Telehealth supervision hours: what actually counts by state

Your state may not have an answer, and that's a different problem than a "no"

Ask around a supervision group and you'll hear confident answers on both sides: some supervisees swear video sessions are fine everywhere now, others insist their board still wants bodies in the same room. Both are sometimes right, because the actual answer depends entirely on which state's rule you're under, and several boards haven't weighed in either way.

That last category trips more people up than the outright bans do. A rule that's silent on video supervision isn't the same as a rule that permits it. Silence just means nobody has told you yes, which is a worse position to be in at a licensure review than a rule that spells out exactly what counts.

Here's what the current administrative code actually says in the ten states AuditHalo tracks, pulled directly from each state's rule file, not from general assumptions about how telehealth has evolved since 2020.

States that explicitly allow video supervision

Louisiana is the most permissive state in this set. Its rule allows up to 100% of face-to-face supervision hours to happen over synchronous videoconferencing on a HIPAA-compliant platform. There's no cap on how much of your supervision can be virtual. The same rule draws a hard line the other direction, though: supervision may not be conducted by mail, email, or telephone. Video is fully allowed. Phone is not allowed at all. Those are two different rules living in the same sentence of the code, and treating them as interchangeable is the kind of mistake that surfaces at application time. See the Louisiana PLPC rule page for the full requirement, or check the Louisiana LPC Board directly.

Delaware takes a different approach: rather than carving out an exception for video, its definition of "face-to-face" includes live video conferencing from the start. That definition applies to both direct client contact hours and supervision meetings, so a supervisee doing sessions by video in Delaware isn't using a special telehealth allowance at all. As far as the rule is concerned, it's just face-to-face supervision that happens to be conducted over a screen. Full detail on the Delaware LACMH rule page, and the source language sits with the Delaware Board of Mental Health and Chemical Dependency Professionals.

Washington states plainly that both immediate supervision and group supervision may be conducted face-to-face or virtually, with no location restriction in the rule text. There's no ratio or cap attached to the virtual option; it's simply listed as an equally valid format alongside in-person sessions. See the Washington LMHCA rule page for the surrounding requirements.

Ohio allows ongoing supervision to happen in person, by videoconference, or by phone, once an initial meeting has taken place (and that initial meeting itself may be conducted by videoconference). Ohio doesn't put a cap on how many of the ongoing sessions can be remote. Full requirement on the Ohio LPC rule page.

The state that allows it, but with a phone ceiling and an in-person floor

Arizona sits in the middle. Its rule allows up to 90 of the 100 required supervision hours to happen by videoconference or telephone combined, but no more than 15 of those 90 may be telephone specifically. On top of that, at least 2 hours of face-to-face supervision are required per 6-month period, and the rule states outright that fully remote supervision is not permitted. So a supervisee in Arizona can build a supervision plan that's mostly virtual, but not one that's entirely virtual, and the phone portion of that virtual time has its own separate ceiling within the larger video-or-phone allowance. Getting the math wrong here (assuming all 90 hours could be phone, for instance) is an easy way to end up short at review. Details on the Arizona LAC rule page, sourced from the Arizona Board of Behavioral Health Examiners.

A state where our data is genuinely unconfirmed

North Carolina's supervision rule, 21 NCAC 53 .0702, appears from secondary-source research to address multiple supervision modalities, possibly including synchronous video. AuditHalo has not been able to verify that against the primary regulation text: the pages we'd normally cite returned access errors when we tried to confirm the language directly. That note sits in our data flagged for licensed-supervisor review, not as a confirmed rule. If you're supervising in North Carolina and need to know whether a video session counts, don't take our word for it or anyone else's secondhand summary. Confirm directly with the NC Board of Licensed Clinical Mental Health Counselors before you build a supervision schedule around an assumption. See the North Carolina LCMHCA rule page for what we do have confirmed.

Silence is a real category, and it isn't permission

Four of the ten states AuditHalo tracks don't address supervision modality anywhere in the rule text we have on file: California, Florida, New York, and Texas. No mention of video, phone, remote, or face-to-face requirements tied to supervision sessions specifically.

That's worth sitting with for a second, because it's tempting to read "the rule doesn't say I can't" as "the rule says I can." Those are not the same statement. A board that hasn't addressed telehealth supervision in writing hasn't blessed it either. If you're practicing in one of these states and your entire supervision relationship is conducted over video, the safest move is asking your board in writing whether that arrangement satisfies the rule, and keeping that answer on file, rather than assuming a gap in the text works in your favor.

What this means for how you document a remote session

Whichever category your state falls into, the session type itself is a fact you should be recording, not reconstructing later. If your state caps a modality (Arizona's phone ceiling) or requires a minimum of a different one (Arizona's 2-hour face-to-face floor), the only way to prove you hit the requirement is a record that shows, session by session, which ones were in person, which were video, and which were phone. Trying to remember that breakdown across a 2-year supervision relationship at application time is close to impossible.

That record also has to be one the supervisor and supervisee agree on and can't quietly edit after the fact. A shared spreadsheet where either party can change a past entry doesn't hold up the same way a signed, timestamped record does.

How AuditHalo handles the modality question

AuditHalo logs the session type (in person, video, or phone) as a required field on every supervision session, alongside date, duration, and supervisor credentials, and locks the record with dual signatures once both parties confirm it. Where a state's rule imposes a modality cap, like Arizona's 15-hour phone limit or its 2-hour face-to-face floor, that field is what makes the cap something you can track against in real time instead of discovering a shortfall at licensure application. Where a state's rule stays silent on modality, the same record gives you a clean, verifiable account to hand a board if they ever ask.

For the fuller picture of how all your supervision hours get counted and verified, see Clinical supervision hours: the complete guide. If you're also trying to work out how often supervision needs to happen relative to your practice hours, The supervision-hour ratio, explained covers that separately.

Check your state's exact rule on the states page, or start tracking your supervision sessions, including modality, today.