[Transcript] Episode 522: Real Talk: PCT Answers – Can My Supervisees Practice Across State Lines Under My Compact Privileges?

 

Evan Dumas 

You’re listening to Group Practice Tech, a podcast by Person Centered Tech, where we help mental health group practice owners ethically and effectively leverage tech to improve their practices. I’m your co-host, Evan Dumas.

 

Liath Dalton 

And I’m Liath Dalton, and we are Person Centered Tech.

 

Liath Dalton 

This episode is brought to you by Therapy Notes. Therapy Notes is a robust online practice management and electronic health record system to support you in growing your thriving practice. Therapy Notes is a complete practice management system with all the functionality you need to manage client records, meet with clients remotely, create rich documentation, schedule appointments and bill insurance all right at your fingertips. To get two free months of Therapy Notes as a new Therapy Notes user go to therapynotes.com and use promo code PCT.

 

Evan Dumas 

Hello and welcome to Episode 522: Real Talk: PCT Answers-Can My Supervisees Practice Across State Lines Under My Compact Privileges?

 

Liath Dalton 

This is a real question, and one that has been coming up increasingly.

 

Liath Dalton 

So first, we’ll introduce the Real Talk series, which is going to be one of those sort of segments that we do for this Practice Tech podcast, alongside guest interviews and our more like in depth and theoretical or philosophical discussions, and our quick wins practical application segments. So, hence the the Real Talk and PCT Answers.

 

Liath Dalton 

And we thought this was a great question to be addressing, because even though the only compact that is actually operational currently is PSYPACT, the interstate licensure and practice privileges compact for psychologists. The other two compacts, the Counseling Compact and Social Work Licensure Compact are soon to be operationalized, and as folks are, you know, considering what the implications of that for their own practice are, in a group context or a supervision context. There are additional implications, right?

 

Evan Dumas 

Mhm.

 

Liath Dalton 

And as people are planning what changes they might make to their practice once these other compacts go into effect, that’s what’s kind of precipitating this understandable question around how privileges apply, or don’t, to supervisees.

 

Liath Dalton 

So spoiler alert, though, we’re going to dive into it more and explain some of the contex,t is that the compacts function to provide individual licensure or practice authorization. The practitioner that receives that authorization is the only one to whom they apply. It does not then extend to supervisees.

 

Evan Dumas 

No.

 

Liath Dalton 

So the compact function is that the eligibility is based on a separate authorization to practice. Essentially, and this is how it works for for each of the compacts, or how it works for PSYPACT now and then we’ll be working for the Counseling Compact and Social Work Compact is that the practitioner holds an active license in their home state and then applies for compact privileges, which allow them to practice in other compact states.

 

Liath Dalton 

Notably for the Counseling Compact, that application will have to be made on a state by state basis.

 

Evan Dumas 

Mhm.

 

Liath Dalton 

Whereas for PSYPACT and the Social Work Compact, it applies across all of them. But it’s really important to note that these compact privileges aren’t a license.

 

Evan Dumas 

No.

 

Liath Dalton 

Right? They are a privilege to practice, and that privilege only applies to the individual who receives them. It doesn’t carry, carry on, can’t be sort of delegated to anybody else.

 

Evan Dumas 

Yeah, yeah.

 

Liath Dalton 

So what that means is that supervision requirements are going to continue to be, as they are now, be governed by state laws and regulations.

 

Evan Dumas 

Mhm, yeah.

 

Liath Dalton 

So, where the supervisee is physically located, and the licensing board of the state where they’re seeking licensure. And so just to reiterate, even if the supervisor holds compact privileges in other states, it doesn’t authorize supervisees to see clients in those states.

 

Evan Dumas 

No.

 

Liath Dalton 

Unless, unless, they are separately licensed, credentialed, registered, or otherwise permitted to do so under that state’s laws.

 

Evan Dumas 

Yeah, yeah.

 

Liath Dalton 

Yeah. So we’ve put together a nice little quick reference guide for this as well, which actually directly quotes and links to the source for each of the applicable compacts, and then also talks a little bit about the other profession type in our in our audience that we don’t want to forget about, which are Marriage and Family Therapists.

