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Interstate Massage Compact

In January 2023, the lobbyist for a large national massage therapy chain initiated legislation to enter Washington into the Interstate Massage Compact at a time when almost all Washington massage therapists knew nothing about the Compact.  WSMTA was instrumental in having this legislation pulled from the 2023 legislative session so our profession could have greater input in 2024.

WSMTA was tasked to research the compact, review the variety of healthcare compacts available, talk to the Washington State physical therapist and nurse associations to determine how their respective compacts work for them.  This page represents the results of this research.

Below, in the blue squares are the facts about the Interstate Massage Compact and other healthcare compacts.  In the lavender squares are the issues about the Compact that affect all massage therapists regardless of state and issues that affect Washington massage therapists specifically.  If you have limited time, we recommend that you start with the issues and then read through the details as you are able to.

In the upcoming weeks, WSMTA will be polling Washington massage therapists to determine your interest in the Interstate Massage Compact. We need massage therapists to be as informed as possible to help determine the pathway our state should take, which is discussed towards the end of this webpage in the section, What should Washington State do about the Interstate Massage Compact?

If you have any questions, or would like to make comments, please contact us at: gr@mywsmta.org.

Thank you, The WSMTA Board Members

Helpful hint and definitions:

  • Wherever you see this symbol " Details " just click on the arrow or the word "Details" to see more, and then click it again to see less.
  • These definitions are taken directly from the Massage Compact Model Legislation document.  Please read through this list as these words and phrases are used throughout this webpage:  To see the definitions, click on the "Details" link below:

  • “Active Military Member” - any person with full-time duty status in the armed forces of the United States, including members of the National Guard and Reserve.
  • “Charter Member States” - Member States who have enacted legislation to adopt this Compact where such legislation predates the effective date of this Compact as defined in Article 12.
  • “Home State” - means the Member State which is a Licensee’s primary state of residence where the Licensee holds an active Single-State License.
  • “Multistate License” - a license that consists of Authorizations to Practice Massage Therapy in all Remote States pursuant to this Compact, which shall be subject to the enforcement jurisdiction of the Licensing Authority in a Licensee’s Home State.
  • “National Licensing Examination” - A national examination developed by a national association of Massage Therapy regulatory boards, as defined by Commission Rule, that is derived from a practice analysis and is consistent with generally accepted psychometric principles of fairness, validity and reliability, and is administered under secure and confidential examination protocols. WSMTA Comment:  the only current exam that meets this definition is the MBLEX. Any other exams would have to be approved by the Compact Commission.
  • “Remote State” - any Member State, other than the Licensee’s Home State.
  • “Single-State License” - a current, valid authorization issued by a Member State’s Licensing Authority allowing an individual to fully practice Massage Therapy, that is not a restricted, student, provisional, temporary, or inactive practice authorization and authorizes practice only within the issuing State.

Background on Occupational Licensure Compacts:

The Department of Defense (DoD) has partnered with The Council of State Governments (CSG) to fund and support the development of interstate compacts which include Massage, Dentistry and Dental Hygiene, Nurses, Physicians, Physical Therapists, Emergency Medical Technicians, Psychologists, Audiologists, Occupational Therapists and Counselors as well as other non-healthcare professions.  


Through licensure compacts, states establish uniform standards to lower barriers to multi-state practice while preserving a state's practice act and initial licensure process. States that meet the eligibility criteria join interstate compacts by agreeing to the uniform provisions through the legislative process.

The DoD has personnel that move often from state to state and military spouses often have issues with transferring professional licenses from one state to another.  The DoD's intent in supporting compacts by funding the creation of them has been to reduce barriers to employment for military spouses.

What is the Interstate Massage Compact?

The Interstate Massage Compact was created via a partnership between the Department of Defense (DoD), Council of State Governments (CSG) and the Federation of State Massage Therapy Boards (FSMTB). This Compact does not become effective until seven states pass legislation to enter into the Compact agreement.

If enacted, the Compact would allow licensed massage therapists, who qualify for a Multistate License (Compact License) to join:


  • and practice in all other states that join the Compact without applying for an individual massage license in those states.  They still must maintain their massage license from the Home State where they live.
  • but it does not help them to move (change residence) from one Compact State to another Compact State.
  • Moving within the Compact: If a massage therapist, who holds a Multistate License, moves from one Compact Member State to another, they must transfer their massage license to the new state they move to through the current system of "licensure by endorsement" (a process not done through the Compact, but between one state and another). This massage therapist would then need to obtain a new Compact License as it is the Home State that issues the Compact License.
  • Moving outside of the Compact: If a Multistate Licensee moves from a Compact Member State to a non-Compact State, then they lose their license with the Compact and they must transfer their Home State massage license to the new state they move to through "licensure by endorsement" (a process not done through the Compact, but between one state and another).

You can read the Washington State "Licensing by Endorsement" requirements by clicking HERE to learn about it.

Military Spouses:  Military spouses have the added benefit of being able to move within the compact and not lose their access to the Compact if they move to a Non Compact Member State.

On May 5, 2023, the Washington Department of Health Program Manager Military Liaison reported to the Board of Massage that there were an estimated 72 military spouses in Washington who held active massage licenses, based on a survey the military had conducted.


What does "Mobility" mean within the Interstate Massage Compact?

