Interstate Massage Compact (IMpact) Update

September 4, 2024

AMTA supports greater mobility through an interstate compact and has been deeply involved in discussions to address barriers and restrictions within the current IMpact that could create unnecessary hurdles and prevent many massage therapists from participating.

Recently, AMTA and FSMTB met to discuss these concerns, leading to clarifications and specific intentions outlined in the joint letter below. The AMTA Board will further discuss the IMpact at its upcoming meeting on September 9-10 in Tampa, FL. We will make sure to update our community as we continue these important conversations. 

IMpact Intentions and Clarifying Examples

The Federation of State Massage Therapy Boards (FSMTB) represents the interests of state regulatory boards and agencies in protecting the public. The American Massage Therapy Association (AMTA) represents the interests of its members and the massage therapy profession overall.

The Council of State Governments (CSG) partnered with the Department of Defense (DoD) and FSMTB to support the mobility of licensed massage therapists through development of the Interstate Massage Compact (IMpact). AMTA and FSMTB are currently fielding questions about IMpact from many massage therapists. While all the answers are not yet known, we provide the following so that massage therapists can make informed decisions about IMpact.

IMpact Commission Composition & Authority

Although the IMpact legislation provides broad statutory language, an IMpact Commission will be formed to develop the specific rules and regulations governing massage therapists’ ability to get a Multistate license. Because the IMpact Commission is not yet formed, it is unclear what the Commission would accept or allow.

What we know is that the IMpact Commission will be made up of the same people who oversee the existing state massage licensing boards and will likely be a subset of FSMTB members. Based on the IMpact development process and recommendations from subject matter experts, we are conveying the intention of the IMpact language in two key areas: education and licensing examination.

Examples of Qualifying Education

IMpact language Article 4.A.2.: To qualify for a Multistate License under this Compact, and to maintain eligibility for such a license, an applicant must: 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.

For a State: The regulatory requirement for a State to be able to participate in the IMpact is that the State requires massage therapy education. The topics covered and the number of hours that the state requires is not specified. What matters is that initial and continuing massage education must be required for a massage therapist to get and maintain a massage license in a participating State.

For a Massage Therapist: What matters for the massage therapist is that the individual LMT (i) must be licensed in a State that is participating in IMpact and (ii) must have at least 625 hours of massage education. The average entry-level massage education program offered in the United States today is in excess of the 625 hour requirement. We also know that some LMTs graduated from a massage therapy education program with less than 625 hours and that others were able to bypass education hours requirements adopted by their state after they started practicing (“grandfathered”).

The language in Article 4.A.2 that says “or the substantial equivalent” is intended to allow the IMpact Commission to include and accommodate LMTs whose core massage education was less than 625 hours, with the  intention that the core education can be supplemented with continuing education.

Example 1: If you went to a 500-hour massage program, you would need to provide proof that you have completed 125 hours of continuing education to meet the 625 hours of education requirement, even if you have been a practicing massage therapist for 5, 10, 20 or more years, before qualifying for a Multistate license.

Example 2: If you went to a 600-hour massage program, and you have not completed any continuing education but you have been in practice for several years, you still would need to provide proof that you have completed 25 additional hours of education to meet the 625 hours of education requirement before qualifying for a Multistate license. 

Examples of Qualifying Licensing Examination

IMpact language Article 4.A.3.: To qualify for a Multistate License under this Compact, and to maintain eligibility for such a license, an applicant must: Have passed a National Licensing Examination or the substantial equivalent which the Commission may approve by Rule.

For a massage therapist, the fact that a particular examination is not specifically named in the IMpact statutory language is intentional.* Article 2.U. defines a National Licensing Examination as a national exam developed by a national association of Massage Therapy regulatory boards, and the exam meets testing and security standards. The current licensing examination adopted by the majority of states for entry into the profession is the Massage & Bodywork Licensing Examination (MBLEx), which satisfies the National Licensing Examination definition. However, we know that many LMTs took an exam for licensure before the MBLEx existed or before their State adopted the MBLEx.   

The language in Article 4.A.3 that says “or the substantial equivalent” is intended to allow the IMpact Commission to include and accommodate LMTs who may have taken a different national exam in the past, such as those offered by the National Certification Board for Therapeutic Massage and Bodywork (NCBTMB). In all cases, the state in which you are licensed must have adopted IMpact.

Example 1: If you went to massage school and then took the NESL, NCETM, or NCETMB offered by the NCBTMB for licensure, then under the provision of “or the substantial equivalent” you would be eligible for the Multistate License without taking another exam.

Example 2: If you went to massage school and did not take a national exam but were licensed in one of the following ways, you would not meet the “or the substantial equivalent” requirement:

• You took a state practical exam to become licensed
• You took a state exam for licensure
• You were licensed by your state based on years in practice and did not take an exam
• You were grandfathered into licensure

In each case, your only options would be to (i) avoid the IMpact and apply for each state license individually or (ii) take the MBLEx or a substantial equivalent to be eligible for the Multistate License.

*Note that the regulatory requirement for a State to be able to participate in the IMpact is that the State must accept passage of the MBLEx for licensure.