client is in a nonresidential state. Follow up with the insurance provider to determine if reimbursement is allowed and if rates are the same.
Do occupational audiologists need a license in each state they have contracts?
ASHA has seen an increase in inquiries regarding occupational audiologists and licensure requirements. Some practitioners are confused, assuming they do not need a license in each state services are provided because hearing conservation programs are a requirement of the Occupational Safety and Health Administration. OSHA and ASHA recommend that practitioners follow state requirements and licensure laws.
What are the requirements for practice internationally?
If you are pursuing telepractice clients outside of the United States, you should contact the country in which the client lives to determine the appropriate requirements. Find additional guidance by contacting the particular countries’ audiology and speech-language associations.
What are some of the licensing alternatives that reduce practice barriers?
Some states are considering alternative telepractice licensure options, such as a limited license or registration. A limited license allows a clinician to practice under limited circumstances—for example, someone licensed in another state could obtain a limited license to provide services via telepractice only. Registration requires a professional with an out-of-state license to register in the client’s home state, allowing the state board to monitor practitioners—but not requiring the practitioner to pay the higher standard license fees.
Louisiana, for example, recently enacted legislation that allows out-of-state practitioners providing telepractice services to Louisiana residents to register with—rather than be licensed by—the state.
What does the future hold?
The need for multiple licenses is a barrier to telepractice, and ASHA is looking at alternatives. ASHA’s model language for state licensure legislation includes registration or a limited license to deliver interstate telepractice.
Federal-level interest in using technology to treat clients is on the rise, and ASHA is working with members of Congress on telepractice-related legislation, including Medicare coverage.
In addition, the American Medical Association endorsed the Federation of State Medical Boards’ multistate compact for physicians already board-certified in one state. The compact is not specific to telepractice, but would instead create a system in which states recognize medical licensure issued by another state. If individual state legislatures choose to adopt this plan and pass legislation, it could open the door for states to expand the use of licensure compacts for other health-related practitioners.
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December 2014
Volume 19, Issue 12