The Compact provides the opportunity for massage therapists who join the Compact to work in other Compact Member States.  Here are several situational examples:


  • Living along a state border:  For residents who live along the border with another state, they currently have to become licensed in the border state to work there as well as maintain a license in their own state.  If both of these states were Compact States then a massage therapist could join the Compact to work in the bordering state.  However, the massage therapist would need to do an analysis to determine if maintaining the border state license is cheaper (or has other benefits), or not, than paying for the Compact License to work in the state next door.
  • Live and work in multiple states:  Some massage therapists maintain multiple residences (or have multiple places to stay) while they live and work in other states.  For example, a person living in Washington State, might travel to Arizona during winter and then stay part of the year in Virginia to live with a son or daughter and then spend the rest of the year at home in Washington.  Currently, the massage therapist would need to be licensed in all three states to do massage as the Compact does not yet exist.  Should the Compact be activated, this massage therapist would need to do an analysis to determine if the Compact works for them as all three states would need to join the Compact for it to work in this example.  Otherwise, if only one or two states become Compact Member States, then the massage therapists would need to decide whether joining the Compact or maintaining each state's individual license was best for them. 
  • Work for a company that travels across states:  Some massage therapists might want to travel with a band, a professional athlete, a dance troupe, sports team for example that travels to multiple states in a year.  With the Compact, a massage therapist might be able to do this if enough states joined the Compact to be able to accommodate the travels of their employer/contractor.

Moving: While working in other Compact Member States, a Multistate Licensee must maintain a residence in their Home State where the Home State License is held.  If a massage therapist moves to another state and changes their residence to that state, the massage therapist does it on their own, outside of the Compact and must follow the laws of the new state to obtain that state's license.  This massage therapist would then need to obtain a new Compact License if the new state is a Member State because it is the Home State that issues a Compact License.

Issues massage therapists need to consider when traveling to work for large destination employers (hotels, spas) and multi-clinic employers with multiple state locations within the Compact:

  • Who pays the massage therapist to travel to the new location to work -- including the personal items needed for an extended stay?
  • Who pays for the temporary lodging of the massage therapist?  Since the massage therapist who joins the compact is required to maintain their residence in their Home State, working in other states requires additional lodging expenses for the massage therapist.

How does the Interstate Massage Compact become activated?

It takes the legislatures of 7 states to enact into law the "Interstate Massage Compact Model Legislation" to activate the Compact. The Model Legislation creates the "shell", or the "boundaries", for how the Compact will function.


  • Once 7 states have made the Model Legislation law, a Compact Commission is created to which each of these initial 7 states send one delegate from their regulating agency to the Commission. 
  • The Compact Commission then creates the rules by which the Compact will operate, staying within the boundaries created by the Model Legislation.
  • It will also be the Compact Commission which will decide many important issues such as:
  • What comprises 625 hours of massage education? Can continuing education be included or not, and if so, to what limit?
  • Can massage therapists join if they passed the NCBTMB exam instead of the MBLEX exam?

Nurse Licensure Compact -- the compact model the Interstate Massage Compact is based on:

The Interstate Massage Compact is based on the model used by the Nurse Licensure Compact (NLC), which was the only one of its kind, until the Interstate Massage Compact was created. Here are a few major points about the NLC:


  • The NLC model allows Compact Licensees to work freely among the compact states without ever reporting to the Compact or with the state regulatory agencies where they work.
  • It relies on nurses to discover and to learn on their own, the regulatory requirements in the states they work in.  This regulatory education may occur before or after they begin work in a Remote State..
  • When nurses move their residence, the Nurse Licensure Compact requires them to transfer their Single-State License from their Home State to the new state they move their residence to via licensure by endorsement. The NLC, like the Interstate Massage Compact, does not help nurses to move from state to state, it helps them to work in other Compact Member States separate from the state they reside in.

The original Nurse Licensure Compact was created in 2000.  The original Compact was dissolved and shortly after the dissolution, the current Nurse Licensure Compact (NLC) was created in 2018.

Until 2023, Washington had remained out of the NLC, the nurses choosing not to join.  However, employer interests (hospitals and large medical clinics, etc.) had stronger lobbyists and were able to convince the Washington State Legislators to have our state join the NLC against the nurses will.  More about this will be stated in the Similarity of issues between the Nurse Licensure Compact (NLC) and the Interstate Massage Compact: section.

These are characteristics of nursing employment:

  • Nurses generally work for larger employers, such as hospitals, medical clinics, nursing facilities, hospice, travel nurse organization.
  • These employers generally have HR departments and usually have formal onboarding processes for new hires.
  • Government regulations and the opportunity for malpractice suits generally tend to create a stronger need to follow regulations.
  • The nursing profession has been chronically understaffed for a longer period of time, so sometimes shortcuts happen.


Compacts that have the benefit of Compact Privilege:

The Physical Therapists (PT) Compact and Occupational Therapists (OT) Compact both require Compact Licensees to obtain "Compact Privilege" for each state they choose to work in. This means that for every Compact Member State that a PT or OT wants to work in, they must contact their respective Compact, request Compact Privilege by paying a small fee, and then taking a jurisprudence exam (if the state requires it). Like the Nurse Licensure Compact and the Interstate Massage Compact, the PT Compact and OT Compact help Compact Licensees to work in Compact Member States, it does not help them to move from one Compact Member State to another.

What benefits does Compact Privilege offer?


