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Telehealth Across the State Line

Missouri OT Jurisprudence · Put your knowledge to work in context.

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Telehealth Across the State Line

A Missouri-licensed OT lives in Springfield, six miles from the Kansas border. She provides telehealth to 12 clients. One client, a 16-year-old with a traumatic brain injury, moved from Missouri to Kansas three weeks ago but wants to continue weekly sessions with the OT. The OT's employer says her Missouri license is sufficient because the OT is physically located in Missouri and the platform's server is in Missouri. The client's Kansas Medicaid plan has asked for a copy of the OT's Kansas license. The OT has never applied for a Kansas license and has not checked Kansas telehealth rules. A second parent asks whether the OT can supervise a Kansas OTA who will treat the client in Kansas. The OT has a full caseload and does not want to disrupt the client's progress.

1. May the OT continue telehealth with the client in Kansas under her Missouri license? Explain.

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Probably not without Kansas authorization. The key question is where the client is located when services are delivered, not where the OT sits or where the server is. Missouri's license authorizes practice in Missouri; it does not authorize the OT to provide services to a client in another state. Kansas law and Kansas board rules determine whether the OT needs a Kansas license, a telehealth registration, or another authorization, and whether an exception applies. The employer's location argument is not a safe basis for continuing. The Medicaid plan's request for a Kansas license is a warning sign. The OT should pause the Kansas sessions until she or the employer verifies the requirement with the Kansas board. If Kansas requires a license, she should apply or transfer the client to a Kansas-licensed OT. Abrupt termination also requires a transition plan and documentation.

2. What should she do before the next scheduled session?

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She should contact the Kansas occupational therapy board or licensing authority and the employer's compliance department, document the inquiry, and obtain a clear answer in writing. She should also review the platform's policies and the client's Medicaid plan requirements. If Kansas authorization is required and not yet in place, she should not hold the session. She should tell the family promptly, explain the licensure reason without blaming them, and arrange interim coverage or a referral. If the client's needs are urgent, she should follow the employer's transition and safety procedures. She should not rely on a colleague's informal opinion or on the fact that prior sessions were not questioned. Continuing to bill while unlicensed in the client's state could create licensing and reimbursement problems.

3. What about supervising a Kansas OTA who will treat the client in Kansas?

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The supervision question is also governed primarily by the state where the client receives services and where the OTA practices. The OT should not assume that a Missouri OT license allows her to supervise a Kansas OTA in Kansas. She should verify Kansas rules on OTA supervision, including whether the supervising OT must hold a Kansas license and what frequency and method of supervision are required. If the OT is not authorized in Kansas, the ethical and practical solution is to arrange Kansas-licensed OT supervision rather than create a paper supervision arrangement. The OT should document the inquiry and any referral. Her Missouri scope of practice does not expand simply because the OTA is physically in Kansas and the OT is in Missouri.