Yes. A state may withdraw by repealing the compact statute. Withdrawal takes effect one year after written notice to the Commission to allow for orderly transition.
Following an in-depth legal and operational analysis comparing the two versions of compact legislation, the conclusion is that the proposed changes do not improve the Interstate Massage Compact (IMpact™) and, in several important respects, move the legislation further away from the principles on which interstate compacts are designed to operate.
The Interstate Massage Compact (IMpact™) model legislation was developed over nearly three years through the national interstate compact development process. Led by the Federation of State Massage Therapy Boards (FSMTB) in partnership with the Council of State Governments (CSG) and the U.S. Department of Defense, the process included state licensing boards, legislators, subject matter experts, professional organizations, educators, employers, military representatives, and other stakeholders. Every provision was carefully evaluated to balance professional mobility, public protection, and the long-term sustainability of the compact.
While some of the proposed changes may appear beneficial at first glance, the analysis found that they do not expand interstate mobility and, in several areas, reduce the flexibility needed for the compact to evolve as the profession, regulation, and public protection needs change.
For example, the proposed changes move several policy decisions from the Compact Commission's rulemaking authority into state statute. Interstate compacts are intentionally structured so that operational requirements can be addressed through Commission rules, allowing the compact to respond efficiently to changing professional standards, licensing practices, and emerging regulatory issues. Placing those decisions into statute means future changes could require legislative action in every member state rather than action by the Compact Commission.
The proposed legislation also establishes a rigid statutory pathway based on education hours and years of licensure. While intended to broaden eligibility, placing these criteria in statute limits the Commission's ability to respond to future developments. If new evidence identifies more effective ways to evaluate competency, strengthen public protection, or address emerging issues such as human trafficking, fraudulent credentials, or evolving licensure standards, the Commission would have significantly less flexibility to adapt without legislative amendments in every participating state.
The analysis also found that the proposed legislation adds new statutory restrictions regarding examination eligibility, limiting the Commission's ability to recognize future nationally accepted licensing examinations or other equivalent pathways as the profession evolves.
Most significantly, the proposed legislation creates a different compact framework rather than expanding the existing Interstate Massage Compact (IMpact™). Instead of bringing additional states into one unified compact, it creates separate legislative frameworks that must ultimately be reconciled before a functioning multistate licensing system can become a reality.
Based on that analysis, maintaining consistent legislation across participating states while preserving the Compact Commission's ability to address operational issues through rulemaking remains the most effective path toward achieving safe, efficient interstate mobility for massage therapists.
Each IMpact member state appoints one Commissioner, which will be the state board administrator/executive director or their designee. All member states have equal representation. No private entity or association controls the Commission — it operates as an instrumentality of the member states.
All Commission meetings and rulemaking sessions are open to the public. Draft rules are published for notice and comment, ensuring transparency.
A state legislature must enact the model compact bill and the governor must sign it into law. To qualify, the state must license and regulate massage therapists, require a national licensing exam, conduct background checks, and maintain continuing-competence requirements. Once seven (7) states enact the IMpact, the Compact Commission is formed to adopt rules and operating procedures.
The IMpact requires certain minimum standards for education, examination, and thresholds of professional disciplinary history that must be met regarding eligibility for a multistate license. It also strengthens public protection by linking verified data on licensees, disciplinary actions, and criminal histories. Shared intelligence among boards helps identify bad actors and prevents them from relocating or operating undetected across states.
The IMpact enhances consumer protection by sharing disciplinary information, establishing uniform minimum standards for education and examination, and enabling instant license verification. It also helps prevent human trafficking and unlicensed activity by improving cross-state communication and enforcement.
The IMpact allows a massage therapist licensed in their home state of residence (a compact member) to apply for a multistate license. Once eligibility is verified, the therapist receives authorization to practice in all other compact member states. The therapist must keep their home-state license active and unencumbered to maintain that privilege.
The IMpact data system uses secure, encrypted technology that meets state and federal standards. Only authorized regulatory officials can access the information.
The development of IMpact was initially funded through a grant from the U.S. Department of Defense (DoD) to the Council of State Governments (CSG). The purpose of this grant was to improve license portability for military families and mobile professionals by facilitating the creation of occupational licensure compacts.
