Interstate Massage Compact (IMpact)
Reducing Barriers to License Portability in the Massage Therapy Profession
(I originally wrote this on my other website on November 20, 2023 and have updated it a few times and am posting it here.)
The Interstate Massage Compact (IMpact) is a proposed program that will help Massage Therapists to be able to work more easily in other states temporarily. The Interstate Massage Compact will be created once 7 states pass a bill in a state that meets all of the requirements and implements the bill. That means legislators in the eligible states will need to write bills and get it passed in the states that want to join. Once passed, it can only be repealed with another bill.
History of the IMpact
The Department of Defense was offering a grant to various professions to help implement a compact license to help military families with people who are massage therapists to more easily be able to move from state to state as they are assigned to various places. The Federation of Massage State Boards applied and received the grant and began working on putting this together.
Press Release: March 18, 2021 – The U.S. Department of Defense has selected the massage therapy profession to receive technical assistance from The Council of State Governments to develop an interstate compact for occupational licensing portability.
The Federation of State Massage Therapy Boards submitted an application for assistance with establishing an interstate licensure compact for the massage therapy profession
“In September 2020, the Department of Defense (DOD) entered into a cooperative agreement with The Council of State Governments (CSG) to fund the creation of new interstate compacts designed to strengthen occupational licensing portability. In collaboration with the Department of Defense, CSG developed and administered a competitive application process to select the professions for initial compact development in late 2020 and early 2021.” ~ See IMpact Development (PDF) on www.massagecompact.org
In addition to FSMTB, the following entities have contributed to the Interstate Massage Therapy Compact development process:
American Massage Therapy Association
Associated Bodywork & Massage Professionals
Commission on Massage Therapy Accreditation
Alabama Board of Massage Therapy
Arizona State Board of Massage Therapy
Florida Board of Massage Therapy
Georgia Board of Massage Therapy
Mississippi State Board of Massage Therapy
Nevada Board of Massage Therapy
Oregon State Board of Massage Therapists
South Carolina Massage/Bodywork Panel
Tennessee Board of Massage Licensure
Texas Department of Licensing and Regulation
Virginia Board of Nursing
MEMBER STATE REQUIREMENTS
There is specific language in the proposed bill as to what states can become members of this compact. This comes directly from the bill language which can be found at www.massagecompact.org . (In bold text are my notes that need to be considered or confirmed.)
A. To be eligible to join this Compact, and to maintain eligibility as a Member State, a State must:
1. License and regulate the Practice of Massage Therapy; (NOTE: California, Wyoming, Kansas, Minnesota, and Vermont currently do not have state licensing in place but they can still pass a bill that can be implemented when they do get state licensing. )
2. Have a mechanism or entity in place to receive and investigate complaints from the public, regulatory or law enforcement agencies, or the Commission about Licensees practicing in that State; (NOTE: the proposed mechanism for this is a database called Massage Therapy Licensing Database (MTLD) that is being created by the Federation of Massage Therapy State Boards. Boards would have to join this. This database was part of the original plan when the FMTSB was created 18 years ago.)
3. Accept passage of a National Licensing Examination as a criterion for Massage Therapy licensure in that State; (NOTE: Currently this is the MBLEx but other exams could qualify if created and approved by rulemaking.)
4. Require that Licensees satisfy educational requirements prior to being licensed to provide Massage Therapy Services to the public in that State;
5. Implement procedures for requiring the Background Check of applicants for a Multistate License, and for the reporting of any Disqualifying Events, including but not limited to obtaining and submitting, for each Licensee holding a Multistate License and each applicant for a Multistate License, fingerprint or other biometric-based information to the Federal Bureau of Investigation for Background Checks; receiving the results of the Federal Bureau of Investigation record search on Background Checks and considering the results of such a Background Check in making licensure decisions; (NOTE: There are some states where background checks are not required so to be a part of the compact, that state would have set up a process for applicants to get that done. This list from ABMP (PDF) shows that CT, HI, ID, IN, MA, NH, SC, SD,WV and WI do not require a background check. )
6. Have Continuing Competence requirements as a condition for license renewal; (Note: That would mean that states without CE requirements would not be allowed. The list from ABMP shows CO, IN, ME, MA, OH and UT don’t have CE requirements. We also may have an issue as there is a difference between Continuing Competence and Continuing Education. The Compact defines it as: “Continuing Competence” – a requirement, as a condition of license renewal, to provide evidence of participation in, and completion of, educational or professional activities that maintain, improve, or enhance Massage Therapy fitness to practice. Technically our CE requirements do not show continued competence because they do not meet any standards of education and there is no testing done to complete a CE.)
