Out-of-state hours · telehealth · checked August 2026
Can you finish your hours from another state?
In short
Can I finish my supervised hours by telehealth from another state?
The five published Board answers, the four conditions, and the risk that is real — which is not the one people worry about
5 published Board answersThe prevailing belief in associate groups is that you cannot. The Board has published the opposite answer 5 times, most recently in February 2026 — and there is a real risk in this, but it is not the one people are worried about.
Two questions, not oneWhere the client isWhere you areThe four conditionsWhat nobody has answeredThree things that do not apply
The post this page was written for
I have yet to find anyone who has ever successfully completed their associateship via telehealth.
That is almost certainly a true observation and a false conclusion. It describes what employers have been willing to arrange. It does not describe a rule, and the rules that do exist point the other way.
The reframe
It is two questions, and they have different answers from different bodies of law.
This decides which state’s practice act applies. It is the question with a hard answer, it is answered by regulation, and it does not bend.
This decides whether the hours count toward your 3,000. No California statute addresses it. The only section in the entire scheme headed “location of services” hands the question to your employer.
Almost every confused conversation about this is two people answering different questions. Below, they are separated.
Question A
Where the client is: the rule that never bends.
16 CCR §1815.5(a)
All persons practicing marriage and family therapy, educational psychology, clinical social work or professional clinical counseling by telehealth with a client who is physically located in this State must have a current and active license or registration issued by the Board.
The words that matter are “or registration”. Your active AMFT, ASW or APCC registration satisfies this rule on its own terms. Nothing in it is about where the provider is sitting; the whole subdivision is about the client.
Subdivision (b) adds that telehealth services sit within the Board’s jurisdiction exactly as in-person services do — the same statutes, the same regulations, the same standards of care. And the definition of telehealth the regulation borrows, at BPC §2290.5, is built around the client being at an “originating site” and the provider at a “distant site”. The architecture of the law already assumes the two are in different places.
The mirror case is covered too, and it is worth knowing which way it runs. §1815.5(e): a California licensee or registrant may serve a client located in another jurisdiction only if they meet that jurisdiction’s requirements and that jurisdiction allows telehealth. So California does regulate you when your client leaves. It says nothing about when you do.
Question B
Where you are: no statute, and five published answers.
The supervised-experience sections — BPC §4980.43 for MFTs, §4996.23 for social workers, §4999.46 for clinical counselors — contain no reference to California, to state lines, to residence or to location of any kind. They are hour counts, week counts and category caps. That is a verified absence, not an oversight.
BPC §4980.43.4(a) — the section actually headed “location of services”
“A trainee, associate, or applicant for licensure shall only perform mental health and related services at the places where their employer permits business to be conducted.”
The identical sentence appears at §4996.23.3(a) and §4999.46.4(a). California’s only statutory rule about where a registrant may work points at the employer, not at the state line. Your employer can say no. The Legislature has not.
And the statute affirmatively authorizes the modality: §4980.43.3(i) says an associate or trainee may provide services by telehealth within their scope of practice, with no cap, no location clause and no time limit. §4996.23.2(j) and §4999.46.3(j) say the same for the other two registrations.
The Board has been asked directly, and has answered 5 times.
| Where | Dated | What it says |
|---|---|---|
| FAQs for Supervisors, question 22 | new February 2026 | A California Associate whose registration number is current and active, or an MFT Trainee, can practice with clients located in California while the supervisee is out-of-state or in another country if the supervisor permits it. |
| ASW FAQ, question 21 | revised January 2026 | Asked whether an associate traveling out of state may serve a California client and count the hours: “Yes”, subject to the four conditions below. The same document adds that there is no limit on the number of telehealth hours that can count toward the supervised experience requirement. |
| MFT FAQ, question 31 | revised February 2025 | The same question and the same answer, citing BPC §§2290.5, 4980.42, 4980.43 and 4980.43.2 and 16 CCR §1815.5. |
| APCC FAQ, question 22 | revised February 2025 | The same question and the same answer for professional clinical counselor associates, citing BPC §§2290.5, 4999.46 and 4999.46.2. |
| Telehealth FAQ | last updated June 2025 | “A California associate whose registration number is current and active can continue to practice with clients located in California while the associate is out-of-state if the supervisor permits it.” |
Read them in order and one thing changes. The 2025 answers are framed around an associate who is traveling. The February 2026 supervisor FAQ drops the word, drops any duration, and extends the answer to another country. What it keeps is the condition: if the supervisor permits it.
What “yes” is conditional on
Four conditions, all of which are ordinary.
These are the Board’s own, listed in the MFT and ASW FAQ answers. None of them is special to being out of state; they are the conditions on any associate’s hours, applied to this situation.
Not a formality. BPC §4980.43.2(d) requires the supervisor, within 60 days of supervision starting, to assess whether videoconference supervision is appropriate — considering your abilities, both parties’ preferences, and the privacy of both locations — to document that assessment, and not to use videoconference supervision if the assessment says it is inappropriate.
The same standards that apply to any California telehealth session, under BPC §2290.5 and 16 CCR §1815.5. Being physically elsewhere changes nothing about informed consent, emergency planning, or knowing where your client is sitting.
Two-way, real-time videoconferencing counts as face-to-face contact under §4980.43.2(b)(2), and there is no cap — nothing must be in person. Two limits do bite: telephone does not count at all, and supervisor contact must occur within the same week as the hours claimed.
W-2 employment or documented volunteer status, never an independent contract. Weekly logs. The supervision agreement. The employer’s permitted place of business. This is where the arrangement actually falls apart, and the next section is about why.