  • It allows the regulatory agency in each Compact Member State to know who has the ability to work in their state.
  • It allows the regulatory agency in each Compact Member State to notify Compact Privilege holders for their state when laws, regulations and rules have changed.
  • For those Member States that require a jurisprudence exam, the exam ensures that PTs and OTs working in their state know the laws, regulations, and rules of their state prior to working in their respective states.
  • By ensuring that Compact Licensees know the laws and regulations prior to working in a given state, it helps to reduce issues related to scope of practice differences as well as reduce potential regulatory and criminal issues a therapist could experience if they practice without knowing the legal requirements in each state they work in.
Other Compacts that use Compact Privilege include:
  • Audiology and Speech-Language Pathology Interstate Compact
  • Counseling Compact
  • Dentist and Dental Hygienist Compact
  • Physician Assistant Licensure Compact (in process, 7 states have not yet joined to activate the Compact)

What are the remaining types of healthcare Compacts?


  • Medical Licensure Compact: Compact Licensees simply apply through the Compact to obtain a license in another Compact Member State and the Compact processes the license with the state's regulatory agency they want to work in. This is considerably simpler than having to actually apply directly to the state because the process of becoming a Compact Licensee has already vetted the doctor to make them eligible to work in other Compact Member States.
  • The Emergency Medical Services Compact: provides privilege to work in other member states but follows the laws and regulations of the Home State unless required by a Physician Medical Director (employer) that they work for or the Remote State itself to follow local practices and regulations.
  • Psychology lnterjurisdictional Compact: Any Compact State may require a psychologist to obtain and retain a license to be authorized to practice in a Compact State under circumstances not authorized by Temporary Authorization to Practice under the terms of this Compact.

Issues regarding the Interstate Massage Compact:

Before reading this section, we recommend that you have read at a minimum the following blue sections:

The primary issues that WSMTA has regarding the Interstate Massage Compact revolve around the Compact Model that was selected and the fact that the nursing profession is structurally different from our profession. Ultimately, WSMTA feels that massage therapists holding a license through the Interstate Massage Compact will potentially:

  • be put at a greater risk of causing harm to the general public
  • face greater risk of civil, criminal and regulatory charges
  • increase licensing fees for Washington massage therapists, and
  • negatively impact the reputation of the massage therapy profession in Washington State.

To read about these issues, please click on the link below:


1.) Issues created by the Compact Model selected:  The two largest issues WSMTA has with the Interstate Massage Compact have to do with the model selected -- the Nurse Licensure Compact.  We believe that it would remove too much regulatory authority from the states and the Compact Commission and gives too much freedom of movement to the Multistate Licensee (the massage therapist).  Without controls built in to ensure the safety of the Multistate Licensee and the public, it will create extra expense for Member States, Multistate Licensees and the Compact.

  • Inability for a Compact Member State to know which Multistate Licensees are practicing in its state creates the potential for safety and liability issues:  The Interstate Massage Compact allows any Multistate Licensee to practice at will in any Compact Member State without any kind of check-in with the licensing authority in that state or without notifying the Compact.  This has the following implications:
  • Multistate Licensees do not know the latest changes to laws and regulations: When any law or regulation changes in a state, the state does not have the ability to notify the Multistate Licensees practicing in its state of the changes which could lead to:
    • liability issues for the Multistate Licensees
    • added disciplinary expenses for the Multistate Licensee and Remote State
    • additional expenses either to the Compact Member States or Compact to work around this issue.
    • increased licensing fees to the resident massage therapists in a Compact Member State, since the Remote State's regulatory agency is financially responsible for any
  • Problems managing Multistate Licensees with disciplinary Issues: When a nurse in the Nurse Licensure Compact is facing disciplinary action, it is possible that the nurse could continue to illegally work in the Remote State because both the Compact and the regulatory agency of the state the nurse is working in both do not know where the nurse is working due to the way the Compact model was created.  Since our Compact uses the same compact model as the Nurse Licensure Compact we could have this same issue.
  • LMTs are unlikely to be educated in legal and regulatory issues by employers, nurses are more likely to be:  Massage therapists generally work for very small employers or for themselves whereas nurses work generally for larger companies like hospitals, health clinics, travel nurse companies, etc.  Multistate Licensee nurses are more likely to be educated by their employer of any changes to laws or regulations in the state they are working in.  This often wouldn’t happen in the massage profession since many massage therapists work either for themselves, small healthcare settings or in non-healthcare settings like hotels, gyms, day spas, resorts, etc.  This is a structural difference between the way massage therapists and nurses practice which would create problems for massage therapists, since our Compact Model is based on a profession that has different employment practices than our own.
  • Problems and expenses related to tracking large-scale licensure fraud: The large fraud case involving around 7600 illegal nursing degrees that was disclosed in February 2023 required a large-scale effort involving the FBI, national media and each state’s regulating agency to track down the thousands of nurses that were able to illegally become licensed.  Since nurses work for a relatively small number of employers (hospitals, clinics, travel nurses, hospice, etc.) and massage therapists work either for themselves or for a very large number of small employers, it would be really difficult to track down LMTs if a similar fraud situation happened with LMTs.  Most likely, the regulatory world would have to depend on the illegally gained licenses expiring and not being able to renew to remove any such fraudulent LMTs from practice.
  • Potential disciplinary and legal issues due to the lack of a jurisprudence exam prior to practicing in a remote state: Because licensed massage therapists are healthcare providers in Washington State, we have considerably more and differing kinds of regulations and laws to navigate than all other states.  This has three implications:
  • Greater Risk to the Public: The general public is at greater risk of harm from Multistate Licensees who do not know our laws and regulations.  Over time, this may impact the public's view of our value and professionalism in helping people to recover from their issues.
  • Greater Risk to Multistate Licensees: Multistate Licensees are at greater risk for having regulatory, civil or criminal charges brought against them as well as having their massage licenses sanctioned if they are not aware of all scope of practice issues and all laws and regulations in the Compact Member states they will be working in prior to working in those states.
  • Potential for Increased Washington State Licensing Fees: Washington State LMTs could have higher licensing fees, since issues related to misconduct by Multistate Licensees will be borne by the state the misconduct occurs in.

