South Carolina CMHC Licensure Guide

Over the past several years, the Counseling Compact has emerged as one of the most significant developments affecting licensure portability for professional counselors in the United States. Designed to allow licensed professional counselors to practice across participating states without obtaining full licensure in each jurisdiction, the compact represents a major shift in how counseling practice may operate across state lines. Interstate licensure compacts have already been implemented in several other professions, including nursing and psychology, and the Counseling Compact represents the counseling profession’s effort to address long-standing barriers to interstate practice (National Board for Certified Counselors [NBCC], 2024). Although the legislative adoption of the compact has spread rapidly across the country, the transition from legislation to operational implementation has been slower than many counselors anticipated. Passing compact legislation in a state legislature represents only the first step. States must also complete regulatory alignment, background check procedures, and secure data-sharing integration before issuing interstate practice privileges. Over the past several months, however, several meaningful developments have occurred that counselors should understand. These developments indicate that the compact is gradually transitioning from a legislative framework to an operational system that will affect clinical practice in the coming years. Operational Launch of the Counseling Compact One of the most important developments since the end of 2025 is that the Counseling Compact is now operational in several states. As of early 2026, three states have completed the technical and regulatory requirements necessary to begin issuing privileges for interstate counseling practice: Arizona, Minnesota, and Ohio. Ohio officially became operational on January 5, 2026, joining Arizona and Minnesota as the first jurisdictions able to issue interstate practice privileges under the compact framework (Counseling Compact Commission, 2026a). This milestone represents the first time counselors have been able to actively use the compact to obtain authorization to practice across state lines. Counselors who live in one of these operational states and hold an independent, unencumbered counseling license may apply for privileges to practice in the other operational compact states. For example, counselors licensed and residing in Arizona may apply for privileges in Minnesota and Ohio, while counselors residing in Minnesota or Ohio may apply for privileges in the other operational states (Counseling Compact Commission, 2026a). Although the system currently includes only three operational states, the launch demonstrates that the compact infrastructure is now functioning and capable of supporting interstate practice privileges. The Rapid Legislative Expansion of the Compact While operational implementation remains limited, the legislative adoption of the compact has expanded rapidly. As of March 2026, thirty-eight states and the District of Columbia have enacted legislation joining the Counseling Compact, representing a significant majority of U.S. jurisdictions (Counseling Compact Commission, 2026b). The states that have enacted compact legislation include Alabama, Arizona, Arkansas, Colorado, Connecticut, Delaware, Florida, Georgia, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland, Minnesota, Mississippi, Missouri, Montana, Nebraska, Nevada, New Hampshire, New Jersey, North Carolina, North Dakota, Ohio, Oklahoma, Rhode Island, South Carolina, South Dakota, Tennessee, Utah, Vermont, Virginia, Washington, West Virginia, Wisconsin, and Wyoming, along with the District of Columbia (Counseling Compact Commission, 2026b). This widespread legislative adoption reflects a growing recognition among policymakers that mental health professionals require greater mobility in order to meet increasing demand for services. Interstate compacts allow states to maintain regulatory authority over professional licensing while also enabling clinicians to provide services in multiple jurisdictions without navigating the burdensome process of obtaining full licensure in each state. Implementation Is Occurring in Phases Despite the large number of states that have enacted compact legislation, most are still working through the steps required to activate the system. According to the Counseling Compact Commission, thirty-six additional states and the District of Columbia are currently progressing toward operational readiness (Counseling Compact Commission, 2026a). Operational readiness requires the completion of several technical and regulatory processes. These include establishing FBI background check compliance, integrating licensing databases with the compact’s national data system, adopting rules consistent with compact requirements, and connecting to the CompactConnect platform used to process interstate privilege applications. Because these processes involve coordination between state licensing boards, regulatory agencies, and the national compact commission, implementation timelines vary significantly from state to state. As a result, the compact will likely continue expanding gradually as additional states complete the required steps. Michigan’s Current Status Michigan is not currently a member of the Counseling Compact, but legislative activity related to the compact has taken place in the state. Michigan House Bill 4591, introduced during the 2025–2026 legislative session, proposes adopting the Counseling Compact within Michigan law (Michigan Legislature, 2025). The bill was introduced in June 2025 and passed the Michigan House before being transmitted to the Michigan Senate on October 30, 2025 (Michigan Legislature, 2025). As of March 2026, however, Michigan has not yet enacted the compact legislation, meaning counselors licensed in Michigan are not currently eligible to participate in the compact system. The existence of pending legislation suggests that Michigan may still consider joining the compact in the future, but participation would require passage of the legislation and subsequent implementation steps before counselors could apply for interstate privileges. States That Have Not Yet Joined the Compact Although the compact has expanded rapidly, several large states have not yet enacted the legislation. As of early 2026, some of the most notable states outside the compact include California, Illinois, Michigan, New York, and Oregon (Counseling Compact Commission, 2026b). These states represent large populations of both counselors and clients, meaning their eventual participation could significantly expand the reach and impact of the compact. However, legislative priorities and regulatory considerations vary widely among states, and the timeline for potential adoption in these jurisdictions remains uncertain. Understanding the Privilege-to-Practice Model One important feature of the Counseling Compact is that it does not create a national counseling license. Instead, it uses a privilege-to-practice model that preserves state regulatory authority