Jurisdiction & Discipline

PSYPACT (H.2528 / S.1487): Jurisdictional / Disciplinary Brief

Psychologists cannot reasonably establish and maintain full licenses in every state where any client might ever come from, visit, or move to.  Each new license imposes significant financial and administrative burdens on all involved Boards (retrieval and analysis of archival documentation), as well as initial and ongoing burdens on the psychologist (fees, continuing education, paperwork).  Even when things go smoothly, licensing typically takes six months or more, and temporary-practice laws rarely bridge the gap. 

PSYPACT provides a streamlined alternative.  Despite minor differences around the edges,
all states follow the same rigorous standards set by the Association of State and Provincial Psychology Boards (ASPPB) and the American Psychological Association (APA).

Qualified psychologists may establish credentials to offer telehealth (Authority to Practice Interjurisdictional Telepsychology (APIT), 95% of credentials) or up to 30 days of in-person practice (Temporary Authorization to Practice (TAP)), in any PSYPACT member state. 

State Boards maintain full jurisdictional authority:

• PSYPACT does not change any state’s laws regarding scope of practice, standard of care, or public protection.  The only thing that changes is how the psychologist earns the right to practice in multiple states.  No “loopholes” or “back-doors” are created.

• • Psychologists must always follow the laws of the state where the client is located.

  • They must also always follow the laws of their home state (where they hold a full license).

  • Telehealth under PSYPACT requires the psychologist to be physically located in their home state at the time of service.

• PSYPACT does not change any ASPPB or APA standards regarding multi-jurisdictional or telehealth practice.  In general, if there are differences between states, psychologists are expected to follow the stricter laws, to seek consultation, and to prioritize client safety.

• PSYPACT does not change Massachusetts’s Shield Law.  Conduct that is legal in MA but illegal elsewhere could be prosecuted or disciplined in the distant state.  Massachusetts is not required to assist, nor is the MA Board of Registration required to take disciplinary action.

PSYPACT holds psychologists to high standards of professional conduct.  

• To be eligible, a psychologist must hold a full, unrestricted license in a member state, and have no history of any adverse disciplinary action in any jurisdiction. 

• If any PSYPACT member state disciplines a psychologist for any reason…

• • The state must report the action to ASPPB’s Disciplinary Data System within ten days.

  • The home state Board is notified, and may choose to take disciplinary action.

  • The psychologist’s PSYPACT privileges are permanently revoked.

• Because loss of PSYPACT privileges means losing practice rights in over 40 states at once, participating psychologists have strong incentives to stay compliant with all laws.  The data bears this out:  Over the past five years, the disciplinary rate for psychologists overall was over three and a half times higher than the disciplinary rate for APIT holders.  Out of over 17,000 APIT holders, only 21 have been disciplined; none for conduct over telehealth.

Bottom line:  PSYPACT preserves state authority, facilitates oversight and communication, and has produced no increase in disciplinary workload.

Prepared December 2025, by Aimee Yermish, Psy.D (aimee@davincilearning.org), on behalf of the Massachusetts Psychological Association Advocacy Committee.  Supplemental briefs (overview, merits, fiscal/administrative) and other information available on request.