Using telehealth private practice hours as supervised hours?

[oldschooliscool]

This year, I will be starting a tenure-track assistant professor position immediately after graduating with my PhD and finishing internship. I'm thrilled for this next step, and part of my negotiation package included ensuring I will have supervision from a fellow faculty member as I work towards licensure in the state where the university is (Tennessee), which is great. I've done the math, and I'll just need about 8-10 hours per week of clinical hours, which they said I'm welcome to obtain from their department's PSC using their growing waitlist. Very simple.

My biggest issue is that I cannot charge money for seeing clients in the department's PSC, and I'm growing tired of not charging for my services. Here is where I've had a crazy idea, and I'd like for you all to either talk me out of it or tell me that I'm not crazy:

Step 1: Take the EPPP, and the Oral / Jurisprudence exams for one of the states listed below.
Step 2: Get licensed in West Virginia, Alabama, North Dakota, or Mississippi, since NEITHER of these states require post-doc hours (I already checked with the boards).
Step 3: Now that I'm licensed in a state as a psychologist, I set up a telehealth private practice in this state -- working from my office at the university in another state -- making money while seeing 8-10 clients per week.
Step 4: Clear this with my faculty supervisor, consult with them weekly, etc.
Step 5: Get my faculty supervisor to sign off on these hours.
Step 6: Do this for 1-2 years, making decent money the entire time.

To me, this seems like a brilliant idea. Questions I'm having:

Q1: Would my supervisor need to be licensed in the state I'm practicing? I see no mention of that on different applications. For example, I am interested in getting licensed in Tennessee (where I'll be living/working), and that's not specified here: https://www.tn.gov/content/dam/tn/h.../Psych_Postdoc_Supervised_Experience_Form.pdf

Q2: Could boards get upset about the idea of doing "postdoctoral hours" while calling myself a "psychologist" (and not a "postdoctoral fellow" or "supervised clinician" or whatever), even if this is technically correct?

Q3: Could this come back to bite me in any predictable way, or is this more common than I'm thinking?

Any feedback would be appreciated. I can't tell if I'm being foolish or brilliant right now, which could possibly be a good indicator that it's a bad idea but perhaps I'm overthinking things.

EDIT TO ADD: if the biggest hang up about this is a supervisor not being licensed in the same state, then I could select a state that we both would be licensed in. If that's the only issue, that seems simple to solve.

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[MCParent]

Super illegal in multiple ways.

Probably familiarize yourself with the relevant laws/rules for PP. Many things you listed are violations of many state board rules and probably uni rules.

 

[oldschooliscool]

Super illegal in multiple ways.

Probably familiarize yourself with the relevant laws/rules for PP. Many things you listed are violations of many state board rules and probably uni rules.

I felt like this could be against regulations, but I'm not sure why. Is it just because the supervisor isn't licensed in the state I'm practicing? If so, would having them ALSO licensed in that state solve everything, or are there still regulations I'm not thinking of?

I looked in the state rules for Tennessee and I couldn't find anything on this.

 

[MCParent]

I felt like this could be against regulations, but I'm not sure why. Is it just because the supervisor isn't licensed in the state I'm practicing? If so, would having them ALSO licensed in that state solve everything, or are there still regulations I'm not thinking of?

I looked in the state rules for Tennessee and I couldn't find anything on this.

Well….
Representing yourself as being a psych in state x and seeing patients while actually being in state y
Sv presumably not licensed in state x
Sounds like misrepresenting yourself in state y
Using university resources (office, computer, net connection) to run a private business
There are probably a few more in there.

 

[oldschooliscool]

Well….
Representing yourself as being a psych in state x and seeing patients while actually being in state y
Sv presumably not licensed in state x
Sounds like misrepresenting yourself in state y
Using university resources (office, computer, net connection) to run a private business
There are probably a few more in there.

I'm not sure these actually are issues. For example, many people have private practices where they see people in multiple states. No misrepresentation is needed - just honestly say "I live in Tennessee, but I am licensed to see clients in X state." If the supervisor is licensed in that same state as well, and I say clearly "Although I am licensed to practice psychology in X state, my cases are being supervised by Dr. So-and-so as I work towards additional licensures. Here are the forms for you to sign to consent..."

