Seeing Home-State Clients While You Travel

Flip the usual telehealth problem around. Your clients are all at home in the state where you are licensed. You are the one spending three weeks at your sister's place across the country, or a month working from a rental near your kids' college. Can you keep your caseload going?

In most cases the core answer is yes, for a simple reason: licensure follows the client's location, and your clients have not moved. You hold the license for the state they are in. The complications are elsewhere, and they are worth ten minutes of checking before you pack.

Does the state you are visiting care?

The question boards actually regulate is counseling delivered to people in their state. Treating a client in Ohio from a laptop in Colorado is, in the ordinary reading of these laws, practice in Ohio. The ACA Code of Ethics (standard H.1.b) acknowledges the gap from the other direction: counselors practicing at a distance "may be subject to laws and regulations of both the counselor's practicing location and the client's place of residence." Few counseling boards have written anything about where the counselor sits, and silence is not a ruling. If you will spend a long stretch in one state, a short email to that board asking whether it regulates out-of-state clients served from inside its borders costs you nothing.

Two practical cautions follow. First, do not see anyone who is located in the state you are visiting, including a local friend of a client or a client who happens to be traveling there too. That is practice in that state. Second, if you plan an extended stay that starts to look like relocation, the analysis changes: your compact home state, your tax residence and your employer's rules can all shift. A month away is travel. Six months is a move.

What should you check before you go?

Your malpractice policy's territory

Read the coverage territory and any telehealth language in your professional liability policy, or ask the carrier in writing. Some policies define coverage by where services are rendered, and "rendered" can be read as where you are. Get the answer before the trip, not after a claim. More on this in malpractice coverage for multistate counselors.

Your emergency plan

Your crisis protocol probably assumes you know the local mobile crisis team and hospital. You still need the resources near the client, not near you, and they have not changed. What changes is your own reachability: time zones, spotty connections and a backup way to reach the client if the video drops during a hard session. Get a current phone number and a location confirmation at the start of each session, as you would at home.

Privacy where you are sitting

Hotel walls, shared houses and airport lounges are not your office. Use headphones, a private room and a secure connection. A mobile hotspot is often a better choice than an unfamiliar Wi-Fi network.

Billing and Medicare

CMS's telehealth FAQ says practitioners can furnish telehealth from their home and, if they have a physical practice location, can enroll and bill from that location as if the service were furnished in person. That answer speaks to your home. For anything unusual, such as a long stay or billing questions under a group's enrollment, ask your Medicare Administrative Contractor. Commercial payers set their own rules, and some contracts say where the clinician must be. Read the contract.

What about travel outside the United States?

Your state license still governs the session, because the client is in your state. But the country you are in has its own laws about working there, data handling and, in some places, health services delivered from its territory. Visa terms for tourists may not contemplate any work at all. Many malpractice policies exclude services rendered from outside the US. If you are going abroad for more than a short trip, get answers from your carrier and, where it matters, from someone who knows that country's rules.

A short checklist

• Confirm every client will be in a state where you are authorized.
• Get written confirmation of your malpractice coverage for where you will be.
• Update your crisis plan and backup contact for each client.
• Check your telehealth platform and connection on the road before the first session.
• Tell clients about the time difference so nobody misses a session.

If your travel turns into a pattern of seeing clients in more than one state, the next step is a privilege or a second license. Our Counseling Compact page explains which states are issuing privileges, and we are happy to talk it through.