Q: Can a Maryland LCPC provide telehealth to a client deployed out-of-state?
I am a Licensed Clinical Professional Counselor (LCPC) in Maryland. My client, who resides in Maryland, is being temporarily deployed out of state for 8 months with the military. She would like to continue therapy sessions via telehealth during her deployment. I am aware that typically both the client and therapist need to be in Maryland, but someone mentioned telehealth might be allowed for continuity of care. Can I legally continue to provide telehealth services to her while she is deployed out of state?
A:
Maryland regulations generally require that licensed mental health professionals only provide telehealth services to clients physically located within Maryland at the time of service. Maryland counselors providing telemental care must be licensed by the State Board of Professional Counselors & Therapists, and the state has strict requirements about practicing across state lines. The basic rule is that you need to be licensed in the state where the client is physically located during the telehealth session.
However, your situation involves important considerations that may qualify for exceptions. For military personnel, some provisions exist that extend practitioner-patient relationships for continuity of care purposes, particularly when an in-person medical evaluation has already been conducted. The Preserve Telehealth Access Act has extended telehealth flexibilities in Maryland through June 30, 2025, which may support your case for continuing care with your established client.
Your next steps should include contacting the Maryland Board of Professional Counselors and Therapists directly to inquire about specific military exceptions for continuity of care. Additionally, investigate licensure requirements in the state where your client will be deployed, as some states have temporary practice allowances for established provider-patient relationships. Document your existing therapeutic relationship thoroughly to demonstrate the necessity of maintaining continuity of care during this temporary deployment period.
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