The Counseling Compact now issues privileges in nine states and PSYPACT covers most of the country. The nation’s 85,587 BCBAs are still licensed state by state.
Key Takeaways
- The mobility gap: Counselors, psychologists and soon social workers have interstate compacts, while behavior analysts, regulated in 40 states and D.C., need a separate license in each.
- The compact rollout: Counselors can now use privileges across nine states, while social work’s compact, enacted in 35 states, has yet to issue a single multistate license.
- The operating cost: For multi-state ABA and behavioral health employers, telehealth supervision and cross-border staffing still run through state licensure and payer enrollment.
- The new incentive: Federal rural health scoring now credits states for compact membership, an inducement that only helps professions with a compact to join.
The instructions on the Counseling Compact’s website are written in the flat register of a licensing board. A Licensed Professional Counselor licensed by Tennessee and living there can now apply for the privilege to practice in eight other states. Once a transaction clears, the Commission says, the privilege number appears on the counselor’s dashboard almost instantly. Using Ohio’s current fees as its example, the site shows a counselor paying $55 to the compact for an initial privilege. Wyoming began issuing privileges on August 31, 2026, and Tennessee followed the next day, bringing the operating network to nine states.
A Board Certified Behavior Analyst in Nashville who supervises technicians serving families across the line in Kentucky has no equivalent screen to click through. Tennessee has licensed behavior analysts since 2014 and Kentucky since 2010, according to the Behavior Analyst Certification Board, and the analyst needs a license from each. Behavior analysis has no interstate licensure compact. Each state stands alone. As compacts for counselors, psychologists and social workers move from statute into daily use, that absence has become a structural difference in how ABA organizations and other behavioral health employers staff across state lines.
Counseling Compact, PSYPACT and Social Work Compact Status in 2026
The Counseling Compact opened applications for its first states on September 30, 2025. Arkansas became the seventh operating state on July 30, 2026, according to the Counseling Compact Commission, and Wyoming and Tennessee brought the total to nine: Arkansas, Arizona, Georgia, Indiana, Louisiana, Minnesota, Ohio, Tennessee and Wyoming. The Commission counts 29 more states plus D.C. in its readiness queue, working through steps such as adopting rules, setting fees and arranging federal criminal record checks, and it expects Pennsylvania to join later this year. Eligibility is limited to counselors licensed at the independent level. Recent graduates still completing supervised hours do not qualify.
Psychologists have had a working compact for longer. PSYPACT authorizes telepsychology and temporary in-person practice across participating jurisdictions, and its Commission recorded new enactments in Alaska and Iowa this summer. Minutes from a Kansas Behavioral Sciences Regulatory Board advisory committee meeting held after PSYPACT’s November 2025 annual conference reported 43 participating states and 18,130 telepsychology authorization holders, along with 1,130 psychologists holding temporary authorization to practice in person in compact states. Social work comes next. The Social Work Licensure Compact reached 35 enacted states as of July 2026, after Wisconsin, West Virginia and Alaska adopted it during their 2026 sessions, though it is not yet issuing multistate licenses.
Social work’s timeline shows how long the distance between enactment and use can be. That compact reached activation in April 2024, when its seventh state signed on, and in the more than two years since, its Commission has been adopting rules and building the shared data system that member boards need before any multistate license can issue. Counseling followed a similar arc, since its first privileges could issue only after participating boards had connected to a common licensure database, set up FBI background checks and adopted the compact’s rules. Any future compact for behavior analysts would face the same sequence, starting from a point that no legislature has yet reached.
Behavior Analyst Licensure Grew One State at a Time
Behavior analysis reached licensure later than counseling or psychology, and it arrived statute by statute. Nevada and Oklahoma enacted laws in 2009. Colorado became the newest state with House Bill 26-1425 this year, a year after Arkansas. Today the BACB lists 40 states and the District of Columbia with laws licensing or otherwise regulating the profession. California and Florida, both large ABA markets, are not on it.