One date worth knowing
Videoconference supervision was on a sunset clause that would have expired on 1 January 2026. SB 775, chaptered 13 October 2025, deleted the sunset and extended the provisions indefinitely. If you read something written before autumn 2025 that treats remote supervision as temporary, that is why — and it is no longer true.
The risk that is real
The question nobody in California can answer for you.
Everything above is about California. None of it says anything about the state you are physically sitting in, and that is not an omission this page can fill.
| The open question | Where it stands |
|---|---|
| Does the state you are sitting in require its own credential? | The Board does not say, and has no authority to. 16 CCR §1815.5(e) covers only the reverse case — a California registrant serving a client in another jurisdiction. Whether Texas or New York or Oregon considers an unlicensed person delivering psychotherapy from inside its borders to be practicing there is a question for that state’s board, and it is the one worth an email before you move. |
| Is a permanent move treated differently from travel? | Not addressed. Three of the five Board answers say “traveling”; the newest does not, and none sets a day limit, a residency test or a temporary-absence standard. |
| Does the out-of-state experience regulation apply to you? | Unreconciled. 16 CCR §1833.2 requires experience “gained outside of California” to have been supervised by someone licensed in that jurisdiction. Read flatly, someone sitting in Nevada is gaining experience outside California. The Board’s published answers treat the arrangement as California experience — the client, employer, supervisor and registration are all Californian — but it has never printed a reconciliation of the two. |
The first row is the one to act on. It is also the one nobody in a California support group can settle, which may be part of why the thread that prompted this page never resolved.
Why it stays rare anyway
The obstacles are practical, and they belong to your employer.
§4980.43.3(a) allows an associate to be an employee or a volunteer and nothing else. An employee living in another state generally means the employer registering for payroll there, withholding there, and carrying workers’ compensation there — a real administrative cost for a practice with two or three people in it. “Just go 1099” is not available, and why not is its own page.
§4980.43.4(a) again: services only at the places the employer permits. A supervisor who does not want to think about any of the above simply says no, and there is nothing to appeal.
Which is the actual content of the original post. An arrangement that is lawful, documented by the regulator, and that no employer has done before is still a conversation you have to have from a standing start — with the five citations in the table above, which is what this page is for.
The first two are inferences from the statutory structure rather than positions the Board has stated, and are marked as such. The Board has published nothing about why the arrangement is uncommon, only that it is permitted.
Cited constantly, relevant never
Three things that do not apply to you.
| What people cite | What it actually is |
|---|---|
| The 30-day temporary practice allowance | BPC §4980.11 — not §4980.03, which is the definitions section. It lets someone licensed in another state serve an existing client who is located in California, for 30 consecutive days once a calendar year. It runs into California, not out of it. And the Board’s own FAQ answers the associate question in one word: asked whether a pre-licensed associate in another state can get one, “No.” |
| The Out-of-State Experience Verification form | Form 37A-304 for MFTs, 37A-202 for LCSWs, 37A-668 for LPCCs. It is completed by your out-of-state supervisor and filed with a Path B application — the route for somebody who was never a California registrant. Its attestation certifies that the hours complied with the other jurisdiction’s requirements. A California associate supervised by a California LMFT has nobody who can sign it. |
| An interstate compact | There is no compact available to you. California is not a member of the Counseling Compact or the Social Work Licensure Compact; the bill that would have joined the latter, AB 427, died in January 2026 with the Board opposed. Both compacts exclude anyone whose practice requires supervision. PSYPACT is for psychologists, and the Board of Psychology’s published action plan lists “California remains outside of PSYPACT” as a success measure. No MFT compact exists anywhere. |
All three come up in every thread on this subject, and all three are answers to somebody else’s question. The provisions that govern your situation are the two in the sections above.
Nothing here is legal advice. If you are planning a move, the two things worth doing before it are getting your supervisor’s written agreement and asking the licensing board of the state you are moving to whether it considers you to be practicing there. If it is a fully licensed move you are contemplating rather than an associate one, that is a different page; if you are still counting, the hours calculator works from your own numbers and sends nothing anywhere.
Where every figure came from
Sources.
The Board's published answers
The regulations and statutes
- BBS Statutes and Regulations, January 2026 edition — every section quoted on this page is reproduced here
- BPC §4980.43 — supervised experience, with no geographic condition in it
- BPC §4980.43.2 — direct supervisor contact, videoconference as face-to-face, the 60-day assessment
- BPC §4980.43.3 — employment status, and subdivision (i) on telehealth
- BPC §4980.43.4 — location of services: the employer’s permitted places
- BPC §4980.11 — the temporary practice allowance, for out-of-state licensees serving clients in California
- BPC §2290.5 — the definition of telehealth, originating and distant sites
The rest
- BBS temporary practice allowance FAQ — “No” for pre-licensed associates
- BBS — planning to supervise by videoconference: telephone does not count
- MFT Out-of-State Experience Verification, form 37A-304 — read for who it is addressed to
- SB 775 (2025) — deleting the sunset on videoconference supervision
- Counseling Compact — the member map, and the exclusion of anyone requiring supervision
- AB 427 (2025-26), the Social Work Licensure Compact bill, which died on 31 January 2026
Where this page says the Board has not addressed something, the documents checked are the five FAQs above, the Board’s newsletters from spring 2024 to spring 2026, the full FAQ index, and the 2025 and 2026 legislative summaries. Absence established by looking is worth printing; absence assumed is not.