2.) Potential long-term Issue created by having Multistate Licensees in Washington State:  Currently, massage therapists from other states who move to Washington, are vetted by the Department of Health to become Washington State massage therapists and then they eventually get absorbed into the local massage culture.  However, if the Compact were to bring numerous temporary workers to our state, how will they comport themselves in the temporary time they work here if they are oblivious to our scope of practice, our role as healthcare providers and all the requirements we work within to be massage therapists in Washington State?

  • How will the Compact affect the professionalism of LMTs in Washington State?  Over the years, LMTs have worked hard to build and maintain relationships with individual doctors, physical therapists, chiropractors, etc. which has helped to raise the awareness of massage and the opinion that massage helps patients to recover from conditions and injuries and has a place in the healthcare world – in addition to providing a relaxing experience that can reduce stress.
  • The education differences of massage therapists outside of Washington State:  In most states, massage therapy is considered to be a personal service and not part of healthcare.  Because of this, massage therapy education in other states can be very different from what is taught in Washington State.  These are some of the primary educational pieces usually lacking in LMTs from other states who have to go through transfer school to become licensed in Washington:
  • The ability to do assessments: active range of motion, passive range of motion, resisted motion, palpation based assessments, visual assessments, and so on.
  • The ability to create, amend and follow a treatment plan.
  • The ability to measure and chart gains and losses of function and mobility.
  • The knowledge of HIPAA requirements.
  • The ability to know when consent is required with a client, both from a legal perspective and from a "this is right for this person” perspective based on the client’s fears and feelings about how and where their body is touched/massaged.  In Washington, quite a few things that massage therapists do legally require written, verbal and/or informed consent.
Issues regarding CSG and FSMTB’s presentation of information about the Compact:

Note: WSMTA has contacted the Council of State Governments (CSG) about some of the inconsistencies on the Interstate Massage Compact website hosted by CSG.  At some time in the future, some of these inconsistencies may be changed, if that happens, we will update our webpage accordingly.

WSMTA has concern over how the Interstate Massage Compact is being presented by the Counsel of State Governments (CSG) and FSMTB on the Compact website and in their talks to interested parties.  Only the Compact Commission (should it be created) can create the rules that will govern the Compact, yet CSG and FSMTB are making statements on outstanding topics as if they have already determined the regulations prior to the creation of the Compact Commission.  In addition, they are not fully explaining the benefits of the Compact, such as mobility, and what might be a benefit in one state, might not be in another.  Finally, WSMTA is concerned about how the educational requirement of 625 hours is being handled and that it could lead to lowering the standards of our profession.

To read about these issues, please click on the link below:


1.) WSMTA is concerned that CSG and FSMTB appear to be glossing over some of the benefits of the Compact, especially when mentioning mobility and enhancing public safety to make them appear more attractive:

  • Mobility: The Interstate Massage Therapy Compact website indicate that “mobility” is a benefit without fully describing what “mobility” means when it uses this term. The Compact helps massage therapists to work in Remote Compact Member States as long as they do not move (change residence) to the Remote State they are working in. The Compact does not help massage therapists to move from one state to another.  This is not openly discussed, except in one pdf on the Compact website.  Their use of "mobility" is misleading because of this and may influence massage therapists to want to join the Compact if massage therapists feel it will help them move from one state to another.
  • Enhancing Public Safety: – Massage therapists with less than 625 hours of massage school education may be able to join the Compact should the Compact Commission decide to allow continuing education to make up the difference between their massage school hours and the 625 hours needed to join the Compact. For states that currently require 625 hours or more of massage school education, this would not “enhance a state’s public safety” and is misleading to add it as a benefit, when it might be for some states and not other states.

2.) WSMTA is concerned that some of the information that CSG and FSMTB are presenting about the Interstate Massage Compact seems to be based on a foregone conclusion, as if what they are saying is how an issue will be handled.  What actually happens will be dependent on the Compact Commission creating rules, not what CSG and FSMTB state will happen.  FSMTB and CSG should be stating that these are “possible solutions to this problem”, or, “if the Compact Commission approves our suggestion”.  Instead, they are portraying these possible solutions as facts, as if these decisions were already made before the Compact Commission has been created.