while allowing counselors to obtain permission to practice in multiple states. Under this model, counselors maintain their primary license in their home state, defined as the state where they reside. If the home state is a member of the compact, the counselor may apply for privileges to practice in other compact states. Each remote state grants a privilege that allows the counselor to practice within that jurisdiction while remaining regulated by both the home state and the remote state licensing authorities (Counseling Compact Commission, 2026c). To qualify for compact participation, counselors must hold an independent counseling license at the highest level available within their state, maintain an unencumbered license, meet educational requirements established by the compact, and complete an FBI background check (Counseling Compact Commission, 2026c). Fees Associated With Compact Privileges The Counseling Compact Commission has established a standardized administrative fee structure for interstate privileges. Counselors applying for a privilege must pay a $30 administrative fee to the compact commission for each privilege issued. In addition, each remote state may charge its own administrative fee for granting the privilege to practice (Counseling Compact Commission, 2026c). As a result, the total cost of obtaining a privilege varies depending on the state issuing the privilege. For example, Ohio’s current fee structure results in a total cost of approximately $55 for an initial privilege, although fees may differ in other jurisdictions (Counseling Compact Commission, 2026c). Privileges generally expire when the counselor’s home state license expires and must be renewed accordingly. Implications for Telehealth Practice One of the primary motivations behind the Counseling Compact is expanding access to mental health services through interstate practice, particularly via telehealth. Under traditional licensing rules, counselors must hold a license in the state where the client is physically located during the counseling session. This requirement can create significant barriers for clients who move between states, travel temporarily, or live near state borders. The compact addresses this issue by allowing counselors to obtain privileges in multiple states without completing the full licensure process in each jurisdiction. Once more states become operational, the compact may significantly expand the availability of interstate telehealth services (NBCC, 2024). However, because only three states are currently operational, the immediate impact on telehealth remains limited. As additional states complete the implementation process, the practical effects of the compact are expected to expand considerably. What Counselors Should Expect Moving Forward The next phase of the Counseling Compact will likely focus on expanding the number of operational states. Because most states have already enacted the legislation, the primary barrier to broader implementation is now technical and administrative rather than legislative. Over the next several years, additional states are expected to complete the requirements necessary to activate their compact systems. As more states become operational, counselors will gain greater flexibility to provide services across state lines, particularly in telehealth settings. For counselors following these developments, the most important takeaway is that the Counseling Compact has moved beyond the legislative stage and is now entering the operational phase. Although implementation remains gradual, the infrastructure necessary for interstate counseling practice is now in place. References Counseling Compact Commission. (2026a). Compact implementation updates. Counseling Compact Commission. Counseling Compact Commission. (2026b). Compact member states. Counseling Compact Commission. Counseling Compact Commission. (2026c). Compact participation requirements and fees. Counseling Compact Commission. Michigan Legislature. (2025). House Bill 4591 (2025–2026): Counseling compact legislation. State of Michigan. National Board for Certified Counselors. (2024). The counseling compact: Interstate licensure portability for professional counselors. NBCC.

Executive Summary The past year witnessed transformative changes across counseling licensure regulation in the United States, with the historic launch of the Counseling Compact marking the most significant shift in interstate practice since licensure began. This comprehensive report documents regulatory changes across all 50 states, Washington D.C., Puerto Rico, and Guam based on direct examination of official state licensing boards and government sources. Key findings include the September 30, 2025 operational launch of the Counseling Compact in Arizona and Minnesota, New York's groundbreaking diagnostic privilege expansion, Utah's comprehensive workforce development reform, and the creation of associate licensure pathways in multiple states. The Counseling Compact Revolution Launches Nationwide The interstate Counseling Compact officially launched September 30, 2025, at 12:00 p.m. ET, representing the most consequential regulatory development affecting counseling licensure in decades (Counseling Compact Commission, 2025a; Arizona Board of Behavioral Health Examiners, 2025). Arizona and Minnesota became the first operational states, with 37 additional states plus Washington D.C. having enacted enabling legislation and preparing for phased implementation throughout 2025-2026 (American Counseling Association, 2025). The Compact allows Licensed Professional Counselors holding unencumbered licenses to obtain "privilege to practice" in other member states through a streamlined application process via the Compact Connect system (Counseling Compact Commission, 2025b). Counselors must hold diagnostic authority, pass FBI background checks, and meet uniform licensure requirements including 60-hour graduate degrees and nationally recognized examinations. This fundamentally transforms professional mobility for counselors, eliminating the need for separate state licenses when practicing across state lines via telehealth or temporary in-person services. State-by-State Compact Adoption Status As of November 2025, 39 states plus the District of Columbia have enacted Counseling Compact legislation (American Counseling Association, 2025). Member states include: Alabama, Arizona, Arkansas, Colorado, Connecticut, Delaware, Florida, Georgia, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland, Minnesota, Mississippi, Missouri, Montana, Nebraska, Nevada (effective January 1, 2026), New Hampshire, New Jersey, New Mexico, North Carolina, North Dakota, Ohio, Oklahoma, Rhode Island, South Carolina, South Dakota, Tennessee, Utah, Vermont, Virginia, Washington, West Virginia, Wisconsin, Wyoming, and Washington D.C. Notable non-members include California, Illinois (legislation failed January 2025), Massachusetts, Michigan, New York, Oregon, Pennsylvania (legislation pending), and Texas (legislation stalled despite board support). Nevada became the 38th state to sign compact legislation when Governor Joe Lombardo signed AB163 on June 10, 