On July 31, 2026, the Massachusetts Board of Registration of Allied Mental Health and Human Services Professions issued revised licensing regulations affecting Licensed Mental Health Counselors (LMHCs) and establishing the new Licensed Supervised Mental Health Counselor (LSMHC) license category.
The revisions address education, supervised clinical experience, teletherapy, the LSMHC pathway, and the transition from LSMHC to LMHC licensure.
MaMHCA has prepared the following FAQ to help counselors, students, graduate programs, supervisors, employers, and other stakeholders understand the current framework.
A Note About the LSMHC
The LSMHC should not simply be described as an "optional license."
Massachusetts law protects the title "licensed supervised mental health counselor," and the Board's revised regulations establish the LSMHC as a formal license category.
At the same time, Massachusetts law does not generally prohibit a person from providing counseling services simply because that person does not hold an LSMHC, provided the person is not unlawfully holding themselves out as a licensed allied mental health professional and otherwise falls within an applicable legal authorization or exemption.
The practical question for an individual counselor is therefore not simply whether the LSMHC exists, but whether the individual's education, employment, supervised experience, and intended professional title require or make use of the LSMHC pathway.
The Massachusetts General Laws specifically prohibit an unlicensed person from advertising or using the title "licensed supervised mental health counselor," while §165 authorizes the Board to issue a supervised mental health counselor license. The Board's July 31, 2026 announcement identifies the LSMHC as a new license category.
Frequently Asked Questions
1. What is the LSMHC?
The Licensed Supervised Mental Health Counselor (LSMHC) is a new Massachusetts license category established by the revised regulations effective July 31, 2026.
The LSMHC is designed to recognize counselors who have completed the applicable graduate education requirements and are completing the supervised post-master's clinical experience required on the pathway toward LMHC licensure.
In practical terms: The LSMHC is the formal Massachusetts license category associated with the supervised post-master's stage of the LMHC pathway.
2. Is the LSMHC mandatory for everyone who practices counseling?
No. The LSMHC should not be understood as a universal requirement for every person who provides counseling services.
Massachusetts law protects the title "licensed supervised mental health counselor." A person who is not licensed or otherwise exempt may not advertise or use that protected title.
Massachusetts law also recognizes circumstances in which individuals may provide counseling or related services without holding an allied mental health license, provided they do not hold themselves out as a licensed allied mental health professional and otherwise comply with applicable law.
Important distinction: Whether an individual needs or should obtain an LSMHC depends on the person's licensing status, educational pathway, supervised experience, employment setting, and the title under which the person is practicing.
3. What examination is required for the LSMHC?
The current Massachusetts LSMHC application requires evidence that the applicant has passed the National Clinical Mental Health Counseling Examination (NCMHCE) administered by the National Board for Certified Counselors (NBCC).
The current application guide requires a passing NCMHCE score. The Board's application guide states that applicants should submit their unofficial score report and that the Board will receive the official score report directly from NBCC.
The current application guide also states that examination scores expire after five years.
4. Is the NCMHCE required more than once?
The current LSMHC application materials require a passing NCMHCE score. They do not identify a requirement that an applicant pass the NCMHCE twice solely because the applicant is pursuing the LSMHC.
Current application guidance: Applicants submit evidence of a passing NCMHCE score. The Board states that examination scores expire after five years.
5. What is a "Relevant Field"?
The revised regulations define "Relevant Field" as:
"Counseling, counselor education, expressive therapies, adjustment counseling, rehabilitation counseling, counseling psychology, clinical psychology, or another Mental Health Counseling field determined by the Board to be a Relevant Field."
This definition is important because the revised education requirements allow several qualifying degree pathways to be based on a master's or doctoral degree in Mental Health Counseling or a Relevant Field.
The Board retains authority to determine whether another Mental Health Counseling field qualifies as a Relevant Field.
If your degree is in a field not specifically identified in the definition: Do not assume that it qualifies. Individual applicants should seek clarification from the Board when the status of a degree or program cannot be determined from the current regulations and application materials.
6. Are 60 graduate credits still required for LMHC licensure?
Yes.
The revised 262 CMR 2.05 requires a minimum of 60 semester credit hours or 80 quarter credit hours of qualifying graduate education.
The revised regulation provides multiple educational pathways for meeting this requirement.