7. Participate in the Data System, including through the use of unique identifying numbers as described herein; (NOTE: This database is called the Massage Therapy Licensing Database (MTLD aka Matilda ) and was created by FSMTB before this compact even came up and will be free for member states to use and populate. The SLB Portal will include licensure information, from multiple states if applicable; contact information; board and disciplinary action; school information, such as school name, location and education completion date; and more. Your state will have to join this database and input information to make this all work.)
8. Notify the Commission and other Member States, in compliance with the terms of the Compact and Rules of the Commission, of any disciplinary action taken by the State against a Licensee practicing under a Multistate License in that State, or of the existence of Investigative Information or Current Significant Investigative Information regarding a Licensee practicing in that State pursuant to a Multistate License;
9. Comply with the Rules of the Commission;
10. Accept Licensees with valid Multistate Licenses from other Member States as established herein;
B. Individuals not residing in a Member State shall continue to be able to apply for a Member State’s Single-State License as provided under the laws of each Member State. However, the Single-State License granted to those individuals shall not be recognized as granting a Multistate License for Massage Therapy in any other Member State;
C. Nothing in this Compact shall affect the requirements established by a Member State for the issuance of a Single-State License; and
D. A Multistate License issued to a Licensee shall be recognized by each Remote State as an Authorization to Practice Massage Therapy in each Remote State.
What states can join the compact?
All of them when they fulfill the specific requirements.
Special Notes : California, Wyoming, Kansas, Minnesota, and Vermont – No Licensing, but can join when they do implement state licensing.
Special Notes: These states do not have CE Requirments but can add them later: Colorado, Indiana, Maine, Massachusetts, Ohio and Utah. Ohio has already passed the compact bill.
NY and NE require 1000 hours of education so they would not people moving there with a lesser amount of education. New Hampshire, Connecticut, Maryland and North Dakota require 750 hours of education so they probably would not want to join unless they want to adopt the licensing exam that will be set up and required by the Compact when it is formed. The thing though is that these states with higher education requirements usually have the basics that most every state have and then pad the education hours with classes that are usually added later through CE in other states.
Ready to go: Alabama, Alaska, Arizona, Arkansas , Hawaii, Florida, Georgia, Idaho, Indiana Illinois, Iowa, Kentucky, Louisiana, Massachusetts, Michigan, Mississippi, Missouri, Montana, Nebraska, Nevada, New Jersey, New Mexico, North Carolina,New Hampshire, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Carolina, South Dakota,Tennessee, Texas, Utah, Virginia, West Virginia, Washington, Wisconsin
What massage therapists can apply for a compact license?
The Compact states that:
A licensed professional message therapist must:
Hold an active, unencumbered license in their home state.
Have completed at least 625 clock hours of massage therapy education. (The 625 hours can be made up of basic massage school PLUS CE Classes. CE classes are quite varied and do not test to show competency of completion. The hope is that the compact will write rules that will require that CE classes that will be counted will come from NCBTMB approved classes, REACH approved classes, ABMP and AMTA classes. It is unknown at this time how it will actually work out. 70% of the programs already provide at least 625 hours of education and then 85% provide at least 600 hours. )
Have passed a national licensing examination. (NOTE: If you did not take the MBLEx, you will have to – this needs to be confirmed. The commission could also allow other exams like the older accepted exams like the NCBTMB. Some states have their own exams like HI, NY, TX.)
Submit to a background check.
Have not been convicted or found guilty, or have entered into an agreed disposition, of a felony offense under applicable state or federal criminal law, within five years prior to the date of their application.
Have not been convicted or found guilty, or have entered into an agreed disposition, of a misdemeanor offense related to the practice of massage therapy under applicable state or federal criminal law, within two years prior to the date of their application.
Have not previously held a massage therapy license that was revoked by, or surrendered to, an applicable regulatory authority.
Have no history of any adverse action taken by the applicable body responsible for the regulation of the massage therapy profession in the applicant’s home state within two years prior to the date of their application.
Have not been convicted or found guilty, or have entered into an agreed disposition, of any offense, whether a misdemeanor or a felony, under state or federal law, at any time, relating to any of the following:
Kidnapping.
Human trafficking.
Human smuggling.
Sexual battery, sexual assault, or any related offenses.
Any other category of offense which the commission may by rule designate.
Who can move around from state to state?
