In nearly every state, the jurisdiction that governs a telehealth session is the one where the client is physically located at the time of the session. Practicing into a state where you hold no license is unlicensed practice regardless of where you sit.
Every complicated cross-border question in this profession collapses into one rule, and the rule is not intuitive.
The rule
The state where the client is physically located at the time of the session is the state whose law applies. Practicing there without a license issued by that state is unlicensed practice, and the fact that you never physically crossed a line has not worked as a defense.
Intuition says otherwise. It feels as though a therapist sitting in an office in one state, licensed there, doing the work they are trained to do, is practicing in that state. Regulators do not see it that way, and the reasoning is about consumer protection: the state's interest is in protecting people located within its borders.
Where this bites in practice
A long-term client relocates for work. A college student goes home for the summer. A client takes a two-week trip and wants to keep their standing appointment. A couple lives in one state and one partner works across a border.
Each of these is routine, and each puts you in a state where you may hold no license. The travel case is the one people rationalize hardest, because the relationship is established and the disruption feels disproportionate. The rule does not have an exception for that.
What some states allow
A number of states carve out limited exceptions worth knowing. Temporary practice provisions sometimes let an out-of-state clinician practice for a defined number of days per year. Continuity-of-care provisions occasionally allow a limited number of sessions with an existing client who has relocated, specifically so treatment is not severed abruptly.
These vary enormously and several states have none. Nothing here is general, which is precisely why the answer has to come from the specific state.
Building a practice around it
Ask where a client is located at intake and again whenever anything changes, and record it. Many practices now put a location question in the periodic check-in for exactly this reason.
Decide deliberately which states you will hold licenses in, based on where your clients actually are, and remember each one carries a renewal cycle, a fee, and its own continuing education requirements. Two or three chosen well are more manageable than six accumulated by accident.
And where you have a genuine choice of which state to add, the seventeen that adopted streamlined endorsement are materially lighter to enter than the rest.
Common questions
- What if my client travels temporarily?
- Their location during the session still governs. A client on vacation in a state where you are not licensed is a genuine problem, and it comes up constantly.
- Does it matter where I am?
- Sometimes. A few states also assert requirements about the clinician's location, so check both ends rather than assuming only the client's side matters.
- Is a single session different from ongoing therapy?
- Generally not. The rule turns on practicing in the state, not on how many sessions.
- Can I see a client who moved away until we finish?
- Only if that state allows it. Some permit brief continuity of care or temporary practice; many do not. Ask before the move, not after.
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