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Interstate Massage Compact -- Mobility and Structural Issues (Part 1)

21 Dec 2023 9:23 PM | Robbin Blake (Administrator)

In this blog post about the Interstate Massage Compact, we wanted to discuss more about what mobility means within the Compact (Part 1), as well as focus on some of the structural issues that we see with this Massage Compact (Part 2). If you have yet to visit our Compact Web page we would highly encourage you to do so after reading this blog.  Also, if you did not read the prior blog, you can view it at: Interstate Massage Compact--What It Is and Professional Issues

We use a lot of examples in this blog.  Please remember that at the time of publication, the Interstate Massage Compact is not active and the states we reference are not Member States or non-Member States of the Interstate Massage Compact at this time, these are all examples.

Some useful definitions: In this blog we will be using the following terms quite a bit:

  • Home State: means the Member State which is a Licensee’s primary state of residence where the Licensee holds an active Single-State License.
  • Member State: any State that has adopted this Compact.
  • Multistate License: a license that consists of Authorizations to Practice Massage Therapy in all Remote States pursuant to this Compact, which shall be subject to the enforcement jurisdiction of the Licensing Authority in a Licensee’s Home State.
  • Remote State: any Member State, other than the Licensee’s Home State.
  • Single-State License: a current, valid authorization issued by a Member State’s Licensing Authority allowing an individual to fully practice Massage Therapy, that is not a restricted, student, provisional, temporary, or inactive practice authorization and authorizes practice only within the issuing State.

If the Interstate Massage Compact was already in existence, then an LMT who joined the Compact would have a Multistate License which would authorize them to practice in any other Member State which had joined the Compact.  The state in which this LMT lived is the LMT’s Home State and any other Member State this LMT works in outside of their Home State is considered to be a Remote State.  This LMT’s Single-State License is the license of their Home State. 

For example, I live in Washington, which would be my Home State and I have a Single-State License here which is my Washington massage therapy license.  If I apply for and obtain a Multistate License, because I want to work in Ohio, which is another member of the Compact, then Ohio would be a Remote State to me.  I then hold two licenses:  my Washington State massage license and my Compact Multistate License.

Obtaining a Multistate License: Before an individual LMT can join the Compact, the State where they live, has to join first.  Once their state joins, and if the LMT meets the Compact eligibility requirements, then that LMT can choose to join the Compact if they want to.  If a state joins the Compact, it is up to the individual LMTs in that state to make a decision to join the Compact – just because a state becomes a Member State of the Compact, the massage therapists in that state do not automatically also become members.  They have to individually meet the Compact requirements and individually apply to join.  Here are some examples:

  • My Home State is not part of the Compact: If the state in which I live does not join the compact, then I cannot join the Compact.
  • My Home State, which was part of the Compact, decides to withdraw: If the state in which I live withdraws from the Compact, then I and all LMTs who reside in that state and have Multistate Licenses will lose our Multistate Licenses and cannot join the Compact while living in that state.
  • My Home State is part of the Compact and I want to work in another Member State (also known as a Remote State): I apply for my Multistate License in my Home State.  Once I obtain it, I can then work in any other Member State of the Compact.  I must maintain my residence and my Single-State License in my Home State, but I can work in any other state that belongs to the Compact.

A Multistate License allows you to work in another state, it does not assist you to move to another state: This is the most misunderstood part of most Compacts.  All healthcare Compacts, to our knowledge, have this same stipulation.  Joining the Compact does not help LMTs to move from one state to another and transfer their massage license, it only permits them to work in other Member States while they maintain their residence in their Home State.  Here are some situational examples:

  • My Home State is a Member State and I want to work in a non-Member State:  In this example, my Home State is Washington and I want to work in Idaho, which in this example is not part of the Compact.  I would have to obtain an Idaho massage license to work there.  Having a Multistate License will not allow me to work in Idaho since Idaho is a non-Member State.  If I have no desire to work in other states outside of Washington and Idaho and Idaho never joins the Compact, then it would make sense for me to maintain my Washington massage license, obtain my Idaho License and not join the Compact.

  • My Home State is a Member State and I want to work in two Remote States:  In this example, my Home State is Washington and I want to work in Arizona where I like to spend winters and Wisconsin where I have family, both of these states are also member states.  My Home State is Washington and I have my Washington State License.  I join the Compact and obtain my Multistate License.  Winter comes and I travel to Arizona and do massage there. I live in a motorhome with my husband and we travel back to Washington in spring.  During summer, I travel to Wisconsin and do massage there while I stay with my brother’s family for a few months and then I return back to Washington.  In this example, I maintain my Washington massage license and I join the Compact and obtain a Multistate License to work in other Member States.