The university is totally fine with faculty members running private practices out of their offices, I've already checked.

That's why I'm asking if these actually are violations of the law, or if it just feels different. I appreciate any questions you raise, and I hope I don't come across as defensive. I'm just trying to figure out what the rules actually are.

EDIT: and all of these disclosures would be on my website, advertisements, forms, and verbal, just to cover my bases.

 

[PsyDuck90]

Unless PSYPACT rules have changed, I’m pretty certain you have to be licensed in your home state to provide services through PSYPACT, which would be the state you are residing in/practicing in (Tennessee).

 

[oldschooliscool]

Unless PSYPACT rules have changed, I’m pretty certain you have to be licensed in your home state to provide services through PSYPACT, which would be the state you are residing in/practicing in (Tennessee).

In this case, I wouldn't be licensed in Tennessee trying to practice in a different state through PSYPACT. Rather, I would be licensed in, say, West Virginia, while living in Tennessee and practicing remotely in West Virginia. I wouldn't be using PSYPACT, I would just be licensed in the state that I am providing services to.

 

[MCParent]

Unless PSYPACT rules have changed, I’m pretty certain you have to be licensed in your home state to provide services through PSYPACT, which would be the state you are residing in/practicing in (Tennessee).

That’s correct.

OP, you need to review the profession and state license and practice rules and laws.

 

[oldschooliscool]

That’s correct.

OP, you need to review the profession and state license and practice rules and laws.

Hang on, I don't think PSYPACT is relevant to this, is it? PSYPACT is only applicable if I am trying to practice psychology under the authority of PSYPACT, but that's not what I'm seeking to do.

Imagine a psychologist who is licensed in multiple states trying to offer telehealth services to those states. Do they have to use PSYPACT? To my knowledge, no, because they are fully licensed in the state that they are providing services to. PSYPACT only comes into play when you want to provide services to a state that you are NOT licensed in, so you use PSYPACT to gain access there.

Please correct me if I'm wrong.

 

[MCParent]

Hang on, I don't think PSYPACT is relevant to this, is it? PSYPACT is only applicable if I am trying to practice psychology under the authority of PSYPACT, but that's not what I'm seeking to do.

Imagine a psychologist who is licensed in multiple states trying to offer telehealth services to those states. Do they have to use PSYPACT? To my knowledge, no, because they are fully licensed in the state that they are providing services to. PSYPACT only comes into play when you want to provide services to a state that you are NOT licensed in, so you use PSYPACT to gain access there.

Please correct me if I'm wrong.

If you want to practice in state x you need to be located in state x unless you are in psypact and both state x and the state you are licensed in is part of psypact. Or be licensed in both states and the state you are not in is cool with someone being licensed and living out of state. There are some exceptions in specific states but again you’d need to review the rules and regs for the state.

 

[PsyDuck90]

Hang on, I don't think PSYPACT is relevant to this, is it? PSYPACT is only applicable if I am trying to practice psychology under the authority of PSYPACT, but that's not what I'm seeking to do.

Imagine a psychologist who is licensed in multiple states trying to offer telehealth services to those states. Do they have to use PSYPACT? To my knowledge, no, because they are fully licensed in the state that they are providing services to. PSYPACT only comes into play when you want to provide services to a state that you are NOT licensed in, so you use PSYPACT to gain access there.

Please correct me if I'm wrong.

Outside of PSYPACT, you need to be physically located in the state you are providing services in. And even with PSYPACT, you need to identify the home state, which is, again, the state you are licensed in and residing in. The only way to get around this is if you work for the VA (and I’d presume other federal entities), which is a federal system, and they only care that you are licensed in a US state, not necessarily the one you are working in.

 

[MCParent]

Outside of PSYPACT, you need to be physically located in the state you are providing services in. And even with PSYPACT, you need to identify the home state, which is, again, the state you are licensed in and residing in. The only way to get around this is if you work for the VA (and I’d presume other federal entities), which is a federal system, and they only care that you are licensed in a US state, not necessarily the one you are working in.

Just add the “check the weird states” thing—eg I think cali still has the (I forget how many?) hours of practice from outside the state per month, I got a temporary practice authorization from Jersey in like 2 days before they joined psypact, etc.