2025, with an effective date of January 1, 2026 (Counseling Compact Commission, 2025c). Washington D.C. became law through B25-0287, joining 37 states that had previously ratified the Counseling Compact (Counseling Compact Commission, 2025d). The Compact requires significant technical infrastructure, including database integration for licensee tracking and coordinated disciplinary data sharing (National Board for Certified Counselors, 2024). States report implementation timelines varying from late 2025 through 2026 as they complete system requirements. Applications are processed through CompactConnect.org, with a $30 administrative fee per privilege request plus individual state fees (Counseling Compact Commission, 2025b). Major State-Specific Regulatory Changes Diagnostic Privilege Expansion (New York) New York enacted the most significant scope of practice expansion, granting Licensed Mental Health Counselors, Licensed Marriage and Family Therapists, and Licensed Psychoanalysts independent diagnostic authority effective June 24, 2024 (New York State Education Department, 2024a). Previously, these professionals required supervision from psychiatrists or clinical social workers for diagnosis and assessment-based treatment planning. Chapter 230 of the Laws of 2022 established two pathways to diagnostic privilege (New York State Education Department, 2024a): Standard pathway: Requires 2,000 hours of supervised experience including diagnosis, psychotherapy, and assessment-based treatment planning Alternative three-year experience pathway: For counselors licensed before June 24, 2024, requiring attestation from a supervisor of at least three years of experience engaged in direct client contact including diagnosis, psychotherapy, and assessment-based treatment plans (available until June 24, 2027) The diagnostic privilege application fee is $175 and requires verification of completion of a 60-semester hour master's degree or higher, including at least 12 semester hours of clinical courses (New York Education Law § 8401-a, 2024). Direct client contact hour requirements for new licensees increased from 1,500 to 2,000 hours. This change addresses long-standing parity issues between mental health professions and expands independent practice capabilities for approximately 25,000 LMHCs statewide. Comprehensive Workforce Development Reform (Utah) Utah's SB26 represents the most comprehensive behavioral health licensing reform enacted during this period, signed March 19, 2024 by Governor Spencer Cox (Utah Department of Commerce, 2024; TrackBill, 2024). The legislation creates two new entry-level positions—Behavioral Health Coach (licensed) and Behavioral Health Technician (certified)—to expand workforce pathways for individuals with four-year degrees (Utah Division of Professional Licensing, 2024). Most significantly, SB26 establishes an alternative pathway to full licensure without national examinations (Utah Division of Professional Licensing, 2024). Mental health therapists can become fully licensed through 500 additional direct client care hours, 25 hours of direct clinical supervision (including 5 hours of direct observation), and two recommendation letters. This alternative becomes fully operational January 1, 2027 (Pathways to Resilience, 2024). The law also grants psychologists limited prescribing authority for low-risk antidepressants, consolidates multiple licensing boards into a single Behavioral Health Board, mandates criminal background checks for master's-level clinicians, and requires enhanced direct observation during supervision (American Psychological Association Services, 2024). Utah officials project these changes will significantly expand access to mental health services in underserved areas. CACREP Accreditation Requirements (Multiple States) Several states moved toward mandatory CACREP (Council for Accreditation of Counseling and Related Educational Programs) accreditation during this period, reflecting national trends toward standardized educational requirements. Florida implemented a CACREP/MPCAC requirement effective July 1, 2025, requiring all applicants for Mental Health Counselor licensure to hold master's degrees from programs accredited by CACREP, MPCAC, or equivalent accrediting bodies, with minimum 60 semester hours or 80 quarter hours (Florida Board of Clinical Social Work, Marriage & Family Therapy and Mental Health Counseling, 2024). North Carolina established specific CACREP coursework requirements effective July 1, 2025, mandating completion of three specific areas: introduction to clinical mental health counseling with professional issues and ethics, practicum and clinical mental health internship, and appraisal/assessment of mental health disorders with DSM including psychopharmacology and differential diagnosis (North Carolina Board of Licensed Clinical Mental Health Counselors, 2025). Each area requires minimum 3 semester hours or 5 quarter hours. Internships must occur in clinical mental health settings. Georgia proposed significant rule changes with public hearings held April 2025, including formal adoption of 60 semester hour requirements, enhanced clinical contact hour minimums, CACREP accreditation requirements with grandfathering provisions for degrees received before May 1, 2026, and restrictions limiting degrees to clinical mental health counseling or counseling psychology (Georgia Composite Board of Professional Counselors, Social Workers, and Marriage and Family Therapists, 2025). These proposals remained under review as of November 2025. Associate Licensure Pathways Created Pennsylvania created the Licensed Associate Professional Counselor (LAPC) license through Act 4 of 2024, signed March 28, 2024 by Governor Josh Shapiro (Pennsylvania Department of State, 2024). This new first-tier, dependent license allows pre-licensed professional counselors to obtain state-issued licenses for insurance billing while working toward full LPC licensure. Requirements include 60-credit hour master's degrees, supervision plans, and job descriptions. Applications opened April 3, 2024, just six days after signing (Commonwealth of Pennsylvania, 2024). At least half of supervision hours must be provided by LPCs with five years of experience; remaining hours may be supervised by LPCs or license holders with master's degrees in related fields with five years of experience (Pennsylvania Consolidated Statutes Act 4, 2024). The Pennsylvania State Board of Social Workers, Marriage and Family Therapists and Professional Counselors vets all associate licensees through the Pennsylvania Licensing System (PALS) (Philadelphia College of Osteopathic Medicine, 2024). Alaska created Associate Counselor licenses through House Bill 126 and Senate Bill 116, signed August 30, 2024, with July 1, 2025 effective date (Alaska State Legislature, 2024). However, implementation faces delays due to Administrative Order 358 freezing new regulation promulgation. Previously, individuals worked as unlicensed professionals under supervision. Once operational, the new license type will provide formal licensure status to counselors gaining post-graduate supervised hours (Alaska Division of