The boards that administer those laws vary as much as their dates. Arizona, Ohio and Minnesota place behavior analysts under psychology boards, Virginia under its Board of Medicine, and Kentucky and Nevada under standalone behavior analysis boards. That variation is one reason a compact is harder to assemble than it sounds, since a compact rests on uniform minimum standards that every member state accepts. Much of that uniformity already exists through the national credential. As of July 1, 2026, the BACB counted 85,587 Board Certified Behavior Analysts, 5,246 Board Certified Assistant Behavior Analysts and 260,174 Registered Behavior Technicians, but certification is not a license, and where a state regulates the field, only the license authorizes practice.
Telehealth Supervision and the Patient’s State
Telehealth is where the difference shows most clearly. Guidance from the coding coalition that wrote ABA’s billing codes, in its model coverage policy, advises that in states with licensure laws, providers must check “the laws and accompanying rules or regulations for the state in which the patient resides” before delivering ABA remotely. Counseling and psychology operate under the same principle, and it is the problem their compacts were built to address. For ABA, a remote supervision session that crosses into a regulated state still requires the supervising analyst to hold that state’s license.
State Medicaid policy adds constraints of its own. Indiana’s 2026 reforms eliminated telehealth for key ABA codes, and CMS’s August ABA toolkit devotes separate sections to telehealth and telehealth supervision, a sign that remote delivery will draw scrutiny regardless of licensure. Its chapters on certification, licensure and how provider requirements differ between fee-for-service and managed care, amount to a federal acknowledgment of how much the rules vary from one state program to the next. Compacts also leave payer enrollment untouched. The Counseling Compact itself advises privilege holders to check with employers, online platforms and insurers before relying on a privilege, because credentialing and network participation remain separate processes.
What Licensure Compacts Mean for Multi-State Behavioral Health Operators
For behavioral health organizations that employ counselors, a nine-state network is small but usable. A group practice with clinicians licensed in Ohio can extend telehealth caseloads into Indiana or Georgia without a second full license for each clinician. Member states also share disciplinary information through the compact, which the Commission presents as a public protection feature. Each privilege carries its own upkeep, since it expires with the home state license and must be renewed separately in the Commission’s system. The Commission’s own worked example shows why timing matters: a counselor who buys a privilege 30 days before renewing a home license, then renews, pays the $55 fee twice, while one who renews first and applies afterward pays it once. Across a staff of dozens, that sequencing becomes a line item for whoever manages licensure.
For ABA operators, growth across state lines still means multiplying licenses, and the cost lands hardest on supervision. Payers and states increasingly specify supervision ratios, as Indiana did with one hour of Board Certified Behavior Analyst time for every eight hours of technician services, and in regulated states the supervising analyst must be licensed wherever the patient is. Federal constraints on the BCBA training pipeline that Acuity reported in May, including loan caps for graduate programs, compound the effect, because a license-bound workforce cannot easily be redeployed across borders to cover shortages. A broader behavioral health workforce shortage applies to clinicians generally, although counselors and psychologists now have a mobility tool that behavior analysts lack.
Rural Health Funding Rewards States That Join Licensure Compacts
A new federal incentive may widen the compact map. States competing for the discretionary half of the $50 billion Rural Health Transformation Program earn scoring credit for certain policy actions, and the Bipartisan Policy Center notes that two of them are workforce measures, joining licensure compacts and expanding scope of practice. Credit is available for enacted policies or for commitments to adopt them before 2028, and CMS can recover funds in later years if promised policies do not pass. That scoring gives legislatures a monetary motive to join compacts that already exist. It offers nothing to a profession without one.
The Social Work Licensure Compact’s first multistate licenses will be the next milestone for behavioral health employers, and the Counseling Compact’s list of operating states is set to lengthen as waiting states finish their preparations. Behavior analysts will watch both developments from the far side of a state line, holding a national certification that travels and a license that stays home.
