Telehealth Counseling - Tennessee License Requirements: Can You Serve TN Clients If You’re Licensed Elsewhere?
- Ryan Burns
- 3 days ago
- 6 min read
The telehealth counseling Tennessee license requirements question usually comes down to one practical issue: where the client is physically located during the session. Tennessee board FAQs for multiple mental health professions say that if the client is in Tennessee, an out-of-state clinician generally must be licensed in Tennessee to provide treatment, including telehealth, unless a specific exception applies. [1-3]
In this article, you’ll learn:
The “client location” concept that drives most cross-state decisions
Two questions to answer before you schedule or continue sessions
Common scenarios that create risk (travel, college, co-parenting, relocation)
A practical workflow for location checks, documentation, and referrals
How practice infrastructure can reduce friction and protect continuity of care
🧭 Key takeaway: Treat “Where are you today?” as a clinical safety and compliance question, not small talk.
Why This Is Confusing (Even for Experienced Clinicians)
Telehealth feels “borderless,” but licensure usually isn’t
Telehealth makes care accessible, but licensure is still state-based. Many policies treat services as occurring where the patient is physically located, which is why cross-state telehealth often requires authorization in the patient’s state. [4,8]
Three common misconceptions make this harder:
“If I’m licensed somewhere, I can see my client anywhere by video.”
“It’s based on where the client lives, not where they log in.”
“If the client is traveling, it’s fine as long as it’s temporary.”
“Where the client is located” is often the key concept
Tennessee board FAQs for counseling/MFT and social work explicitly tie out-of-state telehealth to Tennessee licensure and note that the client must be in Tennessee for those services. [1,2] The psychology board FAQ adds that out-of-state telepsychology generally requires Tennessee licensure unless separately authorized (with examples such as PSYPACT, certain supervised trainee situations, some federal exceptions, or a free clinic rule). [3]
🧠 Key takeaway: “Lives in Tennessee” and “is in Tennessee today” are different compliance questions.
Telehealth Counseling Tennessee License Requirement: The Core Question to Answer Before You See a Client
Where is the client physically located during session?
Make client location a standard check at intake and at every session. It matters most in situations like:
College students who move between campus and home
Co-parenting schedules across state lines
Work travel and family visits
What license(s) do you hold that cover that location?
Once you know the location, ask: “What authorizes me to practice there?”
For clients physically located in Tennessee, Tennessee board FAQs state:
Counselors / MFTs / clinical pastoral therapists: out-of-state telehealth generally requires Tennessee licensure (outside a free clinic environment). [1]
Social workers: same general expectation. [2]
Psychologists: Tennessee licensure is generally required unless separately authorized (examples listed include PSYPACT and certain other limited situations). [3]
🔎 Key takeaway: “I have a license” isn’t enough. You need the right license or authorization for the client’s location for that session. [1-3]
Common Scenarios Therapists Run Into
You’re licensed in State A, client lives in Tennessee
If the client is physically in Tennessee during sessions, the safest baseline is: assume Tennessee authorization is required unless you can clearly document an exception. [1-3]
If you’re exploring pathways, your options typically include:
Applying for Tennessee licensure (discipline-specific process)
Using a compact privilege if your profession has an operational compact pathway for Tennessee
Practicing only under a valid exception (rare and specific)
Client travels between states (college, co-parenting, work travel)
This is where well-intentioned clinicians drift out of compliance.
Example 1: A Tennessee client logs in from another state for two weeks. Even if you’re Tennessee-licensed, cross-state practice questions can arise because the client is not physically in Tennessee. [10]
Example 2: A child alternates weeks in Tennessee and another state. A location-aware plan (and consistent documentation) prevents last-minute surprises.
📍 Key takeaway: Build the travel plan before it happens. It protects the client’s continuity and your scope at the same time.
You relocate but want to keep clients
Relocation is usually a “continuity project,” not a single checkbox.
A practical plan:
Confirm where each client will be during sessions
Confirm which states you are authorized for
Create a supportive transition plan when location makes ongoing therapy non-permissible [10]
What to Check (Without Turning This Into Legal Advice)
Your board rules for telehealth + out-of-state practice
Start with your own board’s rules and FAQs, then document what you relied on. Tennessee boards publish clear FAQ language about out-of-state telehealth to clients in Tennessee. [1-3]
If you’re relying on a compact, verify that it is operational for your situation:
Tennessee’s counseling board notes it does not yet have an anticipated start date to be actively participating in the Counseling Compact. [5]
The Counseling Compact’s official site lists which states are currently live. [6]
For psychologists, Tennessee participates in PSYPACT, which enables telepsychology across participating states when you hold the required PSYPACT authorization. [7,11,12]
Your malpractice insurer’s telehealth coverage
Ask your carrier to confirm coverage for:
Telehealth across state lines
Requirements tied to client location (and clinician location, if relevant)
Documentation expectations
Your informed consent language and documentation habits
At minimum, include:
Client location (city/state, and address for emergencies) at each session
A local emergency plan for the client’s location
What happens if the client is temporarily out of state
✅ Key takeaway: A one-line location note each session is simple, and it’s one of the highest-value risk reducers you can add.