Corporations, Business and Professional Licensing, 2024). Supervision Requirement Modernization Multiple states reformed supervision requirements to address workforce challenges and improve flexibility: Indiana allows up to 100% virtual supervision effective July 1, 2024, through synchronous visual and audio interaction via HIPAA-compliant electronic platforms (excluding telephone calls, email, or text messages) (Indiana Professional Licensing Agency, 2024). Indiana also implemented early testing provisions allowing applicants in their final semester to apply for national examination eligibility before completing all hours, though this does not include temporary permits. Iowa prohibited direct observation requirements through HF 2515, signed April 19, 2024, specifically barring boards from requiring video or recorded sessions with clients as part of supervised training requirements (Iowa Mental Health Counselors Association, 2024). This removes controversial provisions requiring supervisors to directly observe client sessions. Oklahoma removed onsite supervisor requirements through board action August 8, 2025, eliminating requirements for candidates to have designated onsite supervisors and for onsite supervisors to consult with candidacy supervisors every six months (Oklahoma Counseling Institute, 2025a). These changes align Oklahoma more closely with neighboring states and reduce risks of candidates losing ability to count hours toward licensure due to supervisor changes. Alabama amended supervision requirements through Administrative Rule 255-X-2-.24, effective June 14, 2025, with new virtual supervision requirements mandating LPC-S supervisors complete 2 hours of continuing education training in providing virtual supervision (Alabama Board of Examiners in Counseling, 2025). Supervisors without this training must conduct all 50 annual direct supervision hours in-person. Continuing Education Updates South Carolina added mandatory suicide prevention continuing education through Act 158 (S.408), signed May 20, 2024 (South Carolina Legislature, 2024). All licensees must complete at least 1 hour of continuing education in suicide assessment, treatment, and management as part of total CE requirements for license renewal, applicable to renewal cycles ending after 2025. This may be completed virtually. Total requirements remain 40 hours every two years (33 hours related to professional license, 1 hour suicide prevention, 6 hours ethical standards). Alaska implemented enhanced CE requirements for licenses renewing November 1, 2025 – October 31, 2027, requiring 40 contact hours for licenses issued on or before April 30, 2024, including 3 hours professional ethics, 3 hours suicidality, and 3 hours cultural competency, with minimum 20 hours through synchronous/interactive courses (Alaska Division of Corporations, Business and Professional Licensing, 2025). Requirements are prorated for more recently issued licenses. Nevada increased cultural competency requirements from previous levels to 6 hours per two-year renewal cycle through NV AB-267, enacted June 5, 2023, effective January 1, 2024 (NetCE, 2024). Total CE requirement remains 20 hours every two years, including minimum 2 hours ethics, 2 hours suicide prevention, and now 6 hours cultural competency/diversity, equity and inclusion. Kansas reduced diagnosis/treatment CE requirements from 6 hours to 3 hours while adding new 3-hour cultural diversity requirement effective July 1, 2025, through comprehensive HB 2340 (Kansas State Legislature, 2024). Cultural diversity topics include age, disability, ethnicity, gender, gender identity, language, national origin, race, religion, sexual orientation, and socioeconomic status. Ethics requirement maintained at 3 hours. Texas proposed controversial changes to cultural diversity CE requirements in February 2025, with preliminary approval by Texas Behavioral Health Executive Council (The Gilmer Mirror, 2025). The proposed change would replace the 3-hour "cultural diversity or competency" requirement with 3 hours designed to "ensure competency when providing services to a distinct population, defined as a group of people who share a common attribute, trait, or defining characteristic of the licensee's choice." This change generated significant debate, with opponents arguing it weakens professional guidance while supporters claim it removes ideological requirements. Final approval expected June 2025. Telehealth Regulation Evolution Colorado enacted SB 24-141 creating registration for out-of-state telehealth providers, signed June 7, 2024, effective January 1, 2026 (Colorado General Assembly, 2024). Beginning January 1, 2026, healthcare providers including mental health professionals/counselors possessing licenses in other states may provide healthcare services through telehealth to patients in Colorado if they register with DORA. Requirements include valid active unencumbered out-of-state credentials, educational and supervisory standards equivalent to or exceeding Colorado standards, no disciplinary action in any state in the five years preceding application, passage of jurisprudence examination if required, and designation of Colorado agent for service of process. Providers must comply with Colorado professional practice standards and maintain written emergency protocols. Wisconsin adopted telehealth practice standards through new section MPSW 20.03, effective June 1, 2025, clarifying that "standards of practice and professional conduct under this chapter apply to a licensee regardless of whether a health care service is provided in person or by telehealth" (Wisconsin Legislature, 2025). Puerto Rico extended telehealth/cybertherapy authorization through Administrative Order No. 604 dated March 17, 2025, allowing professional counselors to continue providing services via telehealth/cybertherapy without additional certification requirements through December 31, 2025 (Center for Connected Health Policy, 2025). Additionally, Law 8 of April 11, 2025 broadly authorized any physician or healthcare professional with current licenses to conduct consultations or provide services using telemedicine, telehealth, or cybertherapy technologies. Reciprocity and Endorsement Changes Nevada enacted AB 450 revising licensure by endorsement requirements, making endorsement mandatory rather than discretionary for qualifying applicants (Nevada State Legislature, 2025). Previous law stated the board "may" issue licenses by endorsement; amended law states board "shall" issue licenses when requirements are met. The revision eliminates disqualification for applicants who have been investigated but not disciplined, and removes the board's discretionary authority to request undefined additional information. The board must notify applicants within 15 business days of additional required information and approve applications within 45 days of receiving complete information unless denied for good cause. Kansas reduced reciprocity practice time requirements from 48 of the last 54 months to 12 months through comprehensive HB 2340, significantly easing interstate mobility for LPCs and LCPCs (Kansas State Legislature, 2024). Tennessee