 

Evan Dumas 

Yeah!

 

Liath Dalton 

So Evan, do marriage and family therapists have a compact? Did I just forget to say something?

 

Liath Dalton 

Exactly. So there’s a big effort by the AAMFT for licensure portability, which is supposed to make it much easier and efficient as well, to get fully licensed in multiple states.

 

Liath Dalton 

So that provision for licensure portability is not something that is applicable to pre-licensure, to pre-licensed supervision across states, but the supervisor being fully licensed in other states would have more of a knock on effect than, because it’s full licensure, versus an authorization or practice privilege.

 

Evan Dumas 

Yeah.

 

Liath Dalton 

So now that you know this, that the the answer is no, and that this isn’t going to allow pre-licensure folks in your practice or under your supervision, to expand the sort of jurisdictions in which they can practice, how do you manage this? Because there are some really important risk management considerations here, right?

 

Evan Dumas 

Yeah, yeah.

 

Liath Dalton 

No, there’s no compact. But there is new, recent, sort of push to sort of have a common standard. So there is changes in the works.

 

Evan Dumas 

Yeah.

 

Liath Dalton 

You need to avoid assumptions that your license or your privilege covers supervisees. You want to be documenting supervision boundaries clearly.

 

Liath Dalton 

So there will be a difference in how this impacts supervision for marriage and family therapists.

 

Evan Dumas 

Oh, definitely.

 

Liath Dalton 

Right? Clarify explicitly where supervisees are authorized to practice and which clients.

 

Evan Dumas 

Mhm.

 

Liath Dalton 

Cover the cross jurisdictional piece as well. That if a client is not going to be physically located at the time of session in the defined area of authorized practice, that they then need to either schedule the session for when they will be, or go through a defined process with you to determine if, under that state law, they would be able to see the client while they are there.

 

Liath Dalton 

And always being, being mindful of what the liability and ethical implications of unauthorized practice are. Want to be imparting that to supervisees, so that they are really well equipped to navigate cross jurisdictional practice, legally and ethically. Not just the CYA aspect of things. If they’re under your supervision and practicing without permission, but also the what sort of practitioners they will be once they are fully licensed.

 

Evan Dumas 

Yeah.

 

Liath Dalton 

And encourage supervisees to also learn to navigate the process of checking permission to practice in other jurisdiction and reaching out to relevant boards to get clarification, if there is any question as to whether or not practice is permitted or what requirements for permitted practice are.

 

Evan Dumas 

Yeah.

 

Liath Dalton 

Yeah. So that’s part of why we wanted to address this and delve into it a little bit more beyond just the, it’s a no.

 

Evan Dumas 

Yeah. There’s more to it.

 

Liath Dalton 

Right? There are much, much broader implications for it in terms of how you manage supervisees, and what sort of parameters and support mechanisms you put in place for managing this aspect of supervision. And then, as always, especially in this context of supervision, it’s about setting a good precedent and example of how to navigate these areas of practice.

 

Liath Dalton 

So we hope you found this helpful. Check out the link in the show notes to the Quick Reference Guide, and thanks for joining us.

 

Liath Dalton 

Stay tuned for future Real Talk episodes, and maybe at some point we’ll also put a little uh form in where folks can submit their their topic ideas for Real Talk. Of course, we have no, no shortage of questions, uh, through all of the the weekly direct support and consultation sessions, we do our Group Practice Office Hours, which are for group practice leaders, and our Solo Practitioner Office Hours for solo folks.

 

Liath Dalton 

But you know, we always love having a broad section of questions and really being able to know what’s on folks minds, and what are the sort of areas of need where you could use support and guidance.

 

Liath Dalton 

So anyway, thanks for joining us for this inaugural Real Talk: PCT Answers episode, and we’ll chat with you next time.

 

Evan Dumas 

Yeah, talk to you next time, everybody.

 

Liath Dalton 

This has been Group Practice Tech. You can find us at personcenteredtech.com. For more podcast episodes, you can go to personcenteredtech.com/podcast, or click podcast on the menu bar.