  • 625 Hours:  they should state that it “could include continuing education, to be determined by the Compact Commission”, instead of -- "The compact only specifies “clock hours” with no mention of a massage therapy education program. Continuing education hours will count towards an applicant meeting the 625-hour requirement." as indicated on the Compact FAQ page.   
  • National Licensing Examination: they should state that an applicant for the Compact License should have passed a “National Licensing Examination or the substantial equivalent which the Commission may approve by Rule”, instead of stating, "Have passed a national licensing examination", as indicated on the Compact FAQ page, which indicates only the MBLEX can be used.
3.) WSMTA is concerned that how CSG and FSMTB are using "625 hours" may lower the standards of our profession.   In CSG and FSMTB's statements about the minimum hours of education, 625-hours of massage education is discussed as the most important aspect of education.  However, what really is important is the content that adds up to 625 hours.  If you look at their document “Why 625?” at https://massagecompact.org/wp-content/uploads/sites/32/2023/01/Why-625.pdf you will see this statement:

The massage education Entry-Level Analysis Project (ELAP) identified 625 hours as the minimum number of hours required to receive a thorough entry-level education.   (https://elapmassage.org/)

WSMTA feels that this statement omits a critical fact, neglecting the far more important fact of course content.  ELAP is a great piece of work that helped to define what the entry-level minimum education should be for a massage therapist to practice safely.  Many massage therapy organizations came together to sponsor this work so it has the support of the vast majority of the massage community. 

  • What is missing:  It is not the number of hours that is important, it is the content that was developed that is important, and it just happens to add up to 625 hours.
  • What is more important: because it is the content of the 625 hours that is very important, it is disingenuous of CSG and FSMTB to state that any type of massage-based education could be used to make up the 625 hours, to include random continuing education. This doesn’t make for safe massage therapists if they do not have a  foundational massage education.  

    • It is also disingenuous of CSG and FSMTB to state that the Compact will make clients safer in member states when some states have already based their 625-hour (or greater) minimum massage school education on ELAP and now the Multistate Licensees could enter such a state with inferior training.


Issues with "who" will help create the initial Compact Commission Rules:

The Compact Model Legislative Language states in Article 8, section B, subsections 1 and 2:

1. Each Member State shall have and be limited to one (1) delegate selected by that Member State’s State Licensing Authority.
2. The delegate shall be the primary administrative officer of the State Licensing Authority or their designee.

It also states in the Definition section in Article 2:

“Licensing Authority” - a State’s regulatory body responsible for issuing Massage Therapy licenses or otherwise overseeing the Practice of Massage Therapy in that State.

This language is not clean and clear which creates issues.  In other Compacts, it is very clear. 

In some states, the Board of Massage holds all power to regulate, issue licenses and oversee the practice of massage, but in other states these responsibilities are split between the Board of Massage and a state agency, like Washington's Department of Health or the Department of Licensing in other states.  In the states that split responsibility, it could be the state agency's Executive Director which becomes the state's delegate to the Compact Commission or it could be a Board Member depending on  each state's given situation.  Or, it could be possible for the Board of Massage and the Department of Health (or equivalent agency) to split duties as the delegate to the Compact Commission can always assign a designee.

In states, like Washington, the Executive Director (ED) -- or the equivalent depending on the state -- of each state's regulatory agency would most likely be the delegate for the Compact Commission.  In Washington, the ED is an employee of the Department of Health who oversees about 4-5 Professional Boards.  Executive Directors generally do not spend more than a couple of years, at most, with any Board they manage. EDs are generally not healthcare providers but lean more toward being educated in public policy administration.

Here are WSMTA's three primary concerns:

  • WSMTA's primary concern is that it will be non-massage therapists determining important rules related to the non-regulatory function of our profession, such as what education can comprise the 625 hours of education?  Or, can the NCBTMB exam be used in substitution of the MBLEX.  Things that regulators should not be deciding, but massage professionals.
  • WSMTA's secondary concern is that if Washington is one of the initial seven states that joins the compact in an attempt to try and influence the initial creation of Commission Rules, how much influence will our state really have?  We are concerned that since most states already send delegates to the Federation of State Massage Therapy Boards (FSMTB), these same delegates could potentially also serve in the Compact Commission at the same time or at different times and that they could be unduly swayed by FSMTB's priorities versus our state's priorities.
  • Conversely, WSMTA's third primary concern is that Board of Massage members and LMTs in general are not trained in the art of negotiation and possibly would not know how to influence or persuade others to their point of view.

In addition:

  • In many other states, massage is considered to be a professional service and not part of healthcare. The ED that represents massage therapy in those states would more than likely have even less knowledge about massage therapy and healthcare than in our state.
  • EDs could represent the opinion of their own state’s regulatory position, not necessarily the well-being or benefit of the profession they represent.

Possible Solution: WSMTA suggests that should Washington join the Compact in the early stages of developing Compact Commission Rules that it should send both an ED (or other Department of Health designee) and a Board of Massage professional member so that they can both bring their strengths and perspectives. This way our profession is better represented. Only one of these people would be the official delegate and would be able to vote, but together, they would offer the best solutions.

Similarity of issues between the Nurse Licensure Compact (NLC) and the Interstate Massage Compact:

Back in February 2023, when WSMTA began further exploration about the Nurse Licensure Compact, we became aware of the documents that the Washington State Nurses Association (WSNA) had published online.  WSNA, as well as other states' nurse associations had issues with the NLC and had refused to join the NLC.  The issues they have are very similar to WSMTA's issues regarding the Interstate Massage Compact.


The following are some of the postings WSNA has made.

Nurses in Washington state did not want to join the Compact.  Like we mentioned in the "Nurse Licensure Compact -- The compact model the Interstate massage Compact is based on:" section, large employers were able to overcome the nurses objection to joining their compact and were able to have legislation passed in 2023 forcing the nurses to join.

