Do Telehealth Hours Count Toward Licensure? What to Check

Updated 6 minute readBy the Exclusive Design Lab team

Do telehealth hours count toward licensure? It varies by board, and you should check before you count it. Some boards treat live video sessions exactly like in-person contact, some cap the share of hours that can be delivered remotely, some distinguish video from telephone or message-based work, and some apply different rules to supervision than to client sessions.

In other words, telehealth hours for licensure are accepted in many places and limited in others, and the difference is decided by your board rather than by your employer or your training program. The practical answer is not to guess in either direction. Ask your board the specific questions below, get the reply in writing, and tag every entry with its delivery method so you can produce whatever split the board eventually wants.

Ask Your Board These Questions

Send them in one email, numbered, so the reply addresses each. A written answer with a date on it is worth far more than a phone call you half-remember.

  1. Do live video sessions with clients count as direct client contact hours toward licensure?
  2. Is there a limit on how many, or what percentage of, my hours may be delivered by telehealth?
  3. Does telephone contact count? Does asynchronous contact, such as secure messaging, count?
  4. May supervision be delivered by video, and is there a limit or an in-person minimum?
  5. Does it matter where the client is physically located during the session?
  6. Does it matter where my supervisor is licensed if supervision happens remotely?
  7. Are there platform or security requirements that affect whether hours count?
  8. If the rules change while I am accumulating hours, do hours earned under the earlier rules still count?

Save the reply as a PDF with the date in the filename, and keep it with your supervision records. If your board publishes written guidance instead, save the page as a PDF too, since published guidance gets revised without notice.

Why the Answer Differs So Much

Telehealth rules were rewritten across many jurisdictions in a short period, and boards landed in different places. Requirements also sit in more than one document, so the hours rule, the telehealth practice rule and the supervision rule may each say something relevant.

Three areas where boards commonly differ:

  • Modality. Live two-way video is treated most favorably. Telephone-only and asynchronous contact are more often limited or excluded.
  • Caps. Some boards accept telehealth without limit. Others cap it as a share of direct hours or as a fixed number.
  • Jurisdiction. Where the client sits during the session can matter, because practice is generally regulated where the client is located. That affects whether the session was lawful, which in turn affects whether the hour counts.

None of this is legal advice, and none of these patterns tell you what your board does. They tell you which questions to ask.

What a Cap Would Cost You: the Math

This is why the answer matters before you have accumulated two years of sessions.

Say you have logged 640 direct client contact hours, and 288 of them were delivered by video. That is 288 ÷ 640 = 45 percent of your direct hours.

  • If your board has no cap, all 640 count.
  • If your board capped telehealth at 25 percent of direct hours, only 160 hours would count. You would lose 128 hours.
  • At a pace of 9 direct hours a week, 128 hours is about 14 weeks, or roughly three and a half months added to your timeline.

The same arithmetic in reverse is a planning tool. If a 25 percent cap applies and you need 1,200 direct hours, at most 300 may come from telehealth, so you need at least 900 in-person direct hours. At 9 direct hours a week with a third of them remote, you would be generating about 6 in-person hours a week, giving 900 ÷ 6 = 150 weeks against a total-hours timeline of perhaps 136. In-person contact becomes the binding constraint, which is a scheduling problem, not an effort problem. How to set clinical hour targets works through how to rebalance when one category binds.

Log Modality on Every Entry, Starting Now

Tagging takes a second per entry and solves the whole problem later. Add these fields to your log:

Field Values to use
Delivery method In person, video, telephone, asynchronous
Platform type Agency platform, practice platform, other
Client location type Same state, other state, unknown
Supervision delivery In person, video, telephone
Session format Individual, group, family, couple

With those columns in place, any recount is a filter, not a research project. Without them, a new cap means reading two years of calendar entries and guessing.

Keep one more habit: if a session started in person and moved to video partway through a training period, or a client relocated mid-treatment, note it in the entry. Those are the entries a reviewer asks about.

Supervision by Video Is a Separate Question

Trainees often get a clear answer about client sessions and assume it covers supervision. It usually does not. Boards frequently address supervision modality in its own rule, and some that accept telehealth with clients still expect a portion of supervision to be face to face.

Record supervision delivery method in every supervision entry, along with the usual fields. If your supervisor is in another state, ask specifically whether their license needs to be in your state for the supervision to count. Clinical supervision documentation requirements covers the full field list for both individual and group meetings.

A Safe Way to Work While You Wait for an Answer

If you cannot get a definitive answer quickly, protect yourself:

  1. Keep a balanced mix. Deliver in-person hours where your setting allows it rather than going fully remote on an assumption.
  2. Tag everything. Modality, platform type and client location on every entry.
  3. Track the split as a live number. If you know you are at 31 percent telehealth, you can steer. If you find out at application time, you cannot.
  4. Note what your setting told you. If an agency directed you to work remotely, record that instruction and its date.
  5. Ask again when rules change. A rule that applied when you started may have been replaced by the time you apply.

A dashboard that shows in-person and remote hours side by side makes step three effortless. Our clinical hours tracker spreadsheet for Google Sheets lets you set up your own categories, so a modality split can sit alongside your direct, indirect and supervision totals rather than living in a separate file.

What Counts as Contact in a Video Session

If telehealth does count for you, the ordinary rules about what qualifies as contact still apply. Scheduling a video call is not contact. Waiting for a client who does not join is not contact. The clinical time itself is, and you log the real start and end times just as you would in an office.

Technology failures deserve a note. A session that ended at eighteen minutes because the connection dropped is 0.30 hours, and a line in the entry explaining the ending is worth writing. For the general boundaries, see what counts as direct client contact hours and how to track clinical hours for licensure.

Before You Apply

When you assemble your application, run the telehealth split as a report and compare it against the rule in force. If there is a cap and you are near it, say so plainly in your materials rather than leaving a reviewer to discover it. Transparent numbers with a clear method behind them are treated very differently from totals that seem to have been assembled to fit. Clinical hours verification for a license application covers how to put that packet together.

The single action worth taking today: open your log and add a delivery method column, then fill it in for the entries you can still reconstruct accurately. Everything else in this guide depends on having that field.

Frequently asked questions

Do telehealth sessions count as direct client contact hours?

Sometimes, and it varies by board and profession. Some boards count live video sessions the same as in-person contact, some limit how many telehealth hours can count, and some treat phone or message-based contact differently. Confirm with your board before you count them.

Does supervision delivered by video count?

That is a separate rule from client sessions, and boards answer it separately. Some allow remote supervision without limit, some cap it, and some require a portion to be in person. Ask about client sessions and supervision as two different questions.

What should I record for a telehealth session?

Everything you record for an in-person session, plus the delivery method, the platform type and the client's general location at the time if your board cares about jurisdiction. Tagging modality costs seconds and makes any later recount easy.

What if my board changes its telehealth rules while I am accumulating hours?

Rules that change mid-training are exactly why you tag modality on every entry. If a cap appears, you can produce an in-person and remote split immediately instead of reconstructing two years of sessions.