Board OKs permission to publish COMAR change allowing some interstate therapist licenses in schools

Professional Standards for Teacher Education Board · November 14, 2025
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Summary

The Professional Standards for Teacher Education Board voted to permit publication of COMAR 13.08.12.04.10, allowing certain therapists to work in Maryland schools if they hold a Maryland license or a compact/reciprocity-based privilege. The vote was unanimous with no abstentions recorded.

The Professional Standards for Teacher Education Board on Nov. 13 voted to grant permission to publish amendments to Code of Maryland Regulations (COMAR) 13.08.12.04.10, titled “other therapists,” to allow practice in Maryland schools by individuals who hold either a Maryland-issued license or a compact/reciprocity privilege recognized by the relevant Maryland licensing board.

Jason Keyes, director of educator preparation and development at the Maryland State Department of Education (MSDE), told the board the proposed change aligns COMAR with federal rules that permit states and licensing boards to recognize compact privileges and certain military licensures. “These amendments allow a therapist to practice if they hold a valid license issued by the Maryland licensing board or a valid compact privilege to practice in Maryland,” Keyes said.

Board members asked which professions currently have interstate compact privileges. Sean (staff) clarified that, as of the meeting, the physical therapy compact is effective in Maryland and provides a compact privilege; other professions discussed — including occupational therapy, audiology and speech‑language pathology — are at various stages of registration or implementation in different states. Dr. Nikki Woodward noted an emerging compact for SLPs and asked about safeguards for out‑of‑state or remote providers; Keyes replied that licensing boards retain their review authority and that the COMAR change defers due diligence to those boards.

Debbie Hartland moved to give permission to publish the COMAR amendments; Dr. Taylor seconded. The board signaled unanimous consent and the regulation will follow the standard sequence: board of education review, a 15‑day look, a 30‑day Maryland Register publication for public comment, and a return to the board for final action after public comment.

What the rule does and does not change

The amendment does not remove the requirement that practitioners meet licensing standards; it adds an alternative pathway for recognition when a licensing board grants compact or reciprocity privileges. Keyes emphasized the rule is intended to reduce service gaps in schools while preserving the licensing boards’ authority to verify equivalency and discipline.

Next steps

MSDE will publish the proposed COMAR language for public comment and bring any post‑comment revisions back to the board for further consideration before final adoption.