introduced SB0020 in December 2024 (pending as of January 2025, expected effective July 1, 2025 if passed) creating exemptions from the 60-credit hour requirement for applicants holding valid unencumbered professional counselor licenses from other states, territories, or federal districts if licensing requirements are judged acceptable by the Tennessee Board (BillTrack50, 2025). Licensing System and Fee Modernization Missouri launched MOPRO (Missouri Professional Regulation Online Portal) on January 14, 2025, requiring licensees to register for accounts and maintain email addresses on file (Missouri Division of Professional Registration, 2025). The system allows license renewals, supervision hour tracking, continuing education hour tracking, contact information updates, and license application management. North Dakota introduced SB 2071 proposing new licensing fees and technology systems in January 2025, including duplicate wall certificate fees ($20-$50 range) and new technology fees ($50-$100 per licensee) to fund cloud-based licensing systems (North Dakota Legislative Assembly, 2025). The board requested $100,000 appropriation to assist with $65,000 initial setup fees for cloud-based systems (Thentia system) necessary to meet Counseling Compact data requirements, transitioning from paper-based to cloud-based solutions. Oregon transitioned from annual to biennial license renewal effective January 1, 2024, with licensees with even-numbered licenses renewing in even years and odd-numbered licenses renewing in odd years (Oregon Board of Licensed Professional Counselors and Therapists, 2024a). Associate registrations remained on one-year renewal cycles. Oregon also changed Associate Registration supervision reporting from every six months to annual reports submitted with registration renewal, with clinical hours no longer denied when reports are submitted past due dates (Oregon Board of Licensed Professional Counselors and Therapists, 2024b). Washington D.C. moved from fixed biennial renewal cycles to birth month-based renewal effective June 16, 2024 (District of Columbia Department of Health, 2024). All licenses issued on or after June 16, 2024 expire on the last day of licensees' birth months, distributing renewal workload throughout the year instead of fixed December 31 deadlines. West Virginia implemented electronic licensing systems (Certemy platform) during 2024-2025, with online license verification now available at no fee (West Virginia Board of Examiners in Counseling, 2024). Official verification on board letterhead remains available for fees. Ohio suspended verification and name change fees effective approximately April 17, 2025, as part of eLicense system updates, intended to reduce financial burdens on licensees particularly those seeking licensure in other states (Ohio Counselor, Social Worker, and Marriage and Family Therapist Board, 2025). Board Composition and Governance Changes Washington D.C. expanded the Board of Professional Counseling from 5 to 7 members through D.C. Law 25-191, effective July 19, 2024 (D.C. Council, 2024). New composition includes 3 professional counselors, 1 professional art therapist, 1 marriage and family therapist, 1 professional counselor/art therapist/marriage and family therapist/addiction counselor, and 1 consumer member. Board jurisdiction expanded to regulate professional counseling, professional art therapy, addiction counseling, dance therapy, AND marriage and family therapy. Iowa consolidated the Board of Behavioral Sciences, Board of Social Work, and Board of Psychology into a single Board of Behavioral Health Professionals effective May 17, 2024 through SF 2385, with the last Iowa Board of Behavioral Science meeting held June 2024 (Iowa Mental Health Counselors Association, 2024). Advisory committees were created for each former board to make recommendations on licensure cases and implementation, and behavior analyst representatives were added to the consolidated board. Oklahoma faced sunset extension requirements, with the State Board of Behavioral Health Licensure extended from July 1, 2025 to July 1, 2026 through HB 1041 in the 2025 legislative session (Oklahoma Counseling Institute, 2025b). SB397 which would have extended to July 1, 2028 was removed from the agenda. New board appointments were confirmed by the Oklahoma Senate on May 27, 2025 (Oklahoma Counseling Institute, 2025c). Emergency and Transitional Provisions North Carolina addressed Hurricane Helene emergency provisions, with Executive Order 318 ending September 15, 2025 (services termination deadline) and September 22, 2025 (notification deadline) (North Carolina Board of Licensed Clinical Mental Health Counselors, 2025). Out-of-state counselors providing services under emergency orders had to terminate services and notify the board confirming termination and dates of final services. Arizona created 90-day licensure exemptions for recent graduates through House Bill 2001, signed by Governor Katie Hobbs, effective September 26, 2025 (Arizona Legislature, 2025). Recent graduates who completed and graduated from counseling, social work, marriage and family therapy, or addiction counseling programs from regionally accredited institutions, possess valid fingerprint clearance cards from Arizona Department of Public Safety, are currently applying for associate-level licenses, and work under qualified supervision by persons who provided direct supervision during courses of study or internships can practice for 90 days while applications are pending. Direct client contact hours obtained during 90-day periods while applications are pending count toward licensure requirements. Virginia implemented comprehensive Qualified Mental Health Professional (QMHP) regulation changes effective May 7, 2025, pursuant to SB403 of 2024 General Assembly (Virginia Department of Health Professions, 2024). Major changes include elimination of separate QMHP-Adult and QMHP-Child designations replaced by single QMHP registrations, required completion of didactic training before approval, annual renewal requirements for QMHP-Trainee registrations, reduction of supervised experience to 1,500 hours for those without human services or special education degrees (previously 2,000 hours), authorization for QMHPs with 3+ years of experience to supervise Trainees after completing supervisor training, and mandatory supervisor training for all QMHP supervisors. Jurisdictions with Minimal Changes Several jurisdictions reported no significant regulatory changes during November 2024 - November 2025: California experienced no enacted changes beyond SB 1024 (effective January 1, 2025) clarifying supervisee limits and license display requirements for telehealth, and notice to clients changes (July 1, 2025) (California Board of Behavioral Sciences, 2025). Proposed exam changes discussed by the Workforce Development Committee remained under discussion without enactment. Massachusetts held public hearings in 2024-2025 on proposed regulatory amendments for new license categories, clarification of eligibility requirements, and updates to ethical codes references, but no regulations were adopted during the