Similarly, the Massage Therapy Compact has also gained support from large destination resort employers who have been invited to attend CSG and FSMTB sponsored gatherings as vocal supporters of the Compact.  Also, in January 2023, it was the lobbyist for a large national massage therapy spa chain that initiated legislation to enter Washington into the Interstate Massage Compact at a time, when Washington massage therapists knew nothing about the Compact.  WSMTA was instrumental in having this legislation pulled from the 2023 legislative session so our profession could have a greater input in 2024.

The Compact is not likely to satisfy the employment needs caused by massage therapist shortages:

WSMTA found one research document on the topic of the movement of nurses in the Nurse Licensure Compact (NLC) for employment purposes.  The title of the document is: Labor Supply Effects of Occupational Regulation:  Evidence from the Nurse Licensure Compact © 2016 by Christina DePasquale and Kevin Stange, which can be found at www.nber.org/papers/w22344.pdf  Note:  this document is a working paper and is not peer reviewed.  It was created in 2016, well before the pandemic interrupted the flow of people and goods and two years prior to the dissolution of the original Nurse Licensure Compact.


This is the abstract from the document (the authors provide permission to copy two full paragraphs): 

There is concern that licensure requirements impede mobility of licensed professionals to areas of high demand. Nursing has not been immune to this criticism, especially in the context of perceived nurse shortages and large expected future demand. The Nurse Licensure Compact (NLC) was introduced to solve this problem by permitting registered nurses to practice across state lines without obtaining additional licensure. We exploit the staggered adoption of the NLC to examine whether a reduction in licensure-induced barriers alters the nurse labor market. Using data on over 1.8 million nurses and other health care workers we find no evidence that the labor supply or mobility of nurses increases following the adoption of the NLC, even among the residents of counties bordering other NLC states who are potentially most affected by the NLC. This suggests that nationalizing occupational licensing will not substantially reduce labor market frictions. (page 1)

This is from the conclusion on page 26:

In this paper, we estimate the effects of the Compact on labor force, migration, and commuting outcomes. In comparison to other health workers who were not affected by the Compact, we find little evidence that the labor supply or mobility of nurses increased following the adoption of the Compact in the nurses’ home state. Specifically, we find no effect on labor force participation, employment levels, hours worked, wages or the probability of working across state lines. When limiting our sample to nurses that live in border counties and examining the effect of living in a Compact state and bordering another member state, we similarly find no effect on labor market outcomes, including commuting times, for most specifications. Effects on cross-state migration are imprecise, but leave open the possibility that the NLC impacts cross-state migration for very mobile workers. Supplemental hospital-level analysis also revealed no measurable impact of NLC exposure on the aggregate nurse hours worked at hospitals.

WSMTA feels that massage therapists, at least for the next 5-10 years, will probably experience a similar situation as put forward in this research paper.  While we are currently experiencing a national shortage of massage therapists, we don’t have quite the same situation as nurses.  Nurses can work for travel nurse employers that can either be local or multi-state.  Massage therapists do not have this type of employment. 

If massage therapist shortages are big enough, as they are now, it’s possible some multi-state massage therapy clinic employers and multi-state destination hotels and spas might entice some massage therapists with higher pay or temporary housing to cross state lines to come temporarily work for them via a Compact, but the compact will not help those workers to move. 

Conclusion:  WSMTA feels that the Compact will provide benefits on an individual basis, but it will not solve labor shortages or increase the supply of massage therapists.  If “A” State is short on massage therapists for example, and employers recruit out-of-state massage therapists from “B” State to come work to fulfill the demand, there more than likely will be just as many “A” State massage therapists who get pulled away to work in other states because of higher wages offered by employers there facing their own staff shortages.

WSMTA feels that our profession would be better off having money spent recruiting students into massage schools instead of employers recruiting LMTs away from other employers.

What should Washington State do about the Interstate Massage Compact?

WSMTA perceives that there are 4 ways that Washington State could act regarding the Interstate Massage Compact:

  1. Join Now: Be one of the first 7 states to pass into law the Interstate Massage Compact Model Legislature language, with the intent of influencing the Commission Rules that are created.
    • Possible Partial Solution to issues with the Compact Model: It could potentially be possible to circumnavigate some of the issues created by using the Nurse Licensing Compact as the compact model.  If the Interstate Massage Compact Commission would require all LMTs to register all places of business or employers outside of their Home State with the Compact, this would enable each Remote State, should they choose, the ability to: 
      • Know who may be working in their state so any legal and regulatory changes can be provided to Compact Licensees working in their states.
      • Administer a jurisprudence exam to Compact Licensee who indicate they work in their state.  This exam would most likely be administered after an LMT has begun working in a Remote State and they could potentially be prohibited from continuing to work in that state if they can not pass the exam. Ideally, the exam should be administered prior to an LMT working in a new state in case there is an issue in their taking the exam
    • Ending membership in the Compact may not be possible: In the event that the Compact does not work for Washington, it would require the legislators to repeal the RCW that creates Washington's membership in the Compact. Since legislators change over time, this might not be easy or even possible to do. A reminder that Washington joined the Nurse Licensure Compact against the will of the nurses.
  2. Join Later: Washington could wait to see how the Compact Commission develops its rules and determine at a later date if the Compact is something that will be beneficial for Washington LMTs.
  3. Not Join: Remain outside of the Interstate Massage Compact.
  4. Modify the Model Language prior to 7 states ratifying the Compact Model Legislative Language and activating the Compact: If there is a coordinated effort it could be possible to modify the Interstate Massage Compact model Legislative Language to incorporate changes that would make it more functional.  However, for this to happen, seven states would have to put into law this modified Compact Model Legislative Language to activate the Compact, which would take a strong outreach effort to reach out to individual states and national associations.

