Medicare requires marriage and family therapists to be licensed in the state where the beneficiary receives services. For telehealth, that is the state where the beneficiary is physically located during the session. A Medicare enrollment does not extend your license, so seeing beneficiaries in several states means holding an active MFT license in each one.
Medicare enrollment for marriage and family therapists began on January 1, 2024, and it came with a requirement that is easy to read past: you must be licensed as an MFT in the state where the beneficiary receives services. For a clinician who only sees clients in person in one office, that is automatic. For anyone doing telehealth, it is a daily question.
Location at the moment of the session
The general licensing rule for telehealth is that the client's physical location during the session determines which state's license you need. Medicare's requirement lines up with that. It does not matter where the beneficiary's Medicare card was issued, where their mailing address is, or where they lived when they first started with you. It matters where they are sitting when the video call starts.
Older adults move around more than people expect. Seasonal residents split the year between a northern home and a southern one. Retirees stay for weeks with adult children after a surgery or a new grandchild. Some move permanently into assisted living near family in a different state. Each of these can quietly move a long-standing client outside the reach of your license.
Building a location check into your routine
The practical fix is a habit, not a policy document. Confirm the client's location at the start of each telehealth session and record it in the note. Ask about travel plans a few weeks ahead of holidays and the start of winter. For clients you know split their year, put the expected move dates in your calendar so the conversation happens before the move, not after.
When a client will be somewhere you are not licensed, you have a few options. You can pause sessions for that stretch, help the client find a licensed clinician where they will be, or apply for a license in that state if the relationship and demand justify it. Some states have temporary practice or continuity-of-care provisions, but these vary and may not satisfy Medicare's requirement, so confirm with both the state board and your Medicare Administrative Contractor before relying on one.
Planning licenses around your Medicare caseload
If a meaningful group of your Medicare clients spend part of the year in one particular state, that is worth noticing. A second license in that state could let you keep those relationships intact. Seventeen states have adopted streamlined endorsement under Access MFTs as of September 2026, including Arizona, Georgia, North Carolina, and Tennessee, which may simplify the application if your target state is on that list. The license still carries its own fees, renewal cycle, and continuing education.
Once you hold the license, keep your Medicare enrollment record accurate about the states and practice locations involved, and treat renewal dates as billing deadlines. A lapsed license in a state means Medicare services furnished to beneficiaries located there are no longer billable under your enrollment.
Common questions
- Can I see a Medicare client who spends winters in another state?
- Only if you hold an active MFT license in the state where the client is located during those sessions. Medicare follows the beneficiary's location. If you are not licensed there, pause sessions, refer to a local clinician for that period, or obtain a license before the client leaves.
- Does telehealth change which license Medicare requires?
- It changes where you need to look, not the rule. The client's physical location at the time of the session determines which state's license is required, so a telehealth visit with a beneficiary in another state requires a license in that state.
- Is there a compact that lets MFTs see Medicare clients anywhere?
- No. There is no MFT interstate compact. AAMFT chose the Access MFTs model law in 2025, which streamlines endorsement in adopting states, but each additional state still means a separate license with its own renewal and continuing education.
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