specified timeframe (Massachusetts Board of Registration in Allied Mental Health, 2024). Guam updated application checklists in June 2025 but reported no substantive regulatory changes to licensure requirements, continuing education, or scope of practice (Guam Board of Allied Health Examiners, 2025). Hawaii announced Act 93 on November 4, 2025, appearing on multiple official DCCA PVL pages, but specific details were not fully detailed in publicly available documents as of the research date (Hawaii Department of Commerce and Consumer Affairs, 2025). Mental health counselors were advised to contact DCCA PVL directly for specific information. Cross-Cutting Themes and National Trends Interstate Mobility Acceleration Beyond the Counseling Compact, Nebraska enacted the Social Worker Licensure Compact (LB 932) approved April 15, 2024, becoming operative January 1, 2025, though this applies to social workers not counselors (Nebraska Legislature, 2024). Ohio actively participates in both Counseling Compact and Social Work Compact implementation. Education Requirement Standardization The trend toward 60-semester hour minimum requirements and CACREP accreditation continues, with Michiganincreasing requirements from 48 to 60 semester hours effective June 2023 (continuing impact through timeframe), and multiple states including North Carolina, Georgia, and Florida implementing or proposing CACREP-specific requirements. Supervision Quality Enhancements Louisiana implemented the most significant supervisor training change, requiring certificates of completion for all board-approved supervisors effective April 1, 2026 (Louisiana Licensed Professional Counselors Board of Examiners, 2025). All supervisors must complete either graduate-level academic courses in counseling supervision (45 clock hours/3 semester credits) or board-approved professional training programs (minimum 25 direct clock hours face-to-face) within 5 years of applications for board-approved supervision. Previously required but certificate documentation not mandated for renewal. LPC-S must accrue 3 clock hours in supervision every two years before renewal. Mandatory Background Checks Expansion Florida implemented electronic fingerprinting requirements through House Bill 975 (2024 Legislative Session), effective July 1, 2025 (Florida Board of Psychology, 2024). ALL healthcare practitioners must complete electronic fingerprinting screened by Florida Department of Law Enforcement, applying to both new applicants and existing licensees, with existing licensees complying by first renewal dates on or after July 1, 2025. The Department of Health cannot renew licenses after July 1, 2025 until compliance is complete. Utah mandated criminal background checks for master's-level clinicians/therapists through SB26 as part of comprehensive safety enhancements (Utah Division of Professional Licensing, 2024). Implicit Bias and Cultural Competency Training Michigan implemented ongoing implicit bias training requirements including minimum 2 hours of implicit bias training within 5 years immediately preceding license issuance for initial licensure, and minimum 1 hour of implicit bias training for each year of license cycles for every renewal thereafter (Michigan Department of Licensing and Regulatory Affairs, 2024). Training must be synchronous/interactive or asynchronous teleconference or webinar, and may be used to satisfy other training or CE requirements unless prohibited. Michigan also requires one-time human trafficking training for all licensees seeking renewal, requiring completion of training in identifying victims of human trafficking meeting standards in Administrative Rule 338.1771 prior to renewing licenses, effective May 16, 2024 (Michigan Department of Licensing and Regulatory Affairs, 2024). Remnant has this training planned for Fall 2026 for those interested. With our recent NBCC/ACEP live training approval our training will meet the state of Michigan requirements. Technology Integration Guidance Utah became the first state to issue official AI Best Practices Guide for mental health therapists in 2025, developed by Utah Department of Commerce's Office of Artificial Intelligence Policy in collaboration with industry stakeholders, providing guidance on ethical and effective use of AI in practice (Utah Department of Commerce, 2025). Washington allows counselors with pending associate license applications to begin practicing under supervision for up to 120 days while applications are pending, effective October 1, 2025 (WAC 246-809-097) (Washington State Department of Health, 2025). The 120-day window starts when Department receives all required items. Licensure Portability and Reciprocity Summary States demonstrate increasing commitment to reducing barriers for out-of-state licensees: Counseling Compact membership: 39 states + DC Reduced reciprocity timeframes: Kansas (48 months → 12 months), Nevada (mandatory endorsement vs. discretionary) Out-of-state telehealth registration: Colorado (effective January 1, 2026) Expedited processing: Kansas (15-day turnaround for additional fees), Ohio (portfolio approach implementation April 2025) Military provisions: Multiple states maintain military spouse expedited licensure provisions Continuing Education Requirements by State (Current Status) Requirements range from 10 hours annually (Tennessee) to 55 hours every 2 years (Maine), with common themes including mandatory ethics training (typically 2-6 hours), cultural competency requirements (increasingly common), and suicide prevention/assessment training (Alaska, Idaho, South Carolina, Nevada, Tennessee). Virtual and distance learning acceptance expanded significantly post-pandemic, with Vermont permanently accepting synchronous virtual CE as live in-person training through H.305 (2023), and Washington removing all limits on distance learning hours. Implications for the Profession These changes collectively represent the most significant modernization of counseling licensure regulation in decades. The Counseling Compact's launch fundamentally alters professional mobility, enabling counselors to serve clients across state lines and potentially addressing mental health workforce shortages in underserved areas. Supervision requirement reforms, associate licensure pathways, and alternative routes to full licensure demonstrate responsiveness to workforce challenges while maintaining public protection standards. The trend toward CACREP accreditation and 60-hour graduate programs continues standardizing educational requirements nationally, potentially facilitating licensure portability and professional identity. However, states like Illinois rejecting Compact legislation and Texas experiencing stalled legislation demonstrate ongoing tensions between national standardization and state sovereignty over professional regulation. Technology integration guidance, telehealth regulation expansion, and electronic licensing system implementations reflect adaptation to post-pandemic practice realities and digital service delivery models. The profession continues balancing innovation and flexibility with ethical standards and public protection, evidenced