Short version: Think of it like a driver's license. Every state has its own specific rules about how you get a driver's license. But they all also agree that if you have a driver's license in any state, you're allowed to drive in every state. And you are always required to know and follow the laws in the state in which you're driving.
No. Nothing about PSYPACT interferes in any way with any state's right to define and enforce scope of practice, standard of care, or public health protection.
Therapy has always been defined as taking place in the state where the client is physically located. If the client is sitting in their house in Massachusetts and working with their therapist via telehealth, then the therapy is taking place in Massachusetts, the psychologist must be licensed in Massachusetts, and the Massachusetts Board of Registration in Psychology enforces Massachusetts law to protect that client.
If that client moves to New Hampshire, then when they are sitting in their new house in New Hampshire, then the therapy is taking place in New Hampshire, the psychologist must be licensed in New Hampshire or hold an APIT under PSYPACT and be physically located in their declared "home state", and the New Hampshire Board of Psychologists enforces New Hampshire law to protect that client.
(At present, because Massachusetts is not yet a member of PSYPACT, if that client would like to continue working with their Massachusetts-licensed therapist, they must satisfy the demands of the law by driving across the border to Massachusetts and sitting in a parking lot during their therapy sessions. Yes, it really is that silly. But it is also what far too many clients are being asked to do, to spend their own money and time to commute across the border. If the client has moved too far away, or if they are a child or adolescent, or they don't have the extra time and money , or are for whatever other reason not in a position to solve the problem, they are forced to give up working with the therapist they have already built a trusting and effective relationship.)
The only difference is that the client located in a PSYPACT member state has the option of working with any psychologist who holds an APIT. That state's law still applies.
If a client is located in Massachusetts, Massachusetts law applies. That is true whether or not Massachusetts joins PSYPACT. The only thing that changes is that clients get more options to choose a provider who is a good fit and to continue working with that provider as their life circumstances change.
In fact, right now, the fact that MA has not joined PSYPACT means that MA-licensed psychologists have a bizarre incentive to move to almost any other state, establish a license and rent an office there, so that they can establish an APIT and see clients located in any other PSYPACT state.
Let's look at how it works:
Under current MA law (without PSYPACT):
A Massachusetts-licensed psychologist who also holds a full license in another state (e.g., Florida or Connecticut) may legally treat a client located in that state.
If that psychologist then provides services that are illegal in the client’s state (for example, gender-affirming care in a state like FL where that is banned, or conversion therapy in a state like CT where that is banned), that state may take action:
• discipline through its licensing board
• civil enforcement
• in some cases, criminal prosecution
The Massachusetts shield law already governs MA’s response:
• MA will not cooperate with out-of-state subpoenas, investigations, disciplinary requests, or extradition attempts related to care that is legal in MA.
• MA’s Board of Registration will not discipline an MA psychologist for providing care that is legal here, regardless of another state’s rules.
If MA joins PSYPACT, none of that changes.
The only difference is the route by which the psychologist becomes authorized to practice in the other state:
Instead of obtaining a full Florida license, the psychologist obtains PSYPACT credentials, which Florida accepts as granting authority to practice with clients located there.
The underlying legal structure is identical: the psychologist must still follow the laws of the client’s state, must still meet that state’s standard of care, and still risks discipline or penalties in that state if they break its law.
Massachusetts’ shield law continues to apply the same way: MA will not assist enforcement against an MA clinician for providing care that is legal here.
However, PSYPACT adds an additional safeguard:
If a psychologist is disciplined for violating another state’s law, in addition to whatever that state might do, the psychologist also automatically loses their PSYPACT privileges everywhere. It does not have any effect on their home state license unless their home state Board of Registration wants it to.
If a psychologist is disciplined for violating their home state's law, even if they are allowed to keep that home state license, they automatically lose their PSYPACT privileges everywhere.
This setup actually makes psychologists more cautious, not less, because they risk losing access to 43+ states at once rather than just one full license.
Well, since we're psychologists, we'll answer you the same way we would answer this kind of anxiety question in therapy... We can't promise you that there won't be.
But let's look at the data. Between August 2020 and August 2025, 17,432 APITs (telehealth credentials) were established, 14,487 of which were active as of August 2025.
During those five years, only 21 psychologists had those PSYPACT privileges revoked because they had disciplinary actions taken against them.
That is less than 1/3 of the fraction of psychologists in general who had disciplinary actions taken against them in the same time frame, according to data from ASPPB.
And, according to recent oral communication from the PSYPACT Commissioner, not a single one of those APIT revocations was because of disciplinary actions taken by a remote state. All of those psychologists lost their APIT teleheath credentials because they were disciplined by a state in which they held a full license, for conduct that had taken place in that state.
Any adverse discipline in any jurisdiction makes a psychologist no longer eligible to hold any PSYPACT credentials. That's a lot to lose! Therefore, under PSYPACT, psychologists have even more incentive to be even more careful about following the laws of whatever state the client is located in.
That does create a responsibility for the psychologists, to make sure that they know what those laws are and that they follow them. But, as we can see, that does seem to be something they have been very careful about. Even their own home state laws might have changed since they were first licensed!
Psychologists are expected to learn how to recognize a situation where we need to check what the current law is and get appropriate legal consultation. But, empirically, it seems that APIT holders have been doing a pretty good job of that so far.