Massachusetts has not joined PSYPACT. As of 2026, the Psychology Interjurisdictional Compact has been adopted by 42 jurisdictions — 40 states, the District of Columbia, and the Northern Mariana Islands — but Massachusetts is not one of them. Bills to enact the compact have been filed in consecutive legislative sessions, and the current 194th General Court has both a House and Senate version of “An Act Establishing the Psychology Interjurisdictional Compact” pending. Until one passes and is signed, Massachusetts psychologists cannot use PSYPACT to serve clients in other states, and out-of-state psychologists cannot use it to serve clients here.
The Legislative Status
The pending bills would authorize Massachusetts to participate in the compact on the same terms as other member states. Neither has been enacted. An earlier version of information circulating online identified Chapter 358 of the Acts of 2020 as the enacting law, but that statute is an economic development bond bill titled “An Act Enabling Partnerships for Growth” and contains no PSYPACT provisions. There is no Massachusetts PSYPACT law on the books yet.
If a bill passes, implementation still takes time. The PSYPACT Commission has to recognize Massachusetts as a member and open its application portal to psychologists licensed here. Individual psychologists then have to obtain a prerequisite certificate from the Association of State and Provincial Psychology Boards (ASPPB) before they can apply for compact authorization. That sequence is the reason it is worth understanding the mechanics now.
What PSYPACT Would Let You Do
The compact creates two distinct authorizations, neither of which is a license. Your underlying license would remain a Massachusetts license, and both authorizations would depend on that license staying active and in good standing.1Psychology Interjurisdictional Compact (PSYPACT). Application FAQs
- Authority to Practice Interjurisdictional Telepsychology (APIT) would let you deliver telepsychology services to clients located in any other PSYPACT member state. You must be physically present in your declared home state while providing the service, and you can only declare one home state at a time.2Psychology Interjurisdictional Compact (PSYPACT). Practice Related FAQs
- Temporary Authorization to Practice (TAP) would let you provide in-person services while physically in another PSYPACT state where you do not hold a license, for up to 30 calendar days per year in that state.
APIT and TAP each have a separate ASPPB prerequisite: the E.Passport for APIT and the Interjurisdictional Practice Certificate (IPC) for TAP. Both verify that you hold a doctoral-level psychology license and meet one of six educational pathways. The most common pathway requires a doctoral degree from a program accredited by the American Psychological Association or the Canadian Psychological Association at the time your degree was conferred. Other pathways cover re-specialization programs, international credentials, and psychologists with long-standing licensure histories.3ASPPB. New Pathways to E.Passport
First-year costs run $440 for APIT ($400 E.Passport plus $40 Commission fee) and $240 for TAP ($200 IPC plus $40 Commission fee).1Psychology Interjurisdictional Compact (PSYPACT). Application FAQs Because the ASPPB certificate has to come before the Commission application, psychologists who obtain the E.Passport or IPC now would be positioned to apply for compact authorization the day Massachusetts goes live.
What Already Governs Telepsychology in Massachusetts
Regardless of PSYPACT, several Massachusetts rules already apply to psychologists providing services electronically to clients in the Commonwealth.
Mental Health Rights Under Chapter 123
Chapter 123 of the Massachusetts General Laws governs the rights of individuals receiving mental health services, including informed consent, access to records, and confidentiality. These protections apply to telepsychology sessions just as they do to in-person care.4Mass.gov. Massachusetts General Laws Chapter 123
Telehealth Payment Parity for Behavioral Health
Chapter 260 of the Acts of 2020 requires behavioral health services delivered through video or audio-only technology to be reimbursed at the same rate as in-person services. Unlike other telehealth provisions in that law that were tied to the COVID-19 emergency, the behavioral health parity requirement continues indefinitely.5General Court of Massachusetts. Session Law – Acts of 2020 Chapter 260 If Massachusetts joins PSYPACT, this reimbursement rule would apply to out-of-state psychologists serving Massachusetts clients under APIT.
Data Security Under 201 CMR 17.00
Anyone who handles personal information of Massachusetts residents must maintain a written information security program. Under 201 CMR 17.00, that program must include administrative, technical, and physical safeguards scaled to the size of the practice, the volume of data, and the sensitivity of the information. Specific requirements include designating employees responsible for the program, training staff, vetting third-party service providers, and encrypting personal information transmitted over public networks.6Mass.gov. 201 CMR 17.00 Standards for the Protection of Personal Information of Residents of the Commonwealth
This regulation applies on top of HIPAA. Many practitioners assume HIPAA compliance is enough; Massachusetts sets its own separate floor, and you should be able to produce your documented security program if questioned.
HIPAA Platform Requirements
All telehealth services provided by covered health care providers must comply with HIPAA. Your platform vendor must be willing to sign a business associate agreement, and the technology must support encryption of protected health information in transit and at rest.7Department of Health and Human Services. HIPAA Rules for Telehealth Technology Consumer-facing platforms like standard FaceTime or the free version of Zoom generally do not qualify because the vendor will not enter into a business associate agreement. Compliant platforms are widely available at annual costs ranging from a few hundred to a few thousand dollars.
Duty to Warn: A Boundary Worth Knowing
Massachusetts law limits the duty to warn to two situations: when a client explicitly threatens to kill or seriously injure a reasonably identified person and has the apparent ability to carry out the threat, or when the client has a known history of physical violence and the psychologist reasonably believes there is a clear and present danger of an attempt to kill or seriously injure an identified victim. Outside those circumstances, Massachusetts imposes no duty to warn.8General Court of Massachusetts. Massachusetts General Laws Chapter 123 Section 36B
PSYPACT does not replace state law. When you deliver telepsychology to a client in another state, that state’s rules govern the treatment relationship for matters like informed consent, mandatory reporting, and confidentiality, while your home state’s standards continue to govern your license. Some states set broader duty-to-warn triggers than Massachusetts. If Massachusetts joins the compact and you take on a client in one of those states, you would need to follow the client’s state rule for that relationship, even if Massachusetts law would be more permissive.
Insurance Reimbursement Is Separate
Compact authorization does not guarantee reimbursement. The PSYPACT Commission has stated that billing and insurance fall outside its purview, though it has worked with the American Psychological Association to educate insurers about compact authorizations.2Psychology Interjurisdictional Compact (PSYPACT). Practice Related FAQs Some commercial plans still require an in-state license number for claims processing, even in PSYPACT states. Verifying coverage before the first session is the only way to avoid unpaid work.
Steps to Take Now
Three things are worth doing while the bills sit in the legislature.
Check whether you meet an E.Passport pathway. If your doctoral program was APA-accredited at the time you graduated, you likely qualify, and starting the ASPPB application now means the certificate will be ready when Massachusetts opens the portal.
Confirm that your telepsychology platform meets both HIPAA and 201 CMR 17.00. Those obligations apply to your Massachusetts practice today, compact or no compact, and the security program has to exist in writing.
Read the informed consent and mandatory reporting rules in the states where potential clients live. That research will be required the moment you have APIT in hand, and it takes longer than most psychologists expect.