The Access and Service Delivery (ASD) Committee’s Licensure Workgroup is pleased to announce a new Frequently Asked Questions resource on the NSGC website regarding state licensure and the practice of genetic counseling.
Navigating individual state licensure laws can be complex, and this is only compounded by increased use of telemedicine and many genetic counselors juggling multiple licenses. The ASD Licensure Workgroup hopes that this guide can be helpful in thinking through the ways that licensure works in your clinical practice.
Question: How do I determine if licensure is needed? Is it based on the patient’s location/address or the genetic counselor’s location/address? What about the location of the institution where I practice?
Answer: A genetic counselor must be licensed (if available) where the patient is physically located at the time of the consultation. A genetic counselor should also be licensed where they are physically located at the time of the consultation. Physical location may be different than permanent address. This applies for regular practice (e.g. when a GC lives in a different state than their place of work) as well as one-off visits (e.g. vacations).
For example: If a GC is employed and physically in Georgia and providing genetic counseling to a patient who lives in Georgia, but vacationing in Florida at the time of the visit, the GC must have licensure in Georgia (physical location of the patient) and should also have Florida licensure (physical location of the GC).
Importantly, billing does not factor into this in most cases. Licensure is required based on the practice of genetic counseling regardless of whether these services are being billed.
If you are not practicing genetic counseling with a patient (i.e. consulting/answering questions for a local physician), licensure is not required.
If a state does not have licensure the GC can provide services in that state or to a patient in that state without a license. However, if a GC is providing services via telehealth from a state with licensure, it is strongly recommended that the GC be licensed in the state from which they are providing counseling.
Question: Are there exemptions to licensure laws, such as government employees or students?
Answer: Many licensure laws do have exemptions for individuals who are employed by the United States government or students. Please reference the state law where the genetic counselor intends to practice - some key phrases to look for in the law are “this section does not apply to” or “exempt.”
Question: How does licensure affect new graduates of a genetic counseling program and their ability to practice?
Answer: Each state has unique trainee or temporary license processes. Please reference the state law where the new graduate intends to practice. Some key phrases to look for in the law are “temporary or provisional licensure” or “supervision/supervise”.
Question: Do licensing compacts and/or reciprocity exist? In other words, if I am licensed and practice in one state, does my licensure carry over to other states?
Answer: There are currently no states that offer true reciprocity at this time.
Licensure compacts and reciprocity will be a lengthy process, as it requires amendments to each state’s existing GC bill (which requires a legislative effort). However, this is an ongoing area of work for the Access and Service Delivery (ASD) Committee and the membership will be updated on progress. The ASD Committee has/is actively applying for grants for this process and is committed to continuing to work on this process which will likely take at minimum many years.
Question: How do I approach applying for licensure in multiple states?
Answer: Resources have been developed by NSGC to support GCs who are applying for individual state licenses in multiple states. These resources and more information can be found on NSGC’s state licensure webpage.
Question: Which states allow genetic counselors to order testing?
Answer: There are states that explicitly allow genetic counselors to order tests:
- Louisiana - with a physician collaborative agreement
- Ohio - with a physician collaborative agreement
- South Dakota
- Washington - with a physician collaborative agreement
Pennsylvania is the only state with licensure where genetic counselors are explicitly prohibited from independently ordering tests.
Question: What does a GC clinic look like in states where licensure is present?
Answer: GCs in states with licensure may independently see patients.
Disclaimer: This document is not legal advice. These answers are for guidance purposes only, and each state’s laws are nuanced. For detailed answers, the Access and Service Delivery Committee and NSGC recommend that you contact the state licensing board for the state you wish to practice within.
Most healthcare institutions have a compliance committee that makes billing and reimbursement decisions. You should work with your institution’s compliance team to identify standard protocol for your organization.
If you have remaining questions not addressed on this list, please contact Jennifer Trotter, NSGC Government Relations and Advocacy Manager, at firstname.lastname@example.org.