 

[oldschooliscool]

If you want to practice in state x you need to be located in state x unless you are in psypact and both state x and the state you are licensed in is part of psypact. Or be licensed in both states and the state you are not in is cool with someone being licensed and living out of state. There are some exceptions in specific states but again you’d need to review the rules and regs for the state.

Outside of PSYPACT, you need to be physically located in the state you are providing services in. And even with PSYPACT, you need to identify the home state, which is, again, the state you are licensed in and residing in. The only way to get around this is if you work for the VA (and I’d presume other federal entities), which is a federal system, and they only care that you are licensed in a US state, not necessarily the one you are working in.

Thank you both for taking the time to explain this. This information goes contrary to what I've heard over the past year, so I'm glad I'm learning about this now. My understanding was different than this, so I'll be contacting the state boards to confirm, but it seems that the two of you are telling a consistent story so I'm likely the one who is wrong.

 

[WisNeuro]

I'm just going to second/third/fourth the notions that this is a bad idea.

 

[oldschooliscool]

I'm just going to second/third/fourth the notions that this is a bad idea.

And here I thought that I had figured out how to make supervised hours proftable. 😢

 

[MCParent]

And here I thought that I had figured out how to make supervised hours proftable. 😢

It’s not your fault the state boards all have different rules/barely answer questions or respond to emails or calls/give the wrong answer sometimes if you do get ahold of them.

 

[PsyDr]

From a billing perspective:

Federal law defines supervision as the supervisor being physically on site, albeit not necessarily in the same room. Guess what happens when you bill otherwise? From the same organization that says that under billing is fraud?

Let me know. Whistleblowers get 3x the reported fraud. I could use that free cash.

 

[MCParent]

I’ll also add, in case this is found by others;
The uni might SAY they’re ok with running a pp out of a uni faculty office. But are you going to make your uni office your pllc address? And if something goes sideways, I would very much not count on them not throwing you under a bus for liability.

 

[Sanman]

In this case, I wouldn't be licensed in Tennessee trying to practice in a different state through PSYPACT. Rather, I would be licensed in, say, West Virginia, while living in Tennessee and practicing remotely in West Virginia. I wouldn't be using PSYPACT, I would just be licensed in the state that I am providing services to.

My take:

1. You would have to check if the licensed state (say WV) would allow you to practice while permanently residing in another state.

2. You would need to check if you can legally practice in TN this way and if they would allow out of state hours to count toward their licensure requirement.

3. You would likely need to find a supervisor licensed in both states willing to sign off on this setup as I am not sure how someone in TN can supervise a case in WV. Good luck with that. Maybe a WV licensed supervisor would work if you got virtual supervision hours, but who knows.

4. If any of these say no or give you the wrong advice you are back to square one.

5. This would likely need to be cash only because third party reimbursement is a whole extra set of rules.

 

[foreverbull]

Correct me if I’m wrong, but can’t you just find a licensed psychologist in the community who can agree to supervise you in their practice as a postdoc and then you get paid a set amount of the cash pay fee for the clients you see in your supervisor’s private practice?

I interviewed for such an opportunity rather informally but turned it down years ago when considering a postdoc. In my state that is perfectly legal and ethical as long as you sign an agreement and have a contract in place for licensure hours, and that the supervisor doesn’t technically charge you “fees” for an office or their service to you—you get paid as an employee or something to that effect. You’d have to register with the board as a “registered psychologist” or whatever your state calls postdoc but pre-licensed.

Does your state allow this as well?

 

[oldschooliscool]

Everyone's input here has been greatly appreciated! I've reached out to all four states that offer licensing without post-doc hours to ask them the specific questions raised in this thread; I'll also be reaching out to Tennessee for their part of this process as well. I'm going to put updates in this thread when I learn anything, and I'll leave this thread up (instead of deleting it) so that others can learn from what I'm figuring out (in case anyone thinks of this idea in the future).

Thanks again, everyone!

 

[BuckeyeLove]

This is a really horrible idea. I honestly don’t even know if it would be feasible. And I can’t imagine any direct supervisor being ok with it either (especially if they somehow get looped into it). Just deal with the postdoc year.