The biggest point of confusion on this proposed compact is around who can move from state to state. Many people (like me at first!) were assuming that this would allow people to freely move from state to state once they applied for and were approved to receive a compact license. This is NOT True!
Moving Temporarily: The Interstate Massage Compact allows active-duty military personnel or their spouse to designate a home state and keep that designation as long as the service member is on active duty. It would allow massage therapists who move temporarily for seasonal jobs or in states where cities share state lines and have MT’s who might want to work in the neighboring city to move more easily. Franchises and chains could more easily move massage therapists to different areas that are lacking adequate numbers of massage therapists for special events or busy seasons.
Moving Permanently: If you move permanently, you will need to get licensed in your new home state as usual. You have to have an unencumbered home state license. If your home state charges, you need a new license. If your new home state isn’t part of the compact you cease to be eligible (even if you maintain a license in a compact state). Your home state must be your state of residence.
FAQs
The 625 hour requirement
The compact states: a massage therapist must have completed at least 625 clock hours of massage therapy education. This number most likely comes from the Entry Level Analysis Project (ELAP). The ELAP was created in 2012 by the 7 massage therapy organizations working together.
The language also allows that the rules making process will be able to have it so CE hours are included in this number. The commission would have to figure out a way to approve CE classes as they are all over the place and none of them actually test people to make sure they understand the material. The initial thought is that they would make the CE hours used have to be provided by AMTA, ABMP, NCBTMB and the FSMTB Reach program but it is still to be determined.
This restriction limits people and would require people to take extra training if needed to get the approved hours. It would be a burden of time and cost to massage therapists who live in states where there are less than 625 hours required for training.
From the FAQ’s on www.massagecompact.org it says:
“According to a 2022 FSMTB survey of massage therapy schools nationwide, 70% offer programs that provide at least 625 clock
hours of entry-level education and 85% provide at least 600 hours. The average number of clock hours of education was 723.”
My calculations show: 23 states are under the 625 hours required. 22 states require more than the 625 hours. The data that we do not have is the number of hours of education that each school in those states under the 625 are requiring in their programs.
The Exam Requirement
The compact also states :
“To enact the compact a member state must: Accept passage of a National Licensing Examination as a criterion for licensure.”
“To participate in the compact a licensed massage therapist must: Have passed a national licensing examination developed and administered by a national association of massage therapy regulatory boards.”
Currently that is the MBLEx created by the Federation of Massage State Boards. If you were grandfathered into your massage license and never took that exam, you would need to take the exam and pass. Hawaii has it’s own exam so the people there would have to take the exam.
Other exams could be created and accepted in the rule making process.
Will our licensing fees go up in states that join the compact?
(From Webinar on Youtube) line 23:41 - 24:41, it is further clarified:
"States will set a fee for the multi-state license just as they do for regular massage licenses, and then the commission will charge a fee with that as well. Typically, the fee for a multi-state license is more than your typical license... It is an optional addition pathway to multi-state practice."
How much will it cost to move to another state?
Answer: (From Webinar on Youtube) The money to pay for the multistate license will primarily come from fees charged to the massage therapists who choose to apply for and use the multistate license. These fees will include:
Compact Fee or Multistate License Fee: Therapists opting to hold a multistate license will pay this fee, which is set by the commission overseeing the compact. This fee is intended to fund the administration and management of the compact.
Home State License Fees: Therapists are still required to maintain their home state license and pay associated fees. The multistate license is an optional additional pathway for those seeking to practice in multiple states.
The intention is that only those therapists who utilize the multistate license will bear the financial costs associated with the compact, ensuring that individuals who do not use the compact are not financially impacted. States will also determine their specific fee structures and mechanisms for collecting these fees in alignment with the compact commission's guidelines.
Will it reduce the income of our state boards and put them at risk?
Answer from Patty Glenn with FSMTB in our Facebook Group:
It is true that some states will see a reduction in fees they receive from additional licenses issued for non resident therapists who obtain a multistate license. That said, this will be a gradual transition that also reduces administrative burden and can be planned for. In addition, the profession is in a growth phase and the potential increase in licensees will likely outpace any potential lost revenue from redundant licenses being issued. Compacts also help reduce the burden on the licensed public which is a part of public protection.
It is easy to boil things down to a simple “is” or “isn’t” answer but the reality with licensure compacts, as with most things in life, is that there are many layers to consider. With overall benefits, such as easing the burden on therapists, getting qualified people to work faster, increasing revenue, and reducing the strain on unemployment, compacts simply make sense, not just to the profession but to the regulatory community and the legislators.
