Telehealth When the Client Is in Texas, California, and New York
Dr. F is licensed in Louisiana and holds an E.Passport and Authority to Practice Interjurisdictional Telepsychology (APIT) under PSYPACT. She has three telehealth cases: Ms. G, an adult in Texas; Mr. H, an adult who relocated to California for a six-month work assignment; and Ms. I, a Louisiana resident who will spend two weeks in California caring for a parent. Dr. F also plans to provide a one-time consultation to a colleague's patient who is physically in New York. Dr. F's Louisiana license is current, but she has never practiced outside Louisiana and is unsure whether her PSYPACT authority covers all three clients. She asks whether she needs a California license for the six-month and two-week situations.
1. Which of these clients may Dr. F see via telehealth under her current Louisiana license and PSYPACT authority? Explain the location rule.
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The key rule is that telehealth authority generally follows the location of the client at the time of service. Dr. F may see Ms. G in Texas if Texas is a PSYPACT member state and Dr. F's E.Passport and APIT are current. PSYPACT authorizes telepsychology into another compact state under the psychologist's home-state license, but the psychologist must hold the required PSYPACT authority and comply with the remote state's practice requirements.
Dr. F may not see Mr. H in California or Ms. I while Ms. I is in California unless Dr. F holds a California license or another valid California authorization. California is not a PSYPACT state, so the E.Passport and APIT do not create authority there. The two-week trip does not create an exception; the client is physically in California. The New York consultation is the same problem: New York is not a PSYPACT state, so Dr. F cannot rely on PSYPACT for a patient located in New York.
2. What should Dr. F do before continuing with the Texas client and when a client travels to a non-compact state?
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For the Texas client, Dr. F should verify that her Louisiana license, E.Passport, and APIT are active; confirm that Texas is a current PSYPACT state; and document the client's physical location at each session. She should also confirm that her informed consent covers telehealth, emergency procedures, and the limits of interstate practice. If the client has a crisis, Dr. F needs a local emergency plan and a contact in Texas.
For Mr. H and Ms. I, Dr. F should not continue telehealth while they are in California unless she obtains a California license or another lawful authorization. She should plan continuity in advance: identify a California-licensed provider, provide a warm handoff if needed, document the referral, and schedule sessions for when the client returns to a compact state or Louisiana. She should avoid abrupt termination. The same reasoning applies to the New York consultation: she should decline or refer unless she is authorized in New York. Documentation of locations, authority, and emergency plans is essential.