 

[oldschooliscool]

This is a really horrible idea. I honestly don’t even know if it would be feasible. And I can’t imagine any direct supervisor being ok with it either (especially if they somehow get looped into it). Just deal with the postdoc year.

Ouch. Is it a "really horrible idea" because of different reasons than what other people have voiced in this thread, or is this just echoing their concern?

 

[summerbabe]

Agree with all of the points raised.

To the OP (and put this in the unsolicited advice category): since you’ll likely be providing clinical supervision & maybe even teaching ethics in your new role, this might be an example of where looser interpretations of ethics, rules/laws, competency, etc can potentially be more detrimental than taking more narrow interpretations (including when it causes us difficulties).

Good luck with the job and hopefully you can figure something out that is TN-based. I especially like forveverbull's suggestion of bypassing your university and exploring your local community. There's probably a happier medium between free labor & taking these kinds of risks, even if you get some potentially affirmative answers from other states or supervisors who might be willing to sign onto something like this.

And personally, I would NEVER agree to supervise somebody under these circumstances and it doesn't sound like any of the other licensed folks in this thread would either, which I think is telling.

 

[oldschooliscool]

Agree with all of the points raised.

To the OP (and put this in the unsolicited advice category): since you’ll likely be providing clinical supervision & maybe even teaching ethics in your new role, this might be an example of where looser interpretations of ethics, rules/laws, competency, etc can potentially be more detrimental than taking more narrow interpretations (including when it causes us difficulties).

Good luck with the job and hopefully you can figure something out that is TN-based. I especially like forveverbull's suggestion of bypassing your university and exploring your local community. There's probably a happier medium between free labor & taking these kinds of risks, even if you get some potentially affirmative answers from other states or supervisors who might be willing to sign onto something like this.

And personally, I would NEVER agree to supervise somebody under these circumstances and it doesn't sound like any of the other licensed folks in this thread would either, which I think is telling.

Thanks for the encouragement here! I'm still learning about ethics / risks, which is not something that was taught in the detail that I'd like during my graduate program; it seems to me like it's been expected that I'd figure it out as I studied for the EPPP / jurisprudence exams.

I've found that I usually learn best what rules exist and why rules exist when I start asking questions like this, so this has been a helpful process to me. I'm still trying to figure out why everyone in this thread would NEVER want to do this, even if it was approved by all state boards involved, but I'm guessing this will become obvious to me (as it is to everyone else) as I learn more.

 

[psych.meout]

Thanks for the encouragement here! I'm still learning about ethics / risks, which is not something that was taught in the detail that I'd like during my graduate program; it seems to me like it's been expected that I'd figure it out as I studied for the EPPP / jurisprudence exams.

I've found that I usually learn best what rules exist and why rules exist when I start asking questions like this, so this has been a helpful process to me. I'm still trying to figure out why everyone in this thread would NEVER want to do this, even if it was approved by all state boards involved, but I'm guessing this will become obvious to me (as it is to everyone else) as I learn more.

It's the liability and that you don't know what you don't know, for both you and your supervisor. You're practicing virtually, out-of-state and your supervisor isn't observing you and your interactions with patients. How are they supposed to know what the quality of your work is, where your strengths and weaknesses are, etc. besides what you bring into supervision sessions? Even if you were proactively bringing issues into supervision (and there are obvious reasons why people don't do that), it's still begging the question that you have good insight and know where issues are specific to individual patients and to your general clinical skills. Yes, these are somewhat issues even when you're co-located, but you're talking about adding on additional layers of complexity and liability with this plan you've developed.

 

[oldschooliscool]

It's the liability and that you don't know what you don't know, for both you and your supervisor. You're practicing virtually, out-of-state and your supervisor isn't observing you and your interactions with patients. How are they supposed to know what the quality of your work is, where your strengths and weaknesses are, etc. besides what you bring into supervision sessions? Even if you were proactively bringing issues into supervision (and there are obvious reasons why people don't do that), it's still begging the question that you have good insight and know where issues are specific to individual patients and to your general clinical skills. Yes, these are somewhat issues even when you're co-located, but you're talking about adding on additional layers of complexity and liability with this plan you've developed.

