FSMTB Response to CSG’s Statement Regarding the Interstate Massage Compact

Dear FSMTB Members and Associate Members –

You may have received from Council of State Governments (CSG), communications to state massage boards — circumventing FSMTB — that are also reaching the broader massage profession. This contains a number of demonstrably inaccurate statements and mischaracterization of facts. In a dizzying betrayal of shared purpose, CSG has been part of an active campaign to override the original, enacted Interstate Massage Compact (IMpact^TM), and advance an alternate version of a massage therapy compact. This alternate version is being presented as though it is the IMpact™ approved through a thorough and credible vetting process. While the edits are presented as minor “technical changes,” these are nothing of the sort. They materially alter legislative intent, weaken regulatory safeguards, and significantly increase the risk of licensure fraud and human trafficking.

While CSG disseminates information with flagrant disregard for the truth, the real tragedy is not just their abandonment of shared commitments to regulatory improvement, but the erosion of trust and suspicion introduced into the profession. This has normalized ignorance and revealed their indifference to the serious challenges faced by regulators in combatting licensure fraud and sex trafficking.

FSMTB POSITION

Licensure compacts are a state-based regulatory mechanism and should be stewarded by the state regulators, who are charged with protecting public health, safety, and welfare. The FSMTB unequivocally rejects the proposed amendments and, as permitted, we implore our members to do the same in your jurisdiction.

BACKGROUND

As you are aware, FSMTB successfully applied for a Department of Defense grant to support the development of the IMpact^TM. CSG administered the funds and facilitated the IMpact^TM development meetings. The development process followed established interstate compact best practices, including those outlined by CSG, that included a three-month public comment period, where all stakeholder groups’ (including regulators, professional associations, educators, employers, and of course, massage therapists) interests were represented. The goal was for the language to be evergreen, looking toward the future evolution of the industry. The IMpact Advisory Group carefully and thoughtfully adjudicated the ethical and practical implications of groups that may be advantaged or disadvantaged, all while keeping public protection paramount.

Unlike other professions undertaking compacts, massage therapy had to grapple with the complexities introduced by the illicit massage industry. Nevertheless, a perfectly balanced and feasible way was crafted that simultaneously advances professional mobility while restricting the organized crime enterprises that regulators unfortunately encounter. That was intentionally accomplished by allowing state licensing boards (via the Commission) to address bad actors through authority established in Rule, rather than forcing acceptance of all applicants, no matter their legitimacy, though inflexible Statute. YOU understand the difference and consequences between Statute and Rule —those promoting the amended language and presenting it as if it’s the original compact, clearly do not.

WHY THE UNSANCTIONED COMPACT IS A PROBLEM

So many reasons! Here’s one — with estimates exceeding 18,000 illicit massage businesses (The Network identified over 20,000 in 2025) operating across the United States, the alternative compact language being promoted by CSG and the American Massage Therapy Association (AMTA) would likely allow tens of thousands of unqualified individuals and trafficked victims (many of whom obtained their license via fraud and diploma mills) to become eligible for multistate licensure. This implicitly sanctions the indentured servitude of these trafficked persons and bolsters the criminals’ business model. Statute would dictate that they are eligible, despite the fabricated education histories and work experience that legitimize their illegal operations. These risks were a central reason such pathways were explicitly rejected during the original Compact development process. Again, we have a solution that does not undermine enforcement efforts and put the public at risk.

A FAR SUPERIOR SOLUTION

This outcome of increasing the risk of human trafficking and licensure fraud, legislative confusion, restricting professional mobility, creating two competing compacts for one profession, is completely avoidable. The original IMpact^TM is only two states away from forming the Compact Commission, where your regulatory peers on the Commission will formalize the Commission and undertake Rulemaking. The most appropriate and logical path would have been to allow the 2025 legislative session to conclude and then address any remaining concerns through the Commission’s rulemaking process, as previously agreed. In fact, FSMTB and AMTA issued a joint letter in Fall 2024 acknowledging that AMTA’s concerns would be addressed through Commission rules and bylaws — not statutory reopening. Had those concerns not been resolved through rulemaking, AMTA retained the option to pursue legislative changes at that time.

HOW DID WE GET HERE?

The amendments were not requested by the profession or by state regulators. Rather, they emerged from pressure to accelerate adoption based on the unfounded belief that legislative changes could be advanced more rapidly through AMTA’s contract lobbying efforts. These revisions were drafted by CSG staff without communication with or input from FSMTB, despite FSMTB’s clearly stated objections to reopening the Compact and no responses by either CSG or AMTA to FSMTB’s repeated efforts to collaborate to resolve the concerns.  

Notably, AMTA national is the only entity questioning the original IMpact^TM language after stakeholder consensus was reached. Other major professional and industry stakeholders — including Associated Bodywork & Massage Professionals (ABMP), International Spa Association (ISPA), Massage Magazine, Massage Magazine Insurance Plus, and many additional industry leaders — support the original, regulator-led IMpact framework. These entities understand that maintaining the integrity of the licensure process and mitigating human trafficking also bolsters the credibility of the profession.

WHAT ABOUT THE LICENSEES?

It is also important to share how the profession itself has responded. Over a year ago, FSMTB began conducting a national IMpact survey, thus far completed by 1,715 massage therapists and industry professionals. Results consistently show:

• 98% of respondents support the original IMpact
• 47% of respondents were AMTA members and 49% were ABMP members
• AMTA members supported the IMpact at 97%
• ABMP members supported the IMpact at 98%

These data demonstrate that support for the original IMpact^TM language is broad, bipartisan within the profession, and strongly shared by your licensees.

The FSMTB will continue to advocate for the interests of the regulatory community along with the broad coalition of stakeholders who support the fully-vetted IMpact^TM that has thus far been adopted by five states. Empowering our Members with facts and context is essential to ending a process that is introducing unnecessary and harmful revisions outside of the agreed regulatory pathway. 

Please contact Patty Glenn, FSMTB Director of Professional Mobility, at pglenn@fsmtb.org or Mai Lin Petrine, FSMTB Director of Legal and Regulatory Affairs, at mlpetrine@fsmtb.org  with questions or for additional information.

Elisabeth (Liz) Barnard, LMT

FSMTB President

Executive Director, Nevada State Board of Massage Therapy