The Federation of State Massage Therapy Boards (FSMTB) was selected through a competitive grant application process to serve as the steward and primary subject matter expert and for the massage therapy compact. FSMTB did not receive or manage any of the federal grant funds. Those funds were administered entirely by CSG and used solely for the development of the compact language and stakeholder engagement necessary to draft the model legislation.
When the compact language was finalized in December 2022, the DoD-funded project concluded. Since that time, FSMTB has fully funded all ongoing IMpact efforts, including legislative support, communications, technology provisions, and opted to continue collaboration with CSG under a direct contract for technical and legislative assistance.
This ensures that IMpact remains a regulator-led initiative, sustained by FSMTB and its member boards, independent of external funding or federal control.
Because more than one version of compact legislation is currently being circulated, legislators and regulators should not assume that every bill described as the Interstate Massage Compact (IMpact™) contains the same language.
The official Interstate Massage Compact (IMpact™) model legislation is available at massagecompact.org.
If proposed legislation differs materially from the model legislation published there, it is different compact legislation and should be evaluated on its own merits rather than as the enacted Interstate Massage Compact.
Costs vary depending on infrastructure but typically include integrating with the data system and staff training. These are offset by efficiencies and revenue from multistate license fees. The FSMTB is also funding certain components to reduce or eliminate the burden on government.
All rules are adopted publicly. States can provide input and may appeal or challenge a rule if it conflicts with their laws or exceeds Commission authority. States can withdraw from the Compact if necessary.
An interstate compact is a legally binding agreement between two or more states that enables them to collaborate on shared policy matters. In occupational licensing, compacts allow states to mutually recognize or streamline professional licensure across member states — supporting workforce mobility while preserving each state’s authority to regulate the profession.
The Interstate Massage Compact Commission is the governing body that administers the Compact on behalf of all member states. It is an instrumentality of the states, ensuring consistent implementation, protecting state authority, and providing a forum for coordination on licensure and enforcement.
The Interstate Massage Compact (IMpact) is a state-led agreement that enables licensed massage therapists to practice across member states under one multistate license — while preserving each state’s authority to regulate the profession and protect the public. The IMpact was developed through a grant from the U.S. Department of Defense (DoD), administered by the Council of State Governments (CSG), in partnership with the Federation of State Massage Therapy Boards (FSMTB), whose members are the state boards and agencies responsible for massage therapy regulation.
The Commission can adopt rules and bylaws, administer the data system, facilitate cross-state cooperation on enforcement, manage fees and budgets, and hire staff as needed. All rulemaking follows a public process with advance notice and open meetings.
The DoD funded development of the IMpact to support license portability for military families. The DoD does not oversee or regulate the Compact — authority remains entirely with participating states.
It preserves state sovereignty while ensuring uniform national standards. Each state retains control over its own licensing and disciplinary processes.
Yes. Documented continuing education can be applied toward the total when determining equivalency, subject to Commission rules.
No.
Participation in an interstate compact requires states to enact compatible legislation establishing the same compact framework.
Different statutory language creates a separate legal framework rather than expanding the existing compact.
A detailed comparison of the two versions found that the changes do not improve the Interstate Massage Compact (IMpact).
The Interstate Massage Compact wasn't created overnight. It was developed over nearly three years through a national process led by the Federation of State Massage Therapy Boards (FSMTB), working with the Council of State Governments (CSG), the U.S. Department of Defense, state licensing boards, legislators, educators, employers, military representatives, professional organizations, and many other stakeholders. Every part of the compact was carefully designed to support interstate mobility while protecting the public.
Although some of the proposed changes may sound appealing at first, the analysis found they do not expand interstate mobility and may actually make it harder for the compact to adapt as the profession changes over time.
One example is the new education and licensure pathway written directly into the legislation. While it was intended to allow more therapists to qualify, putting those requirements into state law makes them much harder to change in the future. If new public protection concerns emerge — such as human trafficking, fraudulent credentials, or better ways to measure competency — the Compact Commission would have much less flexibility to respond quickly. Instead, every participating state could have to pass new legislation before changes could be made.
The proposed changes also limit the Commission's ability to recognize future nationally accepted licensing examinations or other equivalent pathways as the profession evolves.