Thanks for taking the time to explain this. I guess the part that I put in bold from your comment is what has me the most confused; most of my clinical experiences thus far do not involve my supervisors directly observing me live. There is reviewing of recordings, to be sure, and certainly reviewing of my detailed notes, but all of this can occur via a telehealth practice as well.

A few of the postdoctoral positions I interviewed for were majority remote, which in my unlicensed, unknowledgeable mind feels just about the same.

That's why I'm trying to figure out if this is actually a dramatic violation of rules/regulations, or just a departure from the norm but still very much within the rules and regulations. Granted, "departure from the norm" is not something you usually want to do when seeking licensure, so I understand hesitations there.

 

[summerbabe]

I've found that I usually learn best what rules exist and why rules exist when I start asking questions like this, so this has been a helpful process to me. I'm still trying to figure out why everyone in this thread would NEVER want to do this, even if it was approved by all state boards involved, but I'm guessing this will become obvious to me (as it is to everyone else) as I learn more.

Let's take the example of an actively suicidal/homicidal patient via telehealth in a state where you are not located & where your supervisor might not be licensed.

How would you handle a situation like this? What are the types of factors that you need to be aware of? What additional liability is potentially being incurred by you not being in the state or your supervisor not being licensed there? And if something goes wrong, what type of liability might come back to your supervisor? Will they want to put their license at risk for this type of scenario?

This will be different state by state due to different rules/laws but these are the types of questions I would very much be thinking about.

I supervise interns via the VA, including via telehealth. I make sure that we are 1000% on the same page about the type of work they are doing to avoid negative effects of these kinds of things, as well as have clearly defined pre-identified plans for when stuff goes down.

 

[smalltownpsych]

This discussion adds another reason why I’m not a fan of telehealth for providing psychotherapy. Not totally against it as I find it useful for some situations but it’s become the Wild West out there.

 

[oldschooliscool]

Let's take the example of an actively suicidal/homicidal patient via telehealth in a state where you are not located & where your supervisor might not be licensed.

How would you handle a situation like this? What are the types of factors that you need to be aware of? What additional liability is being incurred by you not being in the state or your supervisor not being licensed there? And if something goes wrong, what type of liability might come back to your supervisor? Will they want to put their license at risk for this type of scenario?

I supervise interns via the VA, including via telehealth. I make sure that we are 1000% on the same page about the type of work they are doing to avoid negative effects of these things, as well as have clearly defined pre-identified plans for when stuff goes down.

Good questions. For this illustration, let's just imagine that both myself and my supervisor are licensed in this state.

I'd imagine that an actively suicidal patient in a state other than where I live (but where I and my supervisor are licensed) would be handled the same way an actively suicidal patient on the opposite end of the state where we live would be handled. Generally speaking, when I have provided care during my clinical training to high-risk patients via telehealth, we get all of this squared away with the patient before beginning treatment ("who is your emergency contact? where is the nearest emergency room? here are the local resources for you if you're in crisis. let's create a safety plan. etc.").

I appreciate your response, as it's a good thinking exercise. I suppose I'm still seeing too many similarities and not enough differences, which is why I'll keep reaching out to the boards, studying regulations, etc.

 

[oldschooliscool]

This discussion adds another reason why I’m not a fan of telehealth for providing psychotherapy. Not totally against it as O find it useful for some situations but it’s become the Wild West out there.

That's a very valid criticism, I totally get you there.

 

[biscuitsbiscuits]

Thanks for the encouragement here! I'm still learning about ethics / risks, which is not something that was taught in the detail that I'd like during my graduate program; it seems to me like it's been expected that I'd figure it out as I studied for the EPPP / jurisprudence exams.

I've found that I usually learn best what rules exist and why rules exist when I start asking questions like this, so this has been a helpful process to me. I'm still trying to figure out why everyone in this thread would NEVER want to do this, even if it was approved by all state boards involved, but I'm guessing this will become obvious to me (as it is to everyone else) as I learn more.

I can appreciate that you are thinking creatively here (seriously) and I understand your frustration with not being paid for your work. But (or "and" if you're DBT):

This is a really, really big "if" here. There might be some wild west states out there, but my guess is that most would not allow this and even less likely that two would allow this setup, even LESS likely that the exact two you're looking at would allow it. I agree with everyone in this thread that this is a bad idea, but why don't you first figure out if this is even legally and ethically possible for you and then go from there. You may not need to get lost in these weeds because it's just not a real possibility. If it is legal and possible.... then you need to find out if any available supervisors would be open to it (unlikely). THEN, maybe return to all of the reasons why it still might not be a great idea, and then weigh the risks for yourself and your supervisor.

