Counseling Compact States 2026: Which Are Live, Plus PSYPACT

Counseling compact states 2026, in short: on October 25, 2026, 40 jurisdictions belong to the Counseling Compact, but only 11 issue privileges to practice, and you can use a privilege only when both your home state and your client's state are among those 11. The list of members is longer than the list of states where the compact actually works. Psychologists have an older, larger compact in PSYPACT. Social workers have a compact that 35 states have passed and that hasn't issued a single license yet. Marriage and family therapists have no compact at all.

This guide gives the status of each one, dated and linked to the official source, then covers what every therapist who works by video needs whatever the license: where a session legally happens, temporary practice and telehealth registration, what to do when a client travels or moves, emergency planning across states, insurance and BAA questions, and a checklist you can copy.

Every status below was checked on the official site on October 25, 2026. These lists change every few weeks, so check the source before you rely on any of it. This is general information, not legal advice.

Where things stand on October 25, 2026

The session happens where the client is

Telehealth across state lines runs on one rule. The Center for Connected Health Policy, the national telehealth policy center that HHS's telehealth site points to, says telehealth "is considered to be rendered at the physical location of the patient," so a clinician typically needs a license in the patient's state (CCHP, cross-state licensing).

In practice that means the state that matters is where your client is sitting when the session starts. Not the address on file, not the state on their insurance card, and not where you are. A client who lives in Ohio but joins from a hotel in Michigan is, for that session, a client in Michigan.

Every compact is built on the same idea:

Your own location can matter too. PSYPACT requires a psychologist using its telepsychology authorization to be physically in their declared home state during the session (PSYPACT practice FAQs). The ACA Code of Ethics tells counselors who work at a distance that they may answer to the laws of "both the counselor's practicing location and the client's place of residence" (standard H.1.b, ACA Code of Ethics). Your home board still governs you wherever the client is.

HHS's telehealth site adds the habit that makes all of this workable: "providers should verify patient location and obtain consent" before an appointment (Telehealth.HHS.gov).

Counseling Compact states in 2026

Is the Counseling Compact in effect?

Yes. The first applications opened on September 30, 2025, at 12:00 p.m. ET, for counselors in Arizona and Minnesota. States have joined the live list one at a time since then. The newest entry on the Commission's home page is dated October 19, 2026: "Missouri goes live in the Compact." On September 22, 2026, the Commission announced that 3,000 privileges had been issued (Counseling Compact news).

The 11 states issuing privileges

Listed with each state's license title, the day it went live, the total cost of one privilege (the Commission's $30 fee plus the state's fee) and whether that state asks for a jurisprudence exam, all as published on October 25, 2026 (Fees, Jurisprudence):

The Commission's map adds the condition people miss: your home state and the state where you want to use a privilege must both be actively issuing privileges (Compact map). A counselor who lives in Florida, a member that isn't live yet, can't get a privilege anywhere today.

Members that are not issuing privileges yet

These 28 states and the District of Columbia have joined but are still working through steps such as rules, fees, FBI background checks and data system testing: Alabama, Colorado, Connecticut, Delaware, the District of Columbia, Florida, Iowa, Kansas, Kentucky, Maine, Maryland, Mississippi, Montana, Nebraska, Nevada, New Hampshire, New Jersey, North Carolina, North Dakota, Pennsylvania, Rhode Island, South Carolina, South Dakota, Utah, Vermont, Virginia, Washington, West Virginia and Wisconsin. So far the Commission has announced each new state on the day it went live or a few days before, on its news page.

States that are not members

Alaska, California, Hawaii, Idaho, Illinois, Massachusetts, Michigan, New Mexico, New York, Oregon and Texas. The map shows a compact bill filed in Michigan. To see clients in any of these states you need that state's license or one of the routes in the temporary practice section below.

Pennsylvania and the Counseling Compact

Pennsylvania's governor signed the Counseling Compact on July 12, 2026, with the law taking effect 60 days later. The Commission calls Pennsylvania its 40th member (announcement). On October 25, 2026, the map still lists Pennsylvania as a member not yet issuing privileges. Until it goes live, Pennsylvania LPCs can't apply for privileges, and counselors elsewhere can't get a Pennsylvania privilege. Pennsylvania psychologists are a different story: PSYPACT has been in effect there since July 8, 2020.

How a privilege works

PSYPACT states for psychologists

PSYPACT, the Psychology Interjurisdictional Compact, is the oldest of the mental health compacts. Its map on October 25, 2026 reads "46 enacted, 44 effective" (PSYPACT map).

PSYPACT gives two separate authorizations:

Two rules catch people out. You must be physically in your declared home state while you use your APIT. And the client must be in a PSYPACT state: PSYPACT's FAQ says the client "can't be in a non-PSYPACT state/jurisdiction or outside the US" (practice FAQs). PSYPACT covers licensed psychologists only.

For scale, PSYPACT's October 2026 newsletter counted 17,407 active telepsychology authorizations and 1,060 active temporary authorizations as of October 2, 2026 (newsletter, PDF).

The Social Work Licensure Compact

The Social Work Licensure Compact has passed in 35 states, with legislation pending in the District of Columbia, Massachusetts and Pennsylvania (compact map). The enacted states are Alabama, Alaska, Arizona, Arkansas, Colorado, Connecticut, Delaware, Georgia, Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland, Minnesota, Mississippi, Missouri, Nebraska, New Hampshire, New Jersey, New Mexico, North Carolina, North Dakota, Ohio, Oklahoma, Rhode Island, South Carolina, South Dakota, Tennessee, Utah, Vermont, Virginia, Washington, West Virginia and Wisconsin. New Mexico and South Carolina passed versions with material changes, which may need fixing before those states can take part.