Most importantly, the changes do not build on the existing Interstate Massage Compact. Instead, they create a different compact model. Rather than bringing more states together under one compact, the profession now has two separate legislative frameworks. That makes it more difficult — and likely takes longer — to achieve the shared goal of a functioning multistate license for massage therapists.
The goal of IMpact has always been simple: one interstate compact that gives qualified massage therapists the freedom to practice across participating states while maintaining strong public protection. Based on the analysis, keeping one consistent compact is still the best path to making that goal a reality.
The easiest way is to compare it with the model legislation published on massagecompact.org.
If the language differs materially from the legislation published on this website, it is not the Interstate Massage Compact (IMpact™) enacted by the current member states.
If you are unsure whether legislation is the Interstate Massage Compact (IMpact), we encourage you to contact us before introducing, supporting, or testifying on a bill.
Once the Compact Commission is operational the application procedure will be published. Until then, therapists can prepare by maintaining their home-state license in good standing, verifying or attaining 625 hours of education, and ensuring they have passed the national licensing exam.
Fees will be determined by each state and the Commission. They are expected to be comparable to current single-state renewal fees.
Yes. The 625-hour education requirement applies to individual therapists seeking a multistate license, not to state education requirements.
Applicants must:
The Commission will define “substantial equivalence” to ensure qualified long-practicing therapists can participate while maintaining safety standards.
You must reactivate your home state license first and reapply for multistate privileges as directed by Commission rules.
Like a driver’s license, the IMpact allows qualified massage therapists to practice in multiple member states with one multistate license — enhancing mobility and reducing administrative barriers.
The Interstate Massage Compact (IMpact™) is a specific piece of model legislation developed through the national interstate compact development process. The model language was created over nearly three years through a collaborative effort led by the Federation of State Massage Therapy Boards (FSMTB) in partnership with the Council of State Governments (CSG) and the U.S. Department of Defense. State licensing boards, legislators, subject matter experts, professional organizations, educators, employers, military representatives, and other stakeholders all contributed to its development before the model legislation was finalized and made available for state adoption.
Since that process concluded, some organizations have promoted different compact legislation while referring to it as the Interstate Massage Compact or an "updated" version of the compact.
Because the language is different from the model legislation enacted by the current IMpact member states, this has created understandable confusion for legislators, regulators, employers, educators, and massage therapists.
To ensure you are reviewing the Interstate Massage Compact (IMpact™), compare proposed legislation with the model legislation published on massagecompact.org. If you have questions about whether a bill reflects the Interstate Massage Compact, please contact us before introducing, supporting, or testifying on legislation.
The Entry-Level Analysis Project (ELAP) identified 625 hours as the minimum number of hours required for a basic massage therapy education. This standard reflects empirical data, national consensus, and public input.
No. Therapists meet their home state’s CE requirements but must follow each remote state’s laws and scope of practice.
Yes, if they meet licensure and regulatory requirements. Currently, California, Kansas, Minnesota, Vermont, and Wyoming are ineligible due to lack of state licensure.
FSMTB provides administrative and policy support to member boards through multiple programs (MBLEx, CE Registry, etc.). The IMpact complements these by enabling national license mobility while reinforcing FSMTB’s mission of supporting public protection.
All licensure and disciplinary information is encrypted, securely transmitted, and accessible only to authorized regulators.
Each member state continues to investigate and discipline under its laws. The Commission ensures that disciplinary information is shared quickly among member states.
Disciplinary actions are shared instantly through the IMpact data system. Other states can take reciprocal or protective actions as needed.
States can appeal or challenge rules through established procedures and retain the right to withdraw from the Compact if necessary.
To promote public protection, regulatory collaboration, and workforce mobility, ensuring qualified professionals can practice across state lines while maintaining professional standards.
Regulators remain responsible for licensing, enforcement, and discipline within their state. They also serve on the Commission to guide policy and rulemaking.
Once seven states enact the Compact, the Commission will form, adopt rules, and build the data system. Multistate licenses are expected 12–18 months after Commission formation.
Interstate compacts derive their effectiveness from participating states enacting substantially the same statutory language.
Material differences may prevent states from participating within the same compact framework and can delay implementation of interstate licensure.