I also think finding a part-time supervised clinical position would be the easiest, best path for you. I was going to jump in with that idea too- I'm not sure why you need to jump through all of these hoops to solve this problem. It's a pretty straightforward, legal, easy to find setup (at least in my state). Good luck!

 

[Therapist4Chnge]

A few of the postdoctoral positions I interviewed for were majority remote, which in my unlicensed, unknowledgeable mind feels just about the same.

This is wild to consider prior to COVID. I just don’t see how this is practical or ethical. I know some aspects of practice have expanded (e.g. telehealth), but that’s for fully licensed ppl. I don’t have a solution, merely pointing out a training scenario I hadn’t considered bc I trained many years ago in the Before Times.

 

[MCParent]

I think the “do it out of my office” part is being overlooked. OP is proposing to use state government funds and equipment to operate their private business. I would assume that approval is just from the dept, with nothing from above? Minefield. I wouldn’t do that without having it, in writing, that the uni completely understands what you’re doing and approves of it including accepting all relevant liability.

 

[calimich]

Tenured faculty here with a pp. I've been careful not to mix the spaces. I've occasionally worked on billing, scheduling, report editing, other admin tasks from campus but I've never done telehealth from the campus office. We're allowed 8-10 hours/week to pursue outside interests, so the time is not an issue, just more worried about liability and any comingling for tax purposes. I also waited until my second year was over to open the pp, however I came in having completed a postdoc with the hours requirement met. I did need to complete the extra CA licensing courses.

 

[ClinicalABA]

Steps 1-2 of your plan are going to take MONTHS. You'd also then have to get your ASPPB e-passport and then your APIT through psypact before you could do any interjurisdictional therapy. I don't know how long the e-passport/APIT stuff takes, but there is language on the ASPPB website to the effect of "we're working hard to process all these applications, but there sure are a lot of them, so be patient". By the time all of this gets done, you could be halfway to your TN license by just seeing PSC clients or doing it the old fashioned way and finding something in the community where you could get supervised hours and maybe make a few bucks.

As mentioned ad nauseum above, states have their own rules. My state (MA) is not a member of pyspact, but there is proposed legislation. It contains the following language:

"The home state maintains authority over the license of any psychologist practicing into a receiving state under the authority to practice interjurisdictional telepsychology."

That makes it seem like you'd need to be licensed in MA to provide telehealth to persons in other states. Check the TN psypact legislation.

 

[psych.meout]

Good questions. For this illustration, let's just imagine that both myself and my supervisor are licensed in this state.

I'd imagine that an actively suicidal patient in a state other than where I live (but where I and my supervisor are licensed) would be handled the same way an actively suicidal patient on the opposite end of the state where we live would be handled. Generally speaking, when I have provided care during my clinical training to high-risk patients via telehealth, we get all of this squared away with the patient before beginning treatment ("who is your emergency contact? where is the nearest emergency room? here are the local resources for you if you're in crisis. let's create a safety plan. etc.").

I appreciate your response, as it's a good thinking exercise. I suppose I'm still seeing too many similarities and not enough differences, which is why I'll keep reaching out to the boards, studying regulations, etc.

I wonder if there's a psychology term for this...

 

[Sanman]

I think the “do it out of my office” part is being overlooked. OP is proposing to use state government funds and equipment to operate their private business. I would assume that approval is just from the dept, with nothing from above? Minefield. I wouldn’t do that without having it, in writing, that the uni completely understands what you’re doing and approves of it including accepting all relevant liability.

This is a fair point and whole different can of worms from working at home or a designated office.

 

[Sanman]

Steps 1-2 of your plan are going to take MONTHS. You'd also then have to get your ASPPB e-passport and then your APIT through psypact before you could do any interjurisdictional therapy. I don't know how long the e-passport/APIT stuff takes, but there is language on the ASPPB website to the effect of "we're working hard to process all these applications, but there sure are a lot of them, so be patient". By the time all of this gets done, you could be halfway to your TN license by just seeing PSC clients or doing it the old fashioned way and finding something in the community where you could get supervised hours and maybe make a few bucks.

