Interstate Telehealth, Unlicensed Supervision, and Board Inquiry

The key issue is where the service is delivered, not where the psychologist sits. Telehealth to a client physically located in Nevada is generally practice in Nevada. A California license does not authorize it. Advertising Nevada telehealth and seeing five Nevada residents supports a finding of intentional or knowing practice, not an incidental contact. She must stop providing psychological services to Nevada-located clients until she holds a Nevada license or practices under a specific Board-recognized authority. If Nevada participates in PSYPACT and she obtains an E.Passport, that authority is limited to telepsychology and does not automatically authorize in-person practice or supervision of unlicensed persons in Nevada; verify current Board requirements rather than assuming reciprocity. She should also review the California clients: if they are physically in California, California law governs those sessions, but she still must comply with Nevada business and records rules for her Reno office. The Board may investigate unlicensed practice and may refer for cease-and-desist or disciplinary action. She should cooperate, preserve records, and not alter documentation.

Supervision is a licensed activity. A Nevada postdoctoral trainee seeing Nevada clients generally must be supervised by a psychologist licensed in Nevada under a Board-approved supervision arrangement, with a written supervision contract, defined hours, direct observation or review, co-signature, and disclosure to clients that the trainee is supervised. If Dr. Alvarez is not Nevada-licensed, her supervision may not satisfy Nevada requirements, and the trainee’s hours may not count. The psychometrist presents a delegation issue: a trained technician may administer and score certain tests under supervision, but the psychologist remains responsible for test selection, informed consent, interpretation, diagnosis, feedback, and test security. “Just testing” is not a separate unregulated task. The psychologist must ensure the psychometrist is competent with each instrument and that test materials are not disclosed improperly. Dr. Alvarez should suspend Nevada-facing services, obtain licensure or approved authority, formalize supervision, and correct advertising and intake disclosures before resuming.

She should respond through counsel if available, within the Board’s deadline, and cooperate rather than ignore the inquiry. She should preserve all records, including intake forms, supervision logs, test protocols, advertisements, and telehealth consent forms. She should not alter or backdate records; late entries should be clearly identified as addenda. She may assert applicable privileges or confidentiality protections for clients, but Board investigative authority generally requires production under the Board’s process, and she should seek legal advice about what must be produced. She should provide a factual chronology: when she moved, when Nevada clients began, what she believed about telehealth authority, who supervised the trainee, and what testing was performed. Remedial steps matter: stop unlicensed practice, remove misleading advertising, notify affected clients if required, and arrange lawful supervision. Because the complaint also concerns the trainee, she should not pressure the trainee to give a particular statement. The Board’s concern is public protection, so candor and prompt correction are more persuasive than claiming ignorance after advertising Nevada services.