No one can use it yet. The compact's July 7, 2026 update says its data system is being built, with completion estimated for spring 2027 (update). A May 2026 FAQ from ASWB, the Clinical Social Work Association and NASW gave no definite date but expected licenses likely within 9 to 12 months (FAQ). Fees aren't set.

When it starts, it will work differently from the Counseling Compact. A social worker will get one multistate license through their home state (where they live) and can then practice in every member state, rather than buying a privilege state by state. It covers bachelor's, master's and clinical licenses, each with its matching ASWB exam, and continuing education stays with the home state. Until licenses are issued, social workers need a license in each state where clients are, or one of the temporary routes below.

Marriage and family therapists: no compact

There is no interstate compact for MFTs, and an LMFT license typically doesn't qualify for the Counseling Compact. What exists instead:

Temporary practice and telehealth registration

Compacts are one of five routes HHS lists for practicing across state lines: a full license, temporary practice laws, licensure reciprocity, a compact, or telehealth registration (Telehealth.HHS.gov). For telehealth registration, HHS says the usual terms are a current unrestricted license elsewhere, no discipline, proof of professional liability insurance, no office or in-person care in that state, and a yearly registration and fee.

Three examples, checked on the official sites on October 25, 2026:

Many states offer nothing like this, and the ones that do attach conditions that change. For telehealth regulations by state, CCHP keeps a state-by-state summary with links to each statute (CCHP). Treat it as a map, then confirm on the board's own site.

When a client travels or moves

Most cross-state problems start with an ordinary life event. Plan for these before they happen.

A client tells you about a trip. Ask where they'll be and when. If you're authorized in that state, hold the session as usual and note the location. If you aren't, check that state's temporary practice or registration rules. If nothing applies, move the session to before or after the trip, and agree on what the client will do if they need help while away (see the emergency section).

A client joins from somewhere unexpected. This is why you confirm location at the start of every session. If they're in a state where you aren't authorized, states differ on what, if anything, you may do in that moment. Decide your policy in advance with a lawyer or your board, and write it into your telehealth consent.

A client moves. Compare the move date with your options in the new state: a compact privilege if both states are live, a license there, a telehealth registration, or a temporary allowance for current clients. If none will be ready in time, plan a transfer: help the client find a clinician licensed in the new state, and with the client's written permission send records and talk to the new clinician. Starting this a month before the move is easier than starting the week after.

A client is outside the US. A US license, privilege or authorization covers practice in US states. PSYPACT says its authorization doesn't cover clients outside the US, and other countries may have their own rules. Check your malpractice policy's territory as well.

You move. The Counseling Compact and the Social Work Licensure Compact are tied to where you live: move, and your new state becomes your home state, where you need a license. The Counseling Compact provides for converting a privilege into a home state license, and states are still setting up that process. PSYPACT ties telepsychology to the declared home state you're physically in during sessions, so update that declaration when you move (practice FAQs).

Emergency planning across states

Crisis rules follow the client too. AMFTRB's teletherapy guidelines note that each jurisdiction has its own involuntary hospitalization and duty-to-notify laws, and that therapists must know the rules where they are and where the client receives services. They also warn that "simply offering 911 may not be sufficient" (AMFTRB guidelines, PDF).

A workable plan, set up at intake and refreshed when anything changes:

One detail matters for travelers. The FCC says the nationwide wireless carriers had to route calls to 988 by the caller's approximate location by January 13, 2025, and smaller carriers must do so by December 14, 2026. Where that routing isn't active, a call still goes to a crisis center based on the phone number's area code, which may be far from where the client is (FCC, 988). For a client who is away from home, write down local numbers too.

Insurance, payers and your BAA

Malpractice insurance. Ask your insurer in writing whether you're covered for clients in another state when you hold a license, privilege or registration there, whether that includes a client who is traveling, and whether your policy has a territory limit. Florida's registration requires coverage that includes telehealth to patients outside your home state. Our guide to professional liability insurance for therapists lists more questions to ask.

Payers. The Counseling Compact says the policies of individual insurance companies aren't yet known to it (FAQ). PSYPACT says billing is outside its purview and an authorization doesn't mean an insurer will pay, so verify coverage before the session (practice FAQs). For Medicare, CMS said in 2021 that it treats licenses obtained through a compact pathway "as valid, full licenses" for its federal license requirements (CMS MLN Matters SE20008, PDF). Ask each payer how it handles a client located in another state.

HIPAA and your BAA. HIPAA is federal, so it applies the same way wherever your client is, and the Business Associate Agreement with your video and booking software doesn't change when a client crosses a state line. State privacy laws that are more stringent than HIPAA still apply alongside it (45 CFR 160.203), and depending on the facts that can include the client's state. If you're choosing a platform, see what to check in a HIPAA compliant telehealth platform, and if you're unsure whether HIPAA covers your practice at all, start with who HIPAA applies to.

A checklist to copy

Fill this in once for your practice, then keep a copy for each state where you see clients.

How this works in TranqBay

TranqBay is practice software for therapists in private practice. Here is how it fits the steps above:

Whatever software you use, confirming where the client is and whether you're authorized there stays your job. To see a practice website and the booking page your clients would use, look at TranqBay for private practice.

Frequently asked questions about counseling compact states

Before you see a client across state lines

Check the official status page for your compact on the day you need it, confirm where your client is at the start of every session, and write your travel and emergency plan into your consent form before anyone books a trip. If you're building a practice that sees clients by video, our guide to starting as a private practice therapist covers the rest of the setup.

When you're ready to put the practice online, see how TranqBay works for private practice: look at a practice website design and the booking page your clients would use, with video sessions and the form library in the same place. If you're deciding whether to join, this page explains how joining TranqBay works.

For the paperwork side of seeing clients by video, our telehealth consent form has a location check and emergency plan you can copy.

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