In this blog post about the Interstate Massage Compact we wanted to give you a brief overview of what Compacts are and why they exist, as well as focus on a few of the professional issues that we see with this Massage Compact in particular. If you have yet to visit our Compact Web page we would highly encourage you to do so after reading this blog.

Current system in Washington: The system that is currently in place for licensed massage therapists wanting to come from other states to Washington to work is called, “Licensure By Endorsement”. WAC 246-830-035 provides for licensed massage therapists from other states that have substantially equivalent requirements to be granted a license in Washington. If the massage therapist comes from a state that does not have substantially equivalent requirements there is WAC 246-830-037 Transfer Programs, that will guide the massage therapist in getting the additional education they need to qualify for a Washington massage license. 

Why do we have Occupational Licensure Compacts:  Through licensure compacts, states establish uniform standards to lower barriers to multi-state practice while preserving a state's practice act and initial licensure process. States that meet the eligibility criteria join interstate compacts by agreeing to the uniform provisions through the legislative process. Essentially, the goal is to create a more streamlined process for licensed professionals to work in multiple states without having to get a license in each state that they want to work in.

Massage Licensure Compact:  The Interstate Massage Compact was created via a partnership between the Department of Defense (DoD), Council of State Governments (CSG) and the Federation of State Massage Therapy Boards (FSMTB). This Compact does not become effective until seven states pass legislation to enter into the Compact agreement. 

One of the largest issues WSMTA has with the Interstate Massage Compact has to do with the model selected -- the Nurse Licensure Compact.  

• • WSMTA believes this model was selected by the committee essentially because it was deemed the simplest. It created mobility with the least amount of effort/involvement for the states involved. What most folks do not understand is that your mobility is only temporary. A multistate licensee can work in another Compact state but the Compact does not help them should they want to move to another state. This was a major misunderstanding for nurses and seems to be for massage therapists as well. 

  • WSMTA also believes that this model would remove too much regulatory authority from the states, transfer regulatory control to the Compact Commission and provide too much unregulated freedom of movement to the Multistate Licensee (the massage therapist).  Without controls built in to ensure the safety of the Multistate Licensee and the public, it could also create extra expense for Member States, Multistate Licensees and the Compact. 

  • If WSMTA had been asked to give input in the beginning of this process we would have advocated for modeling the Massage Compact after the Physical Therapy and Occupational Therapy Compacts. Those Compacts have something that is referred to as “Compact Privilege”. The primary benefits of “Compact Privilege” are:

• • The regulatory agency in each Compact state knows which Multistate Licensees are working in their state. Making it easier to keep them updated with regulatory changes and find them should there be complaints against them.

  • States that require a jurisprudence exam (like Washington) can administer that exam prior to the multistate licensee working in that state. Thus ensuring that they are aware of the scope of practice and any other unique regulatory requirements that the state might have.

In conversations with a representative with CSG we did learn that the Interstate Massage Compact Legislative Model Language can be amended, but seven states would have to agree to the amended language for the Compact to be activated. And any states that had already passed the current language would have to go through their legislative process to amend the language to match, if they wanted to participate in the amended Compact.

Multistate License Qualification:  The term for an Interstate Massage Compact license is “Multistate License”.  The first question you might ask yourself, if you are curious about a multi state massage license is, “Do I qualify for a Multistate License?” Here are the qualifications contained in the Legislative Model Language, by clicking HERE, but we are going to focus on the following,

The answer to the question, “do I qualify for a Multistate License”  for many massage therapists in Washington that have received a license more recently will likely be a simple “yes”. You attended a massage education program of at least 625 hours and you took the MBLEx and received your Washington massage license. As long as you do not have a criminal record, your license is in good standing and you pay a fee you could apply for and receive a Multistate License.

But the answer for many Washington massage therapists who have been licensed for a loooong time is not so straight forward. Take me for example.  I attended a massage program in 1984 that was 48 hours long. I did A&P, and other basic sciences in college. I took a state created written exam and a state created practical exam and received my massage license from the Washington Department of Licensing in 1985. In 1992 I took the NCBTMB exam to become nationally certified. The way the Compact language reads right now I would have to cross my fingers that the Compact Commission, once formed, would maybe create some Rules that might help me. Will they allow me to cobble together 577 hours of continuing education in massage to make up the difference between 48 hours and 625 hours? Will they allow my taking of the NCBTMB certification exam to qualify as a national exam (currently the only national exam that meets the definition in the legislative model is the MBLEx). I am not the only very experienced, successful massage therapist in WA in this situation! A very well known Washington massage therapist and educator attended a 60 hour massage program, took the state written and practical exam and has had a thriving practice ever since. She would have to cross her fingers too and hope the Compact Commission Rules will give her, the ability to cobble together 565 hrs. of massage continuing education and she would have to pay to take and pass the MBLEx if she wanted to be able to obtain a multistate massage license within this Compact.

625 Hours of Massage Education: What should be required in lieu of 625 hrs. in a massage education program? In the examples above the number of hours of continuing education to reach 625 hours is a very significant number of hours. 

The committee that developed the Compact language chose 625 hours because of the Entry Level-Level Analysis Project (ELAP). ELAP is a great piece of work that helped to define what the entry-level minimum education should be for a massage therapist to practice safely.  Many massage therapy organizations came together to sponsor this work so it has the support of the vast majority of the massage community.

The ELAP analysis stated that it was a particular content/curriculum of education that was of primary importance, and that it would take about 625 hours to deliver that content. The question and potential problem for the massage profession has to do with the massage therapist who graduated from a 60 hour program and might be allowed to make up the difference of 565 hours with random massage continuing education content. Is that really going to protect public safety? 

Jurisprudence exams and differing scope of practices: The current Compact language does not allow states to administer a jurisprudence exam to Multistate Licensees. The onus for making sure a Multistate Licensee knows the rules in all the states that they might work in falls to the individual. Most massage therapists have no idea how different the regulations for massage are from one state to another. They likely do not even know where to look to find the regulations. 

Health care provider vs personal service provider: In Washington, massage therapists are somewhat unique in that they are classified as healthcare providers. In most states massage therapists are personal service providers. 

In Washington we have finally won the respect of other healthcare providers and massage consumers. We have shown that we can help people to relax and unwind and we can successfully treat their musculoskeletal issues too! Let’s not just give that away for the sake of portability.

Conclusion: WSMTA is a big supporter of greater portability in the massage profession. We wholeheartedly endorse the idea of greater standardization in the regulation of the massage profession. But let's make sure that it benefits and uplifts the professionalism of massage as both wellness and treatment.

If we allow anyone with just any random level of massage education to work in Washington then why did we increase the minimum education hours from 500 to 625, why do we have Licensure By Endorsement and Transfer Programs?

WSMTA supports the many military families that spend some time in Washington. The Washington Legislature and the Board of Massage are already hard at work making it easier for these families to move from one deployment to another and more easily obtain a professional license.

This was a very quick perusal of a few of the professional issues with this particular Compact. For a more in-depth dive please take a look at our Compact web page.

Later this week we will be sending you information about some of the structural issues with this Compact and what some possible solutions might be to those issues. After that we will be sending out a poll to find out what your thoughts are about the Compact and if the Compact would personally help you in your situation and how it would help you. This information will then be passed on to Washington Legislators.

Thanks in advance for your time and dedication to educating yourself about the issues.