Professional Associations Stance on the Compact
Our professional associations have been involved in this process since the beginning providing their input on the language in the massage compact.
Currently ABMP supports the compact outright, while AMTA has danced around from providing support letters to the first two states that implemented the compact to retracting their support to now not supporting it but also not using resources to go against the compact which tells me something more is at play here.
ABMP’s Position on the Compact – Letter of Support to WA Legislature Jan 2023
Learn About the Proposed Interstate Massage Therapy Compact Draft Bill 06/20/2022
AMTA’s Position on the Compact
Oct 24, 2023 – AMTA supports the Compact in OH bill. Note: letterhead is out of date citing incorrect presidents.
ABMP supports the Compact in OH bill. Letter dated April 18, 2023
AMTA and ABMP’s letters to Ohio Legislature. https://www.legislature.ohio.gov/legislation/135/sb56/committee
AMTA supports the Compact in Nevada
12/08/2023 AMTA’s postion on the IMpact. (Be sure to read the whole thing)
“AMTA fully supports the mobility of the massage therapy profession, but we will continue to oppose any legislative effort that creates arbitrary hurdles, and restricts or excludes, educated massage therapists who have met the requirements for licensure in their home state. When our Coalition partners are ready to join us in listening to the needs of the massage therapy profession, and truly collaborate to modify the IMpact so it benefits more massage therapists, then AMTA will work extensively to get it passed in all 50 states. “
AMTA thinks that the current compact language can be changed at the core before it is implemented, but it has been passed in Nevada and Ohio has it in process.
01/03/2024 : ABMP’s Statement on it all (be sure to read the whole thing)
“ABMP supports the IMpact because we believe in the mantra “perfect is the enemy of good.” There are approximately 320,000 massage therapists in the US. The overwhelming majority will likely never have to navigate the IMpact requirements to practice in another state. But progress as a profession matters, and enacting an interstate compact is an important step forward as a profession. Those who need or want to practice in other states—especially those moving to a state with more rigorous standards than that of their “home” state—will value the opportunity to obtain permission to practice in additional states with relatively minimal effort.
We believe the responsibilities of a leader include a willingness to collaborate and compromise. This is why we continue to support the IMpact effort.”
** Update: 07/18/2024 AFMTE Educational Congress. AMTA boldly states their position on the Interstate Compact and followed up with an email to attendees.
AMTA’s most recent update says:
Recently, AMTA and FSMTB met to discuss these concerns, leading to clarifications and specific intentions outlined in the joint letter below. The AMTA Board will further discuss the IMpact at its upcoming meeting on September 9-10 in Tampa, FL. We will make sure to update our community as we continue these important conversations.
In Tampa, a meeting of chapter GR chairs were informed that AMTA was no longer going to be using resources to hold back the passing of the IMpact and this statement was made to GR chairs:
To: Chapter Presidents & GR Chairs
Thank you to those of you that were able to attend the GR session conducted by James Specker, Christine Hoober, and Jeff Flom in Tampa. We have had some inquiries regarding what information may be shared with chapter boards and members if questions are brought to the chapter.
You may tell your board members that AMTA is still not in favor of the current version of IMpact; however, we will no longer dedicate resources to actively opposing IMpact. If you receive inquiries from members, please refer them to grinfo@amtamassage.org.
Chapters, as part of AMTA, cannot spend or utilize resources such as chapter funds, lobbyist efforts or communication platforms such as email, website and social media either to oppose or to support IMpact. Please understand that if additional changes to massage regulation/legislation are brought forward along with the Compact, the chapter should notify the AMTA GR team for guidance. Chapters should not take any action or comment on any legislation without first contacting the National AMTA GR team of James Specker and/or Christine Hoober at grinfo@amtamassage.org.
Here are the two write-ups that explain the why:
https://www.amtamassage.org/about/news/impact-update
https://www.amtamassage.org/about/news/interstate-compact2
AMTA’s website also has announced their most recent Strategic Plan that says:
Government Relations
Goal: AMTA works for effective licensing both to ensure the right to practice of massage therapists and to protect the public.
Objective: To establish portability of massage practice throughout the United States and its territories.
My concern is that they have been talking about licensing portability for over 80 years.
For more information visit the compact website -www.massagecompact.org
Join the Supporters of IMpact Facebook Group.
Follow the IMpact Facebook Page and Youtube channel.
Progress is moving ahead in about 20 states at this time. To get this implemented in your state a bill has to be passed in each state. That requires that each state find a legislator to sponsor the bill, get it passed and implemented in each state.
