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MPA members have been asking questions about the implementation of PSYPACT. Below are answers to frequently asked questions.

What credentials are required to participate in PSYPACT?

This is a several step-process which is completed on the PSYPACT website at: A psychologist must first apply for and obtain an E. Passport from the Association of State and Provincial Psychology Boards (ASSPB). Psychologists then apply to the PSYPACT Commission for an Authority to Practice Interjurisdictional Telepsychology (APIT) to practice telepsychology across state lines in PAYPACT states and/or apply to the PSYPACT Commission for a Temporary Authorization to Practice (TAP) which allows the psychologist to practice in-person up to 30 days in each PSYPACT state.


What is a PSYPACT/Compact State?

A PSYPACT/Compact State is a state, territory, or the District of Columbia that has enacted PSYPACT legislation and participates in this interjurisdictional psychology compact.

What is a Home State?

The Home State is the PSYPACT state in which the psychologist is licensed to practice.  For telehealth, it is also the state in which the psychologist is physically located (and is licensed to practice).

What is a Receiving State?

The Receiving state is the PSYPACT state where the client is physically located during telehealth visits.

What is a Distant State?

The Distant State is the PSYPACT state in which the psychologist is physically located when delivering temporary in-person, face-to-face services under the Temporary Authorization to Practice (TAP).

Can a psychologist deliver telehealth services from any location?

A psychologist must initiate the telehealth contact in the psychologist’s Home State. A psychologist licensed in multiple PSYPACT states can change their Home State designation as necessary depending on where they are located at the time of the teletherapy session.

In which state does the visit take place?

The psychological service takes place at the physical location of the psychologist.


Which state’s laws and regulations apply?

Scope of Practice. The psychologist is able to provide services under the authority of their home state license.

A psychologist practices under the scope of practice of the State Psychology Regulatory Authority of the Receiving State (for telepsychology) or the Distant State (for temporary in-person, face-to-face services). However, the psychologist’s scope of practice cannot exceed the scope of practice in the Home State. For example, if the Receiving State includes prescription privileges, and the Home State does not, the psychologist cannot prescribe in the Receiving State.

Laws which protect the health and safety of the patient/client and citizens of the state. The compact subjects the psychologist to laws of the Distant or Receiving State with regard to laws that protect the health and safety of the state’s citizens. This includes, for example, laws governing duty to warn, applicable state child abuse reporting requirements, elder abuse, record-keeping rules, and  informed consent, among other laws.


Which state initiates proceedings if there is a Board complaint against the psychologist?

The Home State, Receiving State, or Distant state can initiate Board proceedings against the psychologist. If the Home State or Receiving State issue an adverse action against the psychologist, then the authority to practice under PSYPACT is suspended. The Home State has the power to impose an adverse action against a psychologist’s license.


Which state has the authority to issue a subpoena to the psychologist?

A subpoena issued by a Compact State’s Psychology Regulatory Authority is enforceable in other Compact States.


How long do I have to retain records under PSYPACT? Different states impose different requirements for retaining records, and some have no requirements. APA’s Record Keeping Guidelines indicate that psychologists may consider maintaining full records for seven years after the last date or services or for three years after a minor patient reaches majority, whichever comes later. Given the varying state laws on this issue, it is safest to follow APA’s Record Keeping Guidelines.


Can I notify others that I am authorized under PSYPACT?

Under listed Certifications, the authorization holder may include the Authority to Practice Interjurisdictional Telepsychology (APIT) and/or Temporary Authorization to Practice (TAP) and indicate that it is granted by the PSYPACT Commission.  They can include the date issued and APIT or TAP number. They must not indicate that this authorization implies an advance skill, license, or education level.


Which state regulates the psychologist’s practice?

The PSYPACT commission obtained a legal opinion stating that the psychologist is subject to the Distant State or the Receiving State’s laws applicable to a psychologist licensed in that state that protect the health and safety of that state’s citizens. In addition, the psychologist is always subject to their licensing state(s) laws, rules, and regulations. The Receiving State or Distant State can refer a complaint to the Home State.


What Code of Maryland Regulations (COMAR) should I be aware of when practicing telehealth through PSYPACT?

All Maryland regulations relevant to the practice of psychology are applicable. In addition, Maryland has specific telehealth regulations found in COMAR 10.36.10, including the following:

  1. A psychologist practicing telepsychology shall establish safety protocols for emergencies or crises including local telephone numbers at the client’s location for: (a) Police, fire, and emergency mental health and medical services; (b) The local hospital emergency room; and (c) An emergency contact.
  2. Informed consent for telepsychology shall include: (a) Requirements for privacy such that only the psychologist and the client shall participate in, or be present during, a telepsychology session, unless otherwise agreed to by the psychologist and the client; (b) Actions to be taken if the technology used for the telepsychology session is disconnected or any other technological issues arise; (c) The emergency safety protocols required by §E(3) and (4) of this Regulation; and (d) Disclosure of the privacy and security risks of telepsychology and potential risks of disruption of telepsychology session.