Military Spouses: If Washington chooses to remain outside of the Compact, or the Compact is never activated, Washington legislators seem amenable to helping military spouses to more easily become licensed in Washington for the duration of their spouses deployment.  There are other states that have enacted laws creating a simpler pathway to licensure for military spouses that Washington could copy.

Important Links:

Interstate Massage Therapy Compact: Nurse Licensure Compact: Physical Therapy Compact:

Interstate Massage Compact Q&A:

Here are some of the most common questions and the answers. The answers come from two different locations, the Massage Compact Model Legislative document (these are listed by Article number), and the Council of State Governments (CSG) Interstate Massage Compact webpages. Why both you might ask? We have included both because sometimes the CSG and FSMTB answers don't always align with the Compact's Model Legislative language and the Model Legislative language is the ultimate authority until the Compact Commission is created should the Compact be activated.

Note: WSMTA has contacted the Council of State Governments (CSG) about some of the inconsistencies on the Interstate Massage Compact website hosted by CSG.  At some time in the future, some of these inconsistencies may be changed, if that happens, we will update our webpage accordingly.

What is an interstate compact?

Answer

ARTICLE 1- PURPOSE The purpose of this Compact is to reduce the burdens on State governments and to facilitate the interstate practice and regulation of Massage Therapy with the goal of improving public access to, and the safety of, Massage Therapy Services. Through this Compact, the Member States seek to establish a regulatory framework which provides for a new multistate licensing program. Through this additional licensing pathway, the Member States seek to provide increased value and mobility to licensed massage therapists in the Member States, while ensuring the provision of safe, competent, and reliable services to the public.

An interstate compact is a contract among two or more states creating an agreement on a particular policy issue, adopting a certain standard or cooperating on regional or national matters. Compacts are powerful, durable and adaptive tools for ensuring cooperative action among states. In recent years, professions have been using interstate compacts to facilitate occupational licensing reciprocity among states.  

How can a state, or jurisdiction, become a member of the massage compact?

Answer

ARTICLE 3 - MEMBER STATE REQUIREMENTS  

A. To be eligible to join this Compact, and to maintain eligibility as a Member State, a State must: 

  1. License and regulate the Practice of Massage Therapy; 
  2. Have a mechanism or entity in place to receive and investigate complaints from the  public, regulatory or law enforcement agencies, or the Commission about Licensees  practicing in that State;
  3. Accept passage of a National Licensing Examination as a criterion for Massage Therapy licensure in that State;
  4. Require that Licensees satisfy educational requirements prior to being licensed to provide Massage Therapy Services to the public in that State;
  5. Implement procedures for requiring the Background Check of applicants for a Multistate License, and for the reporting of any Disqualifying Events, including but not limited to obtaining and submitting, for each Licensee holding a Multistate License and each applicant for a Multistate License, fingerprint or other biometric-based information to the Federal Bureau of Investigation for Background Checks; receiving the results of the Federal Bureau of Investigation record search on Background Checks and considering the results of such a Background Check in making licensure decisions;
  6. Have Continuing Competence requirements as a condition for license renewal;
  7. Participate in the Data System, including through the use of unique identifying numbers as described herein; 
  8. Notify the Commission and other Member States, in compliance with the terms of the Compact and Rules of the Commission, of any disciplinary action taken by the State against a Licensee practicing under a Multistate License in that State, or of the existence of Investigative Information or Current Significant Investigative Information regarding a Licensee practicing in that State pursuant to a Multistate License;
  9. Comply with the Rules of the Commission; *there are not any Rules yet*
  10. Accept Licensees with valid Multistate Licenses from other Member States as established herein;

B. Individuals not residing in a Member State shall continue to be able to apply for a Member State’s Single-State License as provided under the laws of each Member State. However, the Single-State License granted to those individuals shall not be recognized as granting a Multistate License for Massage Therapy in any other Member State; 

C. Nothing in this Compact shall affect the requirements established by a Member State for the issuance of a Single-State License; and 

D. A Multistate License issued to a Licensee shall be recognized by each Remote State as an Authorization to Practice Massage Therapy in each Remote State.   

IMpact allows massage therapists who live in a compact member state and maintain an active, unencumbered license to apply for a multistate license. After verifying eligibility, the massage therapist is granted a multistate license. The massage therapist can then practice in all compact member states through one multistate license. The massage therapist must also maintain their home state license in good-standing.

How does the massage compact work?

Answer

The compact allows massage therapists who maintain an active, unencumbered license in the compact member state where they reside (Home State) to apply for a multistate license. After verifying eligibility, the massage therapist is granted a multistate license which authorizes practice in all other compact member states (Remote State). The massage therapist must maintain their “home state” license in good standing.  

What is a multistate license?

Answer
ARTICLE 2- DEFINITIONS, Subsection H.