  • My Home State is a Member State and I want to work for a large multistate employer in another Member State:  In this example, my Home State is in Washington and an employer hires me to work in their Casino Hotel in Las Vegas, Nevada and Nevada is another member of the Compact.  In all situations, I have to maintain my home residence in Washington, which means I would have to obtain secondary housing in Las Vegas, as I can only work in Nevada, I can’t move there as part of the Compact.  Someone, either myself or my employer would need to pay for temporary housing while I work in Las Vegas.  I would also have to bring the necessary clothing and household goods with me to stay there for a period of time (or purchase them in Nevada) which would be an added relocation expense.

  • I move to another Member State:  In the instance that I move my residence to Nevada because I’ve been working at the Casino Hotel for a while and they offered me a regular job, I will have to do the following:

    • Obtain a Single-State License in the Member State you move to:  I would need to obtain a Single-State License from Nevada through their “Licensure by Endorsement” process (I will discuss this process in the next section). This means that with my Washington massage License, I am able to apply to the Nevada State Board of Massage for a Nevada massage License.

    • Obtain a new Compact Multistate License:  It is possible the Compact Commission, once created, could create different rules about this, but at this time a Compact License is obtained through your home state.  If you move, your Home State changes which means that I would also need to obtain a new Multistate License through Nevada.  It is possible the Compact Commission could create rules allowing me to transfer my Home State designation within the Commission and therefore I could transfer my Multistate License to Nevada as my new home state, but since the Compact does not yet exist, this would be speculation.  

These are things to consider when deciding to join the Compact, if it is ever activated and our state joins:

  • Is it cheaper to obtain a Single-State massage License, or is it cheaper to join the Compact and obtain a Multistate License if you only want to work in one additional state?

  • Are all of the states you want to work in Member States of the Compact?  If not, then you should do an analysis to determine if it’s cheaper to join the compact or to obtain a license for each state you want to work in.

  • Who pays to relocate you to the new work location, including the personal items needed for an extended stay?  If you are not self-employed, is it you or your employer paying for the relocation?  A reminder this cannot be a permanent change of residence, otherwise you would have to obtain a new massage license in the state you have changed your residence to.

  • If you are not staying with relatives, friends or living in a vacation dwelling that you or your family own, who pays for your lodging while working in a Remote State?  Since you are required to maintain your residence in your Home State, working in other states requires additional lodging expenses for you.  If you are not self-employed, is it you or your employer paying for these expenses?

As we have stated, the Compact helps you to work in other states, it does not help you to move to other states.  Moving from one state to another, if you already have a massage license, is done through “Licensure by Endorsement”.  This process will not change should the Interstate Massage Compact go into effect.

Licensure by endorsement – moving from state to state: As we mentioned in the prior blog and in the section before, the system that is currently in place that enables licensed massage therapists to move to another state and transfer their massage license, is called “Licensure by Endorsement”.  This system will remain in place even should the Compact become activated.  Generally, for most states, Licensure by Endorsement, means that the massage therapist moving to your state has:

  • a massage license in good standing from the state they are moving from,

  • the equivalent educational requirement in the state they are moving to, and

  • passed a test, such as MBLEX, NCBTMB or a state-based test

For a licensed massage therapist wanting to move to Washington or live in another state and work in Washington, they would do so by 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.

The purpose of licensure by endorsement:  Almost all states that regulate massage want massage therapists moving to their states or working in their states from another state to be compatible with the massage therapists licensed in their state.  The only way they can do this is to set standards via Licensure by Endorsement, which is, as we described above, based on a level of base education equivalent to the state you are going to move to (or work in), having a massage license in good standing and having passed an exam. 

In the prior blog, we talked about professionalism and why the 625-hour educational requirement to join the Compact will affect some massage therapists and overall what it means to our profession here in Washington.  This is why what comprises 625 hours of massage education is very important and why we want massage therapists to make this determination and not regulators.  To read more about this topic, refer to the prior blog at: Interstate Massage Compact--What It Is and Professional Issues

Now we are going to turn our attention to the issues created by taking the Nurse Licensure Compact and using it as the basis for the Interstate Massage Compact.  This blog is continued in the Interstate Massage Compact -- Mobility and Structural Issues (Part 2).

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