7. Does all 60-credit education have to come from one master's degree?
No.
The revised regulation identifies several qualifying pathways, including:
- A master's degree in Mental Health Counseling or a Relevant Field containing at least 60 semester credits.
- A master's degree in Mental Health Counseling or a Relevant Field containing at least 48 semester credits, plus at least 12 semester credits of qualifying additional coursework.
- A master's degree in Mental Health Counseling or a Relevant Field accompanied by a Certificate of Advanced Graduate Studies (CAGS).
- Two master's degrees in Mental Health Counseling or a Relevant Field.
- A doctoral degree in Mental Health Counseling or a Relevant Field.
The important issue is not simply the number of credits. The required coursework and content areas must also be satisfied.
8. Can a CAGS be used to satisfy the educational requirement?
Yes.
The revised 262 CMR 2.05 expressly identifies a master's degree in Mental Health Counseling or a Relevant Field accompanied by a Certificate of Advanced Graduate Studies (CAGS) as one qualifying educational pathway.
Applicants whose degree programs are missing required credits or coursework may also be able to supplement their education with qualifying coursework, subject to the regulation's requirements.
9. What coursework is required?
The revised regulations require successful completion of graduate-level courses covering the specified content areas.
The ten required content areas are:
- Counseling Theory
- Human Growth and Development
- Psychopathology
- Social and Cultural Foundations
- Clinical Skills
- Group Work
- Special Treatment Issues
- Appraisal
- Research and Evaluation
- Professional Orientation
Important: Each course can be used to satisfy only one of the required content areas. Applicants should therefore review their transcripts carefully rather than relying solely on the total number of graduate credits.
10. When can post-master's supervised experience begin to count?
The revised framework makes clear that post-master's clinical field experience begins after the candidate has completed the required education under 262 CMR 2.05.
An applicant cannot count post-master's experience toward the LMHC requirement before satisfying the required educational requirements.
This is particularly important for students and post-master's counselors who are using additional coursework, a CAGS, or another educational pathway to reach the required 60 credits and content areas.
11. What does the new LSMHC mean for the pathway to LMHC?
The revised regulations establish a formal LSMHC license category during the supervised portion of the pathway toward LMHC licensure.
The Massachusetts Department of Public Health has specifically stated that the revised regulations streamline the LMHC application process for applicants who have been licensed as LSMHCs.
MaMHCA therefore recommends that counselors carefully determine which licensing pathway applies to their individual circumstances rather than relying on pre-July 31, 2026 information.
12. Can teletherapy count toward licensing experience?
Yes, subject to the applicable regulatory requirements.
The Massachusetts Board announced on July 31, 2026 that teletherapy is now permanently permitted for qualifying licensing experience hours.
Counselors and supervisors should still review the current requirements governing teletherapy, supervision, documentation, and the location of practice.
13. What should graduate programs and students do if they are unsure whether coursework qualifies?
Graduate programs and students should review the complete transcript against the current 262 CMR requirements.
MaMHCA recommends:
- Reviewing the current 262 CMR 2.05 education requirements.
- Identifying the course used to satisfy each required content area.
- Confirming that the required 60 semester credits have been completed.
- Confirming that all required content areas have been completed.
- Keeping official transcripts and course descriptions available.
- Obtaining clarification from the Board when the applicability of a particular degree, course, or educational pathway is unclear.
Do not rely solely on older graduate-school handbooks, application checklists, or licensing guides. The regulations changed effective July 31, 2026.
14. What about errors or typographical issues in the regulations?
Questions have been raised regarding typographical and drafting issues appearing in the revised regulatory materials.
MaMHCA has been advised that corrections are being worked on.
Until corrections are formally published: Applicants and programs should rely on the current official regulation, Board application materials, and subsequent official Board guidance rather than attempting to resolve regulatory inconsistencies through informal interpretations.
MaMHCA Will Continue to Monitor the Regulations
The July 31, 2026 regulatory changes represent a significant change to Massachusetts mental health counselor licensure.
MaMHCA will continue to monitor implementation of the revised regulations, communicate with the Board, and provide updates as additional guidance becomes available.
Counselors, students, graduate programs, supervisors, employers, and other stakeholders are encouraged to review the current requirements and avoid relying on licensing information that predates July 31, 2026.
