Why are therapists seeking licenses in multiple states?
You are probably reading this page to determine whether you can deliver telemental health across state lines legally, right? Some states have explicit requirements that allow LPC reciprocity if want to transfer your LPC licensure and practice professional counseling in another state. I've tried to make it easy for you--Here are direct links to all 50 states counselor reciprocity rules.
If the rules don't immediately appear, search the page for the link to rules/regulations. Then press "Ctrl F" and search the document for out-of-state, special conditions of licensing, license waiver, license by credentials, LPC LMHC LPPC LCPC endorsement, reciprocity, reciprocal and other similar search terms.
You will need to review and carefully compare requirements of the state you wish to have your current state license endorsed. *I do not warrant or interpret this information. Contact the state if you have additional questions. I can only answer questions about bringing your LPC license to Georgia.*
Taking Your Georgia LPC License to Another State
Every state has different licensing rules. And they vary widely. If you have a Georgia license, in some states it is quite easy to have your GA LPC license endorsed. For example, with the South Dakota Board of Examiners for Counselors and Marriage and Family Therapists, it can be as simple as providing proof of a current license with a clean history and paying a fee. Key points to remember:
1) Go to the the state's licensing board website. Read that board's rules on reciprocity or endorsement.
2) Very important: prior to submitting application, speak with peers who reside in that state and ask questions about the process.
3) Read how to practice telemental health across state lines.
What It Means To Transfer Your License
First, a "transfer" of license is a misnomer, but suppose you are a Licensed Professional Counselor in the state of Tennessee and relocate to Georgia. You would like to be issued a license without being required to submit an entire license application. So you ask GA's board if it will recognize your current TN LPC license and issue you a Georgia license by endorsement. This is endorsement and is basically the same process for each state.
Key Terms | Understanding State-To-State Licensing
First, licensees' situations differ, but I will help you understand how to analyze your license issue and provide tips for submitting the Licensure by Endorsement application.
There are three terms you should know: endorsement, reciprocity, and portability:
- The GA composite licensing board uses either Endorsement or Reciprocity in transfer of a psychotherapy license from another state.
- Reciprocity therefore generally equals endorsement in Georgia. The board uses the terms interchangeably.
- Portability of your LPC license usually means if you have a license in good standing it would be accepted in any state.
Portability has been proposed by the American Counseling Association (ACA) and other professional associations. Portability is controversial. There are obvious advantages to licensees who want to move their license from one state to another. Opposition to portability is also valid since there are ALOT of different graduate degree programs acceptable for LPC licensure.
The Essential Problem of Bringing Your License to Georgia
Examining the clinical supervision you received has become more important since effective 9/30/2018 the board has made a major change to it's definition of eligible "Supervisor". An LPC Supervisor must be credentialed as a LPCA CPCS supervisor or a national NBCC Approved Clinical Supervisor. The ACS is currently accepted in 15 states. I hold both credentials.
Georgia's board rules are not explicit and evaluated case-by-case..
Regarding Georgia, some additional questions are:
1) should you first you become licensed as an LPC in your home state then attempt to transfer through reciprocity,
2) not become licensed in your state, ensure you comply with Georgia's Composite board's licensing requirements, then apply for a Georgia license.
In either case, you will need to address whether you obtained supervision from a qualified LPC supervisor.
Here's the tough stuff. There are aspects of enforcing the new "Supervisor" definitions that may be a quandary for the board...
Georgia's Board May Opt to Not Accept Your Out of State Supervision
- The required CPCS is a credential created by the LPCA of Georgia.There isn't much reason for your home state supervisor to obtain the GA CPCS. The other accepted credential is the NBCC ACS
- If your supervisor is credentialed as a NBCC ACS Approved Clinical Supervisor, great! But if you want to transfer your license from North Carolina, there are only 92 ACS in the entire state--the 9th most populous state in the U.S. The odds your supervision was provided by an ACS are slim.
- The definition change is new. As of this writing, it hasn't been put to the test by the board. Will the board enforce the rule for Georgia LPC's and waive it for out-of-state applicants attempting Licensure by Endorsement or transfer?
- The definition change is very specific and has sweeping effect. LPCA of GA CPCS or National ACS credentials only. All Georgia business and professions board rules are now scrutinized by the Georgia governor prior to approval so it is possible the board would not even be allowed to make exceptions.
- Using North Carolina again, on July 27 2009 North Carolina House Bill 746 was passed creating a Licensed Professional Counselor Supervisor credential BUT it is not required as equivalencies are accepted.
- Will it be strictly enforced by requiring additional supervision by a Georgia approved supervisor? In some instances this could require 3-4 more years of approved directed experience by an approved supervisor. In this case, one might be too discouraged to pursue the Georgia LPC license.
Possible Solutions to the Problem
Solutions aren't clear cut because there are many variables. The board could take any of the following actions:
1) adopts a rule that allows non-credentialed supervisors with equivalent experience and training in clinical supervision. Something that allows the board greater discretion in enforcing the rule.
2) The board strictly enforces the new rule. This will close the door on many out of state applicants.
Other Transfer Requirements
You must still meet the following. It is accurate as of this writing and subject to change:
- Your state's licensing requirements meet or exceed Georgia's.
- Clean licenses from every state.
- Other requirements not explicit in board rules.
Prepare in Advance of Submitting Your Endorsement Application
For the sake of clarity, I will use the term endorsement throughout this license transfer blog post. First, there are three tiers of board decision making in determining whether to license you by endorsement:
- Rules: These are directly subject to GA LPC Licensing Law. The board writes rules that provide a starting point for how it will regulate licenses.
- Policies: these are less formal than rules and often change with the overall climate of licensing. For example, it has not been practical for the board to commit to rigid endorsement rules due to numerous states with different licensing requirements and many other variables.
- Finally, Discretion refers to the board's additional flexibility in enforcing rules.
It is very important you thoroughly read Rule Chapter 135-3-.04 "Licensure By Endorsement". I will provide all necessary links to these documents below.
Clearly Understanding Your License Situation
Board Rule Chapter 135-3-.04
The Georgia Secretary of State Licensing Boards Division web page is where you will find all information for your license including ethics continuing education and license renewal. Here is the link: http://sos.ga.gov/index.php/licensing/plb/43 (the SOS website will open in a new browser window). From the dropdown menu at the top of the page, select Board Rules. Attest to the copyright agreement. Open 135-3, "General Procedures". Scroll down to "Licensure by Endorsement".
Follow the three steps carefully, but especially pay attention to, "...so long as that other state or jurisdiction's requirements for the license in question are substantially equal to or greater than those in Georgia".
You must compare point-by-point the requirements for licensure in your state to Georgia's board. Georgia's board WILL scrutinize this aspect of your endorsement application. This helpful article on the Art of Reading Board Rules is a great place to start.
Now you are prepared to perform a side-by-side comparison by reading Chapter 135-5, "Requirements for Licensure".
Download the required endorsement application forms at http://sos.ga.gov/cgi-bin/plbforms.asp?board=41 and save to your computer desktop:
GA Composite Board Policies
* 8/6/19: Board policies have been removed from the board website.When and if they will be posted again is unknown.*
There are general rules that are uniformly enforced, but we cannot predict how the board will address the dilemma of transfer and licensure by endorsement. The new LPC "Supervisor" rule definition will need to be tested by the board.. Then you will know more how you might proceed with your application. Call me before you seek clarification from the board if you need assistance.