A new Michigan law will require occupational therapists and assistants who serve patients across state lines to pay a fee for each remote state where they practice—effective January 2028.
Most Michigan health services owners don't realize that a provision buried deep in HB4103 will create a new, recurring cost for any business employing or contracting occupational therapists or OT assistants who practice across state lines. Starting January 22, 2028, this requirement will affect how you budget for multi-state operations.
HB4103 enacts Michigan's participation in the Occupational Therapy Licensure Compact—an interstate agreement designed to streamline OT licensing across member states. But embedded in Section 3C (Page 6) of the bill is a specific requirement: each occupational therapist or OT assistant who provides services in a "Remote State" (any state other than their home state) must pay a Compact Privilege fee for the right to practice there.
This is not a one-time licensing fee. It is a per-state, recurring fee that applies whenever your practitioner delivers services across state lines. If you employ an OT who treats patients in Ohio, Indiana, and Illinois, that practitioner must pay the Compact Privilege fee to each of those three states.
This requirement directly impacts:
If your occupational therapy staff work entirely within Michigan, this provision does not apply.
The immediate impact is straightforward: increased labor and compliance costs. Your organization will need to:
The law does not specify the fee amount—that detail will be determined by the Compact itself—but the administrative burden is certain. For businesses with significant multi-state operations, this creates a new line item in operational costs and compliance overhead.
The provision becomes effective on January 22, 2028—18 months after the bill's enactment on July 21, 2026. However, the requirement is contingent on House Bill No. 4104 also being enacted. HB4104 contains complementary provisions necessary for the Compact to function. If HB4104 does not pass, the Compact Privilege fee requirement in HB4103 will not take effect.
This means you have time to plan, but you should monitor the status of both bills and begin thinking now about how multi-state operations will be affected.
For a detailed, business-specific breakdown of how this applies to your service model, resources are available through Michigan health services trade associations.