by debates over cultural competency requirements in Texas and diagnostic privilege expansion in New York. These developments position the counseling profession for continued evolution while addressing workforce needs, technological changes, and expanded access to mental health services. Counselors practicing in 2025 operate in a significantly more mobile, technologically integrated, and standardized regulatory environment than existed just five years ago, with implications for career planning, continuing education, and service delivery models. Research Methodology This report represents comprehensive research conducted November 9, 2025, utilizing: Official state licensing board websites for all 53 jurisdictions State legislative databases and bill tracking systems State administrative codes and regulation repositories Official board meeting minutes, agendas, and announcements State statutes and session laws Counseling Compact Commission official sources Professional association resources (American Counseling Association, state counseling associations) All information is sourced from primary official government websites and documents. Information reflects status as of November 9, 2025, and is subject to ongoing regulatory changes. Important Note: Counselors should verify current requirements directly with their state licensing boards, as regulations continue to evolve and implementation timelines vary. The Counseling Compact represents an ongoing development with phased implementation throughout 2025-2026, and counselors interested in interstate practice should monitor compact status updates at https://counselingcompact.gov. References Alabama Board of Examiners in Counseling. (2025). Administrative Rule 255-X-2-.24: Certification of administrative rules. https://abec.alabama.gov/ Alaska Division of Corporations, Business and Professional Licensing. (2024). Professional counselors: Board information. https://www.commerce.alaska.gov/web/CBPL/ProfessionalLicensing/professionalcounselors.aspx Alaska Division of Corporations, Business and Professional Licensing. (2025). Professional counselor license renewal November 1, 2025 – October 31, 2027 [CE requirements]. https://www.commerce.alaska.gov/web/Portals/5/pub/pco4281.pdf Alaska State Legislature. (2024). House Bill 126: An Act relating to the Board of Professional Counselors. https://www.akleg.gov/basis/Bill/Detail/33?Root=HB+126 American Counseling Association. (2025). Counseling Compact: Interstate compacts for professional counselor licensure. https://www.counseling.org/advocacy/counseling-compact American Psychological Association Services. (2024, April 12). Utah passes prescriptive authority for psychologists. https://www.apaservices.org/practice/news/utah-prescriptive-authority Arizona Board of Behavioral Health Examiners. (2025). Counseling Compact. https://bbhe.az.gov/counseling-compact Arizona Counseling Association. (2025). Advocacy. https://www.azca.org/i4a/pages/index.cfm?pageid=3343 Arizona Legislature. (2025). House Bill 2001: 90-day licensure exemptions for recent graduates. https://www.azleg.gov/legtext/57leg/1R/summary/H.HB2001_040825_SENATEENGROSSED.DOCX.htm BillTrack50. (2025). TN SB0020. https://www.billtrack50.com/billdetail/1760765 California Board of Behavioral Sciences. (2025). Winter 2025 newsletter. https://www.bbs.ca.gov/pdf/newsletters/winter2025.pdf Center for Connected Health Policy. (2025). Puerto Rico. https://www.cchpca.org/puerto-rico/ Colorado General Assembly. (2024). SB 24-141: Out-of-state telehealth providers. https://leg.colorado.gov/bills/sb24-141 Commonwealth of Pennsylvania. (2024). Act 4 of 2024. https://www.legis.state.pa.us/cfdocs/legis/li/uconsCheck.cfm?yr=2024&sessInd=0&act=4 Counseling Compact Commission. (2025a). Counseling Compact to officially launch September 30, 2025 [Press release]. https://counselingcompact.gov/ Counseling Compact Commission. (2025b). Info for counselors: Frequently asked questions. https://counselingcompact.gov/faq/ Counseling Compact Commission. (2025c). Nevada becomes 38th state to sign interstate counseling compact into law. https://www.counseling.org/advocacy/counseling-compact/2025/06/16/nevada-becomes-38th-state-to-sign-interstate-counseling-compact-into-law Counseling Compact Commission. (2025d). News. https://counselingcompact.org/news/ D.C. Council. (2024). D.C. Law 25-191: Health Occupations Revision General Amendment Act of 2024. https://code.dccouncil.gov/us/dc/council/laws/25-191 District of Columbia Department of Health. (2024). Professional counseling licensing. https://dchealth.dc.gov/service/professional-counseling-licensing Duquesne University School of Education. (2025, July 31). New Pennsylvania counseling legislation increases access to care. https://www.duq.edu/news-and-stories/stories/authentic-collaboration-leads-to-systemic-change-in-pa-mental-health-care-access.php Florida Board of Clinical Social Work, Marriage & Family Therapy and Mental Health Counseling. (2024). Licensed mental health counselor. https://floridasmentalhealthprofessions.gov/licensed-mental-health-counselor/ Florida Board of Psychology. (2024). 2024 bills impacting health care professions. https://floridaspsychology.gov/new-legislation-impacting-your-profession-2024/ Georgia Composite Board of Professional Counselors, Social Workers, and Marriage and Family Therapists. (2025). Proposed rule changes [Public hearing materials, April 2025]. Gilmer Mirror, The. (2025, February 20). Texas mental health licensing board gives initial OK to remove training requirement associated with DEI. https://www.gilmermirror.com/2025/02/20/texas-mental-health-licensing-board-gives-initial-ok-to-remove-training-requirement-associated-with-dei/ Guam Board of Allied Health Examiners. (2025). Application checklists [Updated June 2025]. Hawaii Department of Commerce and Consumer Affairs. (2025). Act 93 announcement. https://cca.hawaii.gov/pvl/ Indiana Professional Licensing Agency. (2024). Behavioral health and human services. https://www.in.gov/pla/professions/behavioral-health-and-human-services/ Iowa Mental Health Counselors Association. (2024). Updates to licensure rules and laws: A summary. https://imhca.net/newsletters/licensure-laws-a-summary/ Kansas State Legislature. (2024). HB 2340: Professional counselor licensure amendments. https://www.kslegislature.gov/li_2024/b2023_24/measures/documents/hb2340_02_0000.pdf Louisiana Licensed Professional Counselors Board of Examiners. (2025). Supervision requirements for board-approved supervisors. [Effective April 1, 2026]. Massachusetts Board of Registration in Allied Mental Health. (2024). Board of registration in allied mental health. https://www.mass.gov/info-details/board-of-registration-in-allied-mental-health Michigan Department of Licensing and Regulatory Affairs. (2024). Implicit bias training and human trafficking training requirements. [Administrative Rules 338.1771]. Missouri Division of Professional Registration. (2025). Committee for professional counselors: MOPRO system launch. https://pr.mo.gov/counselors.asp National Board for Certified Counselors. (2024). Counseling Compact update. https://www.nbcc.org/govtaffairs/newsroom/counseling-compact-update