Practical Workflow for Staying Inside the Lines
Location check-in at each session
Use a neutral script:
“What city and state are you in today?”
“What address are you at, in case we get disconnected and I need to send help?”
Then document it.
A plan for “client is temporarily out of state”
A simple decision tree:
Confirm location and expected return date.
Confirm authorization for that location.
If not authorized, pause formal therapy sessions and shift to allowed support (care coordination, scheduling, and referrals).
Document your steps and rationale. [10]
How to refer out (and keep it supportive, not punitive)
Try: “I want you to have uninterrupted support. Because you’re in another state right now, I may not be able to legally provide therapy during that period. Let’s set you up with care there, and we’ll plan next steps.”
How Practices Can Support You
Clear policies + templates reduce risk
Practice infrastructure can prevent common failure points:
Templates that prompt location documentation
Standard telehealth consent language
Clear “pause vs refer” guidelines
Admin systems that make location tracking easier
Examples:
Intake question about typical session location
Scheduler flags for frequent travelers
Appointment reminders that reinforce location expectations
If you’re building a Tennessee caseload, aligned care pathways also help. Clinicians benefit when clients can easily access specialized therapy services, psychological assessments, and Meet our team.
Options for Tennessee-Focused Clinicians
If you’re building a TN telehealth caseload and want infrastructure support
If you want to provide telehealth in Tennessee while keeping your workflow clean, supportive infrastructure matters: templates, admin support, and policies that reduce guesswork.
At ScienceWorks, we support coordinated care across services, including executive function coaching and pathways for clients who need different levels of support over time.
Contact us through our Careers page
About ScienceWorks Behavioral Healthcare
ScienceWorks Behavioral Healthcare is a Tennessee-based practice providing therapy, coaching, and assessment services with a focus on thoughtful, research-informed care.
Clients come to ScienceWorks for support across a range of needs, including:
Evidence-informed therapy through our specialized therapy services
Comprehensive psychological assessments
Skill-building support such as executive function coaching
References
Tennessee Department of Health. Frequently Asked Questions: Board for Licensed Professional Counselors, Licensed Marital and Family Therapists and Licensed Clinical Pastoral Therapists. Available from: https://www.tn.gov/health/health-program-areas/health-professional-boards/pcmft-board/pcmft-board/frequently-asked-questions.html. Accessed 2026 Feb 2.
Tennessee Department of Health. Frequently Asked Questions: Board for Social Worker Licensure. Available from: https://www.tn.gov/health/health-program-areas/health-professional-boards/sw-board/sw-board/faqs.html. Accessed 2026 Feb 2.
Tennessee Department of Health. Frequently Asked Questions (FAQs): Board of Examiners of Psychology. Available from: https://www.tn.gov/health/health-program-areas/health-professional-boards/psychology-board/psych-board/frequently-asked-questions.html. Accessed 2026 Feb 2.
Center for Connected Health Policy. State Telehealth Policies for Cross-State Licensing: Professional Requirements. Available from: https://www.cchpca.org/topic/cross-state-licensing-professional-requirements/. Accessed 2026 Feb 2.
Tennessee Department of Health. MultiState Regulations: Professional Counselors & Therapists. Available from: https://www.tn.gov/health/health-program-areas/health-professional-boards/pcmft-board/pcmft-board/multistate-regulations.html. Accessed 2026 Feb 2.
Counseling Compact Commission. Counseling Compact. Available from: https://counselingcompact.gov/. Accessed 2026 Feb 2.
Tennessee Department of Health. MultiState Regulations: PSYPACT. Available from: https://www.tn.gov/health/health-program-areas/health-professional-boards/psychology-board/psych-board/multistate-regulations.html. Accessed 2026 Feb 2.
U.S. Department of Health and Human Services. Licensing across state lines. Telehealth.HHS.gov. 2025 Apr 30. Available from: https://telehealth.hhs.gov/licensure/licensing-across-state-lines. Accessed 2026 Feb 2.
Center for Connected Health Policy. The Cross-State Licensure Continuum (fact sheet). 2024 Jul 18. Available from: https://telehealthresourcecenter.org/wp-content/uploads/2024/08/OutofState-Telehealth-Provider-Policies-FINAL.pdf. Accessed 2026 Feb 2.
American Psychological Association Services. What to know about doing telehealth in a different state. 2021 Jan 15. Available from: https://www.apaservices.org/practice/legal/technology/telehealth-different-state. Accessed 2026 Feb 2.
PSYPACT Commission. FAQ. Available from: https://psypact.gov/page/faq. Accessed 2026 Feb 2.
PSYPACT Commission. Practice-Related FAQs. Available from: https://psypact.gov/page/Practice_Related_FAQs. Accessed 2026 Feb 2.
ScienceWorks Behavioral Healthcare. Therapy & Assessments with Dr. Kiesa Kelly. Available from: https://www.scienceworkshealth.com/kiesakelly. Accessed 2026 Feb 2.
Disclaimer
This article is for informational purposes only and is not legal advice. Licensure rules can change, and details vary by profession and situation. Clinicians should consult their licensing board and, when needed, qualified legal counsel.