As mentioned ad nauseum above, states have their own rules. My state (MA) is not a member of pyspact, but there is proposed legislation. It contains the following language:

"The home state maintains authority over the license of any psychologist practicing into a receiving state under the authority to practice interjurisdictional telepsychology."

That makes it seem like you'd need to be licensed in MA to provide telehealth to persons in other states. Check the TN psypact legislation.

I think that this is the issue that makes it so crazy to me. In theory, this is not so different from folks I know that got supervised post-doc hours licensed in one state and then applied for a license in a neighboring state. However, in this case, I think this is spending a lot of extra time and headache for a few dollars when one can just do the bolded.

 

[oldschooliscool]

I think that this is the issue that makes it so crazy to me. In theory, this is not so different from folks I know that got supervised post-doc hours licensed in one state and then applied for a license in a neighboring state. However, in this case, I think this is spending a lot of extra time and headache for a few dollars when one can just do the bolded.

Echoing that the bolded part of your post @ClinicalABA does, in fact, seem easier and not that bad.

Although, for anyone interested:
Mississippi's board has gotten back to me this morning, and they told me that I do not need to be a resident or located in their state in order to obtain a license or to see telehealth clients there, and that I can still got licensed as a non-resident living in a different state even if it is my first state that I'm licensed in.

Now I wait to hear back from the other states.

I have also reached out to Tennessee to see if all of this doesn't even matter, because they won't accept that experience as "supervised."

I'm continuing to look into this. Now, I'm beginning to consider simply seeing patients in the PSC at my university in Tennessee as I receive supervised training and work towards licensure, but perhaps ALSO seeing telehealth patients in another state - unsupervised, because I'll be operating under my own license there - purely to make extra cash in the evenings if I'm desperate for money (but not counting it towards licensure hours).

 

[quickpsych]

Agree with all the replies here. While can certainly appreciate your enthusiasm for getting to work, your idea proposed is a terrible idea and opens you up to unnecessary clinical, legal, ethical, and billing concerns.

This seems like a lot of extra work and headache for high risk, low reward.

If you need some extra income, see if there is work you can do on the side while working on your home state license.

 

[ClinicalABA]

Although, for anyone interested:
Mississippi's board has gotten back to me this morning, and they told me that I do not need to be a resident or located in their state in order to obtain a license or to see telehealth clients there, and that I can still got licensed as a non-resident living in a different state even if it is my first state that I'm licensed in.

Yes- but this is their policy as pertains to general licensure (for example- I am licensed in multiple states, but only legally reside in one) and to being a psypact receiving state, rather than a psypact home state. To practice under psypact with a e-passport and APIT (both required), you need to designate a home state and be physically located in that home state when practicing telepsychology. Here's a screenshot from the psypact website:

In your plan, if you get licensed in MS and declare it your home state, then you can do telepsychology with a client in any psypact state, but you must be in MS when you do so. You could be in WV and do telehealth with TN clients, subject to the practice board of MS (and scope of practice requirements for TN). You can't do it the other way around. Basically, if you are going to be physically practicing psychology in a state- regardless of where your client is located- you need to be appropriately licensed to do so in the state in which you are located. That home state will have primary legislative/board policy oversight, including sanctioning. That's the language in the regs I quoted in an earlier post about "The home state maintains authority over the license of any psychologist practicing into a receiving state under the authority to practice interjurisdictional telepsychology." I checked, an identical language appears in the pertinent TN regulation (link: Tennessee General Assembly Legislation)

My guess is that- if they ever get back to you- the TN board is going to tell you that if you are practicing psychology and are physically located in TN, you need to be licensed in TN. Even if they don't tell you that, it seems like it a requirement of psypact. Don't expect state Psych License Board members to be experts on the rules of psypact. At best, you can expect a reasonable level of comfort with their own state rules. These are generally volunteers, and all this psypact stuff is pretty new. If you still think this is possible plan, I'd suggest getting in touch with someone at psypact.

ETA: here the definition of "home state" from the psypact website:

" “Home State” means: a Compact State where a psychologist is licensed to practice psychology. In order to practice telepsychology services under PSYPACT, the psychologist must be physically present and providing services from their declared Home State.

