The Relocated Client and the E.Passport Gap

Maryland licensure authorizes practice where the client is located only to the extent Maryland law and the other jurisdiction allow. Once J lives in Virginia, the service is telepsychology into Virginia. Virginia is a PSYPACT state, and PSYPACT’s E.Passport is the mechanism that lets a psychologist licensed in a PSYPACT state practice telepsychology into another PSYPACT state. Dr. Whitaker’s Maryland license alone is not enough. Without an active E.Passport, she should not continue after the move. She should apply immediately, confirm activation, verify that her Maryland license is in good standing, and comply with Maryland’s telepsychology regulations. She should not assume a temporary-practice exception applies. If the E.Passport cannot be obtained before the move, she must plan a clinically appropriate transition: identify a Virginia provider, obtain releases, provide a summary, and avoid abandonment. The informed-consent discussion should cover the new location, emergency resources in Virginia, and limits of confidentiality.

California is not a PSYPACT state. PSYPACT does not authorize practice into non-participating states, and Maryland licensure has no extraterritorial effect. Dr. Whitaker cannot lawfully provide therapy to the adult client while he is physically in California unless she holds a California license or qualifies under a specific California exception. The general emergency exception is narrow: it permits limited contact to address an imminent emergency until appropriate services are available; it is not a six-week treatment authority. She should arrange a planned interruption, provide referrals in California, document the clinical rationale, ensure coverage, and resume Maryland sessions only after he returns. If the client is a risk, she should follow emergency protocols. She should also check whether her malpractice coverage covers services in non-PSYPACT states; it may not.

The associate is not an independent licensee. In Maryland, a psychology associate may practice only under Board-approved supervision, and the supervisor remains responsible for the case. Even if the associate is physically in Maryland, the client is in Virginia, so the associate’s authority depends on Virginia’s supervised-practice rules and PSYPACT. An associate ordinarily does not hold an E.Passport, and PSYPACT applies to licensed psychologists, not associates. The associate should not take over video sessions into Virginia merely because the supervisor is Maryland-licensed. Options: the supervisor obtains E.Passport and continues; a Virginia-licensed provider takes over; or sessions pause until the family returns. If supervision continues, document a supervision contract, session-by-session review, emergency contact, and informed consent naming the supervisor. Check Board regulations before changing the treatment structure.