Maryland Counselor Telehealth Rules: Out-of-State Practice and Board Complaints
For LCPCs, LPCs, and out-of-state counselors whose clients move to Maryland: what changed on October 1, 2026, how the new continuity-of-care rule differs from a Maryland license and the Counseling Compact, and what to check if a Maryland telehealth complaint arises.
Last reviewed October 3, 2026. This is general information, not legal advice.
New Maryland telehealth continuity-of-care rule
Beginning October 1, 2026, Maryland changed how certain out-of-state counselors may continue treating an existing client who moves or returns to Maryland.
Under HB 1483 (Chapter 242), a counselor who is licensed and in good standing in another state may qualify to continue providing telehealth to an established client in Maryland for up to six months when the statutory continuity-of-care requirements are met. The law repealed Maryland's previous temporary telehealth license mechanism for clinical professional counseling.
A qualifying counselor must:
- be licensed and in good standing in another state,
- have established the client-counselor relationship while the client was outside Maryland,
- no longer be able to provide in-person counseling because the client is now located in Maryland, and
- provide telehealth for continuity of care for no more than six months after the client relocates to Maryland, or returns after a continuous and nonincidental relocation outside the state.
This is a limited exception. It is not the same as holding a Maryland license, it is not the same as practicing under a Counseling Compact privilege, and it does not let an out-of-state counselor take on new Maryland clients.
Three different ways to practice with a Maryland client
Maryland license
Traditional authority to practice professional counseling in Maryland.
Counseling Compact privilege
Authority to practice in Maryland through the interstate compact when Maryland and the counselor's home state are operational for Compact privileges and the counselor meets Compact eligibility requirements.
Six-month continuity-of-care exception
A limited Maryland statutory exception allowing certain out-of-state counselors to continue treating a previously established client by telehealth for up to six months after the client moves or returns to Maryland.
These are different legal pathways. A counselor should determine which authorization actually applies before treating a client located in Maryland. For how complaints work under Compact privileges, see Counseling Compact complaints and investigations.
What if you treated a Maryland client from another state?
Professional licensing questions can arise when a counselor and client are located in different states. If a complaint involves telehealth with a Maryland client, determine:
- where the client was physically located,
- where the counselor was licensed,
- whether the counselor held a Maryland license,
- whether a Counseling Compact privilege applied,
- whether the six-month continuity-of-care exception applied, and
- the dates of the treatment involved.
An out-of-state license does not automatically authorize unlimited practice with Maryland clients. A Maryland complaint about unlicensed counseling may also lead to a report to your home-state board, so review your self-report obligations.
Military families and Foreign Service members
Qualifying active-duty servicemembers and spouses may be able to practice in Maryland through license recognition while stationed in the state, and beginning October 1, 2026, qualifying Foreign Service members and spouses may be able to practice under an out-of-state license during a Maryland assignment (HB 1120). Both are subject to statutory requirements and are not automatic. Recognition of an out-of-state credential does not remove Maryland's authority to enforce its professional standards, so a complaint can still lead to a Maryland regulatory process.
How BoardWise can help
If you receive a Maryland Board complaint or investigation notice involving interstate or telehealth practice, BoardWise can help you organize the notice, identify deadlines and jurisdictional issues, and prepare for the board process.
Start your Maryland board responseFrequently asked questions
- Can an out-of-state therapist treat a client who moved to Maryland?
- Only in limited circumstances unless the therapist holds Maryland authority to practice. Under HB 1483, effective October 1, 2026, a counselor licensed and in good standing in another state may continue telehealth with an established client for no more than six months after the client relocates to or returns to Maryland, if the relationship began while the client was outside Maryland and the statutory requirements are met.
- Is the six-month exception a temporary Maryland license?
- No. It is a limited licensure exception for continuity of care. HB 1483 repealed Maryland's earlier temporary telehealth license mechanism for clinical professional counseling.
- Is the continuity-of-care exception the same as a Counseling Compact privilege?
- No. They are different legal pathways with different requirements. A Compact privilege depends on Maryland and the counselor's home state being operational for Compact privileges and on Compact eligibility.
- Can the Maryland Board investigate a counselor who is not licensed in Maryland?
- A counselor who treats a client located in Maryland may face questions from Maryland regulators about the authority used. An out-of-state license does not automatically authorize unlimited practice with Maryland clients.