If the psychologist is licensed in more than one Compact State and is practicing under the Authorization to Practice Interjurisdictional Telepsychology, the Home State is the Compact State where the psychologist is physically present when the telepsychological services are delivered. If the psychologist is licensed in more than one Compact State and is practicing under the Temporary Authorization to Practice, the Home State is any Compact State where the psychologist is licensed.

From: https://psypact.org/page/keyterms

 

[ClinicalABA]

Echoing that the bolded part of your post @ClinicalABA does, in fact, seem easier and not that bad.

Although, for anyone interested:
Mississippi's board has gotten back to me this morning, and they told me that I do not need to be a resident or located in their state in order to obtain a license or to see telehealth clients there, and that I can still got licensed as a non-resident living in a different state even if it is my first state that I'm licensed in.

Looking further into this, turns out that MS isn't even a psypact state (legislation was just introduced, but not passed yet). It may be the case that MS allows you to be licensed in MS and see clients via telehealth who are located in MS, even if you are not in MS yourself. However, the place where you are physically located while practicing psychology probably has some of their own rules about what you need to do to legally practice psychology there. So, you may be fine as far as MS board is concerned, but still subject to the regs of another state board where you are definitely not fine. MS board is not (and should not) give you any guidance regarding other states regulations or board policies.

 

[eeor1006]

Have you crunched the numbers? I suspect doing what you are proposing here is not going to make you that much money, but potentially makes you vulnerable to a lot of potential ethical and legal issues.

It is fairly common practice that a new faculty member, if so inclined, sees a handful of patients in the department in-house clinic for free till they get licensed. While I do agree with you it sucks you won't be compensated for your valuable work, in return, you are receiving free (typically solid quality) clinical supervision and administrative support. Also, if you are interested in testing, you will have access to a variety of testing kits. Usually you will get plenty referrals and accumulate your hours quickly.

To do what you are proposing here, you will be paying supervision, EMR, liability issurance, a business LLC/PLLC license, license fee for whatever state you will be licensed in, and Psychpact application fee. And you have to do your own marketing and fill your schedule. If you are interested in testing, you will have to purchase testing kits. I don't know how much the ongoing rate for supervision in your area in but where I am located $180 per hour is on the lower end.

As a new faculty member, you are going to be very busy. Do you really think all the headache and hassle to do what you posted is going to worth it?

 

[AcronymAllergy]

I'll just second a lot of what's already been said, while skipping a whole bunch of other content--at a minimum, when providing telehealth clinical services, you need to be licensed in the state you're located in as well as the state the patient's located in. PSYPACT doesn't really apply unless you're purporting to practice via PSYPACT, and some PSYPACT states still allow for telehealth into their state even if you aren't PSYPACT.

I suppose you could get provisionally licensed in the state you're in, and then have your supervisor oversee your telehealth cases. In those instances, at a minimum: your supervisor would need to be licensed in the state you're in (otherwise you probably can't practice under them with a provisional license) AND in the state the patient's located in. Basically, the supervisor needs to be able to step in and provide in and all services that you're providing under their license. As a supervisor, a supervisee providing telehealth can increase liability, so there are some folks who'd be hesitant. If going this route, I'd recommend following some of VA's telehealth protocols, like getting a patient's current (i.e., during the session) address/location and backup phone number in case emergency services are needed. Even if they aren't suicidal/homicidal, maybe they have a medical emergency mid-session; you still need to be able to get them help.

Your supervisor should probably also be available anytime you're seeing patients. Ideally on-site, but some states allow for being remotely available.

I would personally not refer to myself as a psychologist if practicing under someone's license and supervision in an effort to gain postdoctoral hours toward licensure in another state (and especially if having a provisional license in that other state). This could be different if you're, say, at a VA and required (by VA) to have a psychologist supervise you and sign off on your notes for a year, but you're fully licensed and practicing solely within the federal system.

Also: I second/third the concerns about using state resources for a personal private practice. If not already done, that approval is something I'd want in writing from facility-level leadership or equivalent. And even then, I just don't know that it's a good look. It'd be different if the facility were taking a cut of what you bill.