“Multistate License” - a license that consists of Authorizations to Practice Massage Therapy in all Remote States pursuant to this Compact, which shall be subject to the enforcement jurisdiction of the Licensing Authority in a Licensee’s Home State.

A massage therapist who wishes to practice in multiple states under the compact will apply for a multistate license. To be eligible, a massage therapist must hold an active license in their primary state of residence (Home State) (which must be a member of the compact) and meet other eligibility criteria (see below). When eligibility is verified and all fees are paid, the therapist receives the multistate license and may begin legally working in any compact member state (Remote State). 

What are the eligibility requirements for a multistate license? 

Answer

ARTICLE 4 - MULTISTATE LICENSE REQUIREMENTS

A. To qualify for a Multistate License under this Compact, and to maintain eligibility for such a license, an applicant must: 

  1. Hold an active Single-State License to practice Massage Therapy in the applicant’s Home State; 
  2. Have completed at least six hundred and twenty-five (625) clock hours of Massage Therapy education or the substantial equivalent which the Commission may approve by Rule.
  3. Have passed a National Licensing Examination or the substantial equivalent which the Commission may approve by Rule.
  4. Submit to a Background Check; 
  5. Have not been convicted or found guilty, or have entered into an agreed disposition, of a felony offense under applicable State or federal criminal law, within five (5) years prior to the date of their application, where such a time period shall not include any time served for the offense, and provided that the applicant has completed any and all requirements arising as a result of any such offense; 
  6. Have not been convicted or found guilty, or have entered into an agreed disposition, of a misdemeanor offense related to the Practice of Massage Therapy under applicable State or federal criminal law, within two (2) years prior to the date of their application where such a time period shall not include any time served for the offense, and provided that the applicant has completed any and all requirements arising as a result of any such offense; 
  7. Have not been convicted or found guilty, or have entered into an agreed disposition, of any offense, whether a misdemeanor or a felony, under State or federal law, at any time, relating to any of the following:
    1. Kidnapping;
    2. Human trafficking;
    3. Human smuggling;
    4. Sexual battery, sexual assault, or any related offenses; or
    5. Any other category of offense which the Commission may by Rule designate.
  8.  Have not previously held a Massage Therapy license which was revoked by, or surrendered in lieu of discipline to an applicable Licensing Authority; 
  9. Have no history of any Adverse Action on any occupational or professional license within two (2) years prior to the date of their application; and 
  10.  Pay all required fees.

B. A Multistate License granted pursuant to this Compact may be effective for a definite period of time concurrent with the renewal of the Home State license. 

C. A Licensee practicing in a Member State is subject to all scope of practice laws governing Massage Therapy Services in that State. 

D. The Practice of Massage Therapy under a Multistate License granted pursuant to this Compact will subject the Licensee to the jurisdiction of the Licensing Authority, the courts, and the laws of the Member State in which the Massage Therapy Services are provided.

A licensed professional massage therapist must:  
  • Hold an active, unencumbered license in their home state (the state where they reside).  
  • Have completed at least 625 clock hours of massage therapy education.  
  • Have passed a national licensing examination.  
  • Submit to a background check.  
  • Have not been convicted or found guilty, or have entered into an agreed disposition, of a felony offense under applicable state or federal criminal law, within five years prior to the date of their application.  
  • Have not been convicted or found guilty, or have entered into an agreed disposition, of a misdemeanor offense related to the practice of massage therapy under applicable state or federal criminal law, within two years prior to the date of their application.  
  • Have not previously held a massage therapy license that was revoked by, or surrendered to, an applicable regulatory authority.   
  • Have no history of any adverse action taken by the applicable body responsible for the regulation of the massage therapy profession in the applicant’s home state within two years prior to the date of their application.  
  • Have not been convicted or found guilty, or have entered into an agreed disposition, of any offense, whether a misdemeanor or a felony, under state or federal law, at any time, relating to any of the following:  
  • Kidnapping.  
  • Human trafficking.  
  • Human smuggling. 
  • Sexual battery, sexual assault, or any related offenses. 
  • Any other category of offense which the commission may by rule designate.  
  • Pay all required fees. 

How are military spouses different within the Compact?

Answer

ARTICLE 7 - ACTIVE MILITARY MEMBER AND THEIR SPOUSES 

Active Military Member, or their spouses, shall designate a “Home State” where the individual has a current license to practice Massage Therapy in good standing. The individual may retain their “Home State” designation during any period of service when that individual or their spouse is on active duty assignment. 

Do continuing education hours count toward the 625-hour requirement?

Answer

ARTICLE 4 - MULTISTATE LICENSE REQUIREMENTS, Subsection 2

Have completed at least six hundred and twenty-five (625) clock hours of Massage Therapy education or the substantial equivalent which the Commission may approve by Rule.

Yes. The compact only specifies “clock hours” with no mention of a massage therapy education program. Continuing education hours will count towards an applicant meeting the 625-hour requirement.

WSMTA Comment: Only the Compact Commission can determine if continuing education can be used towards the 625 hours. And, only the Compact Commission can determine how much and what types of continuing education can be used if it chooses to allow it.  FSMTB and the initial states invited to create the Model Legislative Language may have determined this is what they wanted to do but the first seven states that join may choose to do something different.  Therefore, the FAQs page on the CSG and FSMTB website should only only suggest that continuing education could be an option.

If you have any questions, or would like to make comments, please contact us at: gr@mywsmta.org.

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