Telehealth for Occupational Therapists Across State Lines

For telehealth, an occupational therapist needs to be licensed, or to hold an OT Compact privilege, in the state where the client is located at the time of the session. Where the OT sits does not change that. The OT Compact model law says it outright: "the Practice of Occupational Therapy occurs in the State where the patient/client is located at the time of the patient/client encounter." A Minnesota OT seeing a client in Iowa by video is practicing in Iowa.

Why does the client's location control?

The OT Compact builds the rule into its definitions. Section 1 of the model law states the location rule, and its definition of a compact privilege repeats it (Section 2D). One of the compact's stated purposes is to "facilitate the use of Telehealth technology" (Section 1G), and it defines telehealth as "the application of telecommunication technology to deliver Occupational Therapy services for assessment, intervention and/or consultation" (Section 2Z).

In practice that means three things:

• Check location every session. A client who usually lives in Ohio but is spending the winter in Florida is in Florida for that visit. Florida is not in the OT Compact.
• Your home state license covers your home state's clients only. Every other state needs its own authorization.
• The rules of the client's state apply. Scope, documentation, supervision and any telehealth-specific requirements are that state's. Section 4C of the model law says a privilege holder "shall function within the laws and regulations of the Remote State."

Our sister site covers patient location verification in more depth.

Can the OT Compact cover my telehealth clients?

In the ten states issuing privileges, yes, if your home state is one of them. As of October 5, 2026, those are Minnesota, Ohio, West Virginia, Indiana, Virginia, Maryland, Tennessee, Wisconsin, Arkansas and Mississippi. A privilege is "equivalent to a license" (Section 2D), so it covers telehealth exactly as it covers in-person care. Each privilege carries the $75 Commission fee and a state fee, any jurisprudence requirement (Ohio, Maryland and Wisconsin among the issuing states), and a background check through your home board. See which states are issuing.

For clients in the 27 enacted states that are not issuing yet, and in non-member states such as California, Texas, Florida and New Jersey, you need a license. New York has only a bill filed.

Are there exceptions for a short-term or occasional client?

Some states have narrow ones, and they rarely fit telehealth well. New Jersey, for example, lets an OT or OTA licensed in a substantially equivalent state practice up to 60 days a calendar year without a New Jersey license, but only "in association with" a New Jersey licensed OT who first gets confirmation from the state's OT council and notifies it in writing (N.J.A.C. 13:44K-1.3). That is a supervised arrangement, not a general permission to see New Jersey clients from out of state. Read any exception's exact conditions before you rely on it, and our state license index notes the ones we have verified.

Does Medicare pay for OT telehealth?

Through December 31, 2027, yes. Section 1834(m)(4)(E) of the Social Security Act adds "a qualified occupational therapist" to the practitioners who may furnish Medicare telehealth services, for a period that now ends December 31, 2027. The Consolidated Appropriations Act, 2026 (Pub. L. 119-75, signed February 3, 2026) set that date in section 6209(b). The same section extended, through December 31, 2027, the removal of geographic limits and the home as an originating site (6209(a)) and audio-only telehealth (6209(e)).

Medicare does not change the licensing rule. For an OT in private practice, 42 CFR 410.59(c) requires being "legally authorized" to practice "by the State in which he or she practices." And CMS says it treats licenses through compact pathways "as valid, full licenses" for its federal license requirements (MLN Matters SE20008).

After 2027, OT telehealth under Medicare depends on Congress acting again. Our sister site tracks the details in Medicare telehealth through 2027, and our Medicare enrollment for OTs post covers the enrollment side.

Can I supervise an OTA by telehealth?

It depends on the state where the OTA is working. Supervision rules are among the least uniform parts of OT regulation:

• Oregon defines "routine supervision" as in-person contact at least every two weeks at the work site "or via telehealth," and "general supervision" as at least monthly direct contact in person "or via telehealth" (OAR 339-010-0005).
• Pennsylvania requires face-to-face individual contact on site at least once a month, including observation of the OTA performing OT (49 Pa. Code § 42.22).
• Kentucky requires at least two hours a month of face-to-face supervision, and defines face-to-face as "being physically present in the room" (201 KAR 28:130).

For OTAs on a compact privilege, the supervising OT must hold a license or privilege in the OTA's work state (Section 4D of the model law). See OTA supervision rules.

Which licensing setup suits a telehealth caseload?

1. List where your clients actually are. Not where your employer is based. Include clients who travel seasonally.
2. Use privileges where you can. If you live in an issuing state, privileges cover the other issuing states with less paperwork than a license in each. See what a privilege costs.
3. License the rest. By endorsement in most states; a full application in states that evaluate the whole file. See OT license by endorsement.
4. Keep one renewal calendar. Privileges expire with your home license; each license has its own cycle and CE. See keeping several OT licenses current.

Payer coverage and billing rules for telehealth are separate from licensing. Our sister company covers billing in telehealth billing after the flexibilities.

How do we help telehealth OTs?

An OT Compact Readiness Review ($149) maps your client states against your home state and tells you which can be privileges and which need licenses. The Compact Privilege Concierge ($299 first privilege, $149 each additional) prepares the background check and jurisprudence and guides you while you complete and submit each application yourself, as the Commission requires. We carry licenses by endorsement ($599 for OTs, $499 for OTAs per state) end to end, and our Annual Renewal & CE Compliance service ($299 per license, per year) keeps them all current. For practices hiring OTs across several states, see practicing occupational therapy in more than one state.