A new Michigan law lets out-of-state occupational therapists practice here without a full license—but there's a yearly fee most owners haven't heard about yet.
Most Michigan health services owners don't realize that starting January 22, 2028, occupational therapists and occupational therapy assistants licensed in other states will have a faster, cheaper way to work in Michigan. But that convenience comes with a $75 annual fee—and understanding how it works matters for your hiring and contracting decisions.
Michigan is joining the Occupational Therapy Licensure Compact, a multi-state agreement that lets licensed OTs and OTAs from member states practice in Michigan without obtaining a separate Michigan license. Instead, they pay an annual "compact privilege" fee of $75 per year.
This applies whether the out-of-state practitioner works in person at your facility or provides services remotely via telehealth.
If your health services organization currently hires or contracts with occupational therapists or assistants from other states, this law changes how they gain Michigan practice authority. The compact privilege becomes an alternative to the traditional full Michigan licensure process.
This is especially relevant for:
The law takes effect 18 months after enactment (which occurred July 21, 2026). On that date, out-of-state OTs and OTAs licensed in compact member states can apply for Michigan practice authority through the compact privilege rather than pursuing full Michigan licensure.
The $75 annual fee is set by the law itself—it's not subject to future increases without legislative action. Practitioners renew this privilege yearly to maintain active practice authority in Michigan.
This provision in HB 4103 is tied to the enactment of HB 4104, which establishes the regulatory framework for the compact. Both bills had to pass for the compact privilege to take effect. Both were enacted.
If you're planning to hire or contract with out-of-state OTs, you'll want to understand the compact privilege process before January 2028. It may streamline your recruitment from compact member states, though you'll need to verify which states are compact members at the time you hire.
For practitioners already licensed in Michigan, nothing changes. The compact privilege is an option for out-of-state licensees only.
For compliance purposes, keep the effective date in mind: January 22, 2028. Until then, out-of-state OTs seeking Michigan practice authority must follow the traditional licensure path.
Legal basis: House Bill 4103, amending 1978 PA 368 (MCL 333.1101 - 333.25211) by adding sec. 16188, with regulatory details in proposed MCL 333.18303a and 333.18303b (per HB 4104). Effective January 22, 2028.