Nebraska Legislature. (2024). LB 932: Social Worker Licensure Compact. https://nebraskalegislature.gov/laws/statutes.php?statute=38-4501 NetCE. (2024). Nevada counselors/therapists CE requirements, accreditations & approvals. https://www.netce.com/ce-requirements/counselor-therapist/nv/ Nevada State Legislature. (2025). AB 450: Revisions to licensure by endorsement requirements. https://archive.leg.state.nv.us/Session/83rd2025/Bills/AB/AB450_R1.pdf New York Education Law § 8401-a. (2024). Diagnostic privilege. https://law.justia.com/codes/new-york/edn/title-8/article-163/8401-a/ New York State Education Department. (2024a). Diagnostic privilege for certain mental health practitioners. https://www.op.nysed.gov/mental-health-practitioners/Diagnostic-Privilege-for-Certain-Mental-Health-Practitioners New York State Education Department. (2024b). Subpart 79-9: Mental health counseling regulations. https://www.op.nysed.gov/professions/mental-health-counselors/laws-rules-regulations/subpart-799 North Carolina Board of Licensed Clinical Mental Health Counselors. (2025). CACREP coursework requirements effective July 1, 2025. https://www.ncblcmhc.org/ North Dakota Legislative Assembly. (2025). SB 2071: Licensing fees and technology systems. https://ndlegis.gov/assembly/69-2025/testimony/SINBUS-2071-20250114-28353-F-GRAHN_ERIN.pdf Ohio Counselor, Social Worker, and Marriage and Family Therapist Board. (2025). Fee suspension announcement[Effective April 17, 2025]. Oklahoma Counseling Institute. (2025a). Breaking news: Oklahoma Board of Behavioral Health votes to make changes to supervision requirements. https://www.counselinginstitute.org/news/breaking-news-oklahoma-board-of-behavioral-health-votes-to-make-changes-to-supervision-requirements Oklahoma Counseling Institute. (2025b). Will the Oklahoma Board of Behavioral Health Licensure dissolve in 2025?. https://www.counselinginstitute.org/news/will-the-oklahoma-board-of-behavioral-health-licensure-dissolve-in-2025 Oklahoma Counseling Institute. (2025c). Oklahoma Senate confirms new appointments to state mental health licensing boards. https://www.counselinginstitute.org/news/oklahoma-senate-confirms-new-appointments-to-state-mental-health-licensing-boards Oregon Board of Licensed Professional Counselors and Therapists. (2024a). Biennial license renewal transition. https://www.oregon.gov/oblpct/pages/renew.aspx Oregon Board of Licensed Professional Counselors and Therapists. (2024b). Administrative rule changes to supervision reporting. https://secure.sos.state.or.us/oard/displayDivisionRules.action?selectedDivision=3732 Pathways to Resilience. (2024, March 7). New Utah law to grow the behavioral health workforce. https://pathways-us.org/2024/03/07/new-utah-law-to-grow-the-behavioral-health-workforce/ Pennsylvania Consolidated Statutes Act 4. (2024). Social Workers, Marriage and Family Therapists and Professional Counselors Act: Omnibus amendments. https://law.justia.com/codes/pennsylvania/act-4/ Pennsylvania Department of State. (2024, April 3). Within days of new law creating associate licenses for mental health providers, Department of State prepared to accept applications [Press release]. https://www.pa.gov/agencies/dos/newsroom/within-days-of-new-law-creating-associate-licenses-for-mental-he.html Philadelphia College of Osteopathic Medicine. (2024, April 24). Associate counselor license provides path for better opportunities. https://www.pcom.edu/academics/programs-and-degrees/mental-health-counseling/news/associate-counselor-license.html South Carolina Legislature. (2024). Act 158 (S.408): Suicide prevention training for health professionals. https://www.scstatehouse.gov/sess125_2023-2024/bills/408.htm TrackBill. (2024). Utah SB26: Behavioral health licensing amendments. https://trackbill.com/bill/utah-senate-bill-26-behavioral-health-licensing-amendments/2466317/ Utah Department of Commerce. (2024, March 19). Great news! SB26, the Behavioral Health Licensing Amendments bill, was signed into law today [Tweet]. X (formerly Twitter). https://x.com/UtahCommerce/status/1770233468754309289 Utah Department of Commerce. (2025). AI Best Practices Guide for mental health therapists. Utah Office of Artificial Intelligence Policy. Utah Division of Professional Licensing. (2024). SB26 explainer: Behavioral health licensing amendments. https://dopl.utah.gov/wp-content/uploads/2024/03/SB26-Explainer-March-18-vPOSTED.pdf Virginia Department of Health Professions. (2024). Virginia Board of Counseling: QMHP information. https://www.dhp.virginia.gov/Boards/Counseling/ApplicantResources/QMHPInformation/ Washington State Department of Health. (2025). Mental health counselor: Frequently asked questions. https://doh.wa.gov/licenses-permits-and-certificates/professions-new-renew-or-update/mental-health-counselor/frequently-asked-questions West Virginia Board of Examiners in Counseling. (2024). Counselor and therapist license verification. https://wvbec.org/counselor-and-therapist-license-verification/ Wisconsin Legislature. (2025). Chapter MPSW 20: Telehealth practice standards. https://docs.legis.wisconsin.gov/code/admin_code/mpsw/20 Author's Note: This report represents an extensive compilation of regulatory changes across 53 U.S. jurisdictions based on direct examination of official government sources as of November 9, 2025. While every effort has been made to ensure accuracy, counselors should verify current requirements directly with their state licensing boards before making practice decisions. The regulatory landscape continues to evolve rapidly, particularly regarding Counseling Compact implementation. Artificial Intelligence Disclosure Statement This article was developed with research support from artificial intelligence (AI) technology. Specifically, AI tools were utilized for: Source identification and retrieval: AI assisted in locating relevant scholarly literature, professional organization documents, and empirical research related to advocacy and activism in counseling. Information synthesis: AI helped organize and summarize information from multiple sources to identify key themes, arguments, and empirical findings. Citation verification: AI tools were employed to cross-reference sources and verify the accuracy of cited material. However, all substantive intellectual work—including the conceptual framework, argumentative structure, critical analysis, ethical reasoning, interpretation of sources, and final conclusions—represents Remnant's scholarly judgment and professional perspective. The arguments presented, the ethical analysis conducted, and the conclusions drawn are my own and reflect my understanding of the counseling profession's ethical obligations. Remnant has reviewed all AI-generated content for accuracy and have taken responsibility for verifying sources, ensuring proper attribution, and confirming that the arguments presented align with my professional knowledge and values. Any errors or omissions remain my own responsibility. This disclosure is provided in the interest of transparency and in accordance with emerging standards for academic integrity in an age of AI-assisted research and writing.