The Hidden Bombshell in CSG's Revised Compact
- Kirby Clark, MMT
- 3 days ago
- 6 min read
There’s been a lot of chatter lately about changes to the Interstate Massage Compact. Some say the changes are “minor”, "more inclusive", or frame them as "helpful tweaks". But one detail in the revised language is not minor — it’s structural, and it risks excluding experienced, licensed therapists who were previously intended to be covered by the original compact’s flexibility.
The revised compact excludes every therapist who qualified for licensure under NCBTMB’s historic national exams — because those exams are not named anywhere in the statute.
As states prepare for the 2026 legislative cycle, many massage therapists are only now learning that the Council of State Governments (CSG) recently released a revised compact.
Few therapists have been closely following the progress and development of the compact, and even fewer have taken the time to do their own investigation to inform their opinion about it; including failing to review the proposed changes put forth by CSG and supported by AMTA.
And the most ironic twist in this story is: the only exam explicitly listed in the revised language is the MBLEx.
Meaning: only MBLEx test-takers are automatically eligible for the multistate license. Everyone who entered the profession through NCBTMB’s historic national certification exams are now excluded.
This was not the intent of the original IMpact. And it is a direct consequence of how the revised language is written. This isn't interpretation and confirmation bias, it's the letter of the law.
Original IMpact language: Article 3, Paragraph A, Section 3. "Accept passage of a National Licensing Examination as a criterion for Massage Therapy licensure in that State;"
Revised compact language: Article 3, Paragraph A, Section 3 has been stricken and a new Section 4 has been added with three Subsections. "Accept passage of a psychometrically valid national examination as a criterion for Massage Therapy licensure in that State; For purposes of this compact, such examination shall not include a State-administered examination but shall be inclusive of the following:
a. The Massage and Bodywork Licensure Examination; or
b. The National Certification Board for Therapeutic Massage & Bodywork prior to January 1, 2015; or
c. the substantial equivalent of the foregoing which the Commission may approve by Rule."
And this is repeated again in Article 4, Paragraph A, Section 4, Subsections a-c.
Notice how MBLEx is expressly named in subsection a, but subsection b names an organization (NCBTMB) and none of the three NCBTMB exams once used for licensure?
To be clear:This is not an argument about which exam is “better.”
This is about inclusion, political infighting, and the integrity of the compact.
And it raises crucial questions:
Why is CSG replacing a flexible, evergreen compact (the original IMpact) with a revised version that dramatically narrows eligibility? And why was AMTA so fast to support the revision? And how did they miss such a critical drafting error?
Historical Context
From the 1990s to 2015, NCBTMB operated the only nationally recognized examination in massage therapy. Across those decades, NCBTMB administered three different exams that states recognized for licensure:
The National Certification Exam in Therapeutic Massage (NCETM)
The National Certification Exam in Therapeutic Massage & Bodywork (NCETMB)
The National Exam for State Licensing (NESL) (discontinued when NCBTMB began issuing Board Certification)
Tens of thousands of licensed massage therapists entered the profession through one of those exams. These were the national standards of the time before the MBLEx was developed.
Yet the revised compact language does not name either of those exams. Not one.
Instead, the statute names only these two things:
NCBTMB (the organization) — but not its exams
The MBLEx (the exam) — but not its organization
This is the exact opposite of good regulatory language.
The result?
The only pathway explicitly recognized in the revised compact is passing the MBLEx.
The Big Misunderstanding
For years, AMTA publicly argued that the original IMpact model language was “too rigid” because it used terms like:
“national licensing examination,” and
“substantial equivalent, as determined by the Compact Commission.”
But this was not rigidity — it was intentional durability. This ensured fairness for practitioners who entered the profession under different exam eras. It also protected states by allowing the Commission to define equivalency standards based on psychometrics, not politics.
But the revised compact — rushed forward after pressure to “simplify” requirements — replaces that flexibility with rigid naming.
And here’s where the political layer shows:
AMTA has historically opposed explicit statutory recognition of the MBLEx.
Yet AMTA quickly endorsed the revised language — a version that, ironically, elevates the MBLEx as the only exam explicitly recognized.
The revised document is small. The ramifications of naming an organization instead of its exams should have been obvious.
This creates the appearance that AMTA was more eager to endorse anything that undermined or superseded the original IMpact than they were committed to protecting the exam-based eligibility rights of longtime practitioners.
The original IMpact:
Allowed multiple exam pathways
Protected legacy practitioners
Let the compact commission define equivalency using clear rules and objective criteria
Avoided naming specific organizations or exams in statute — a best practice in regulatory drafting
Ensured states did not lock themselves into one historical moment or one exam vendor
This is why we call IMpact an evergreen statute; it grows with the profession. It evolves through rulemaking. It stays neutral and fair.
The original IMpact already solved the exam-era problem by design.
The Revised Compact Removes Flexibility & Introduces Exclusion
When AMTA pushed against IMpact — claiming it was too rigid — the result has produced a document that is far more rigid and far less inclusive than the original.
The revised language:
Names NCBTMB (the organization)
Fails to name any of NCBTMB’s three legacy exams
Leaves all historic exam pathways unrecognized
And explicitly names only one exam: the MBLEx
This is the exact opposite of what AMTA says it wanted.
By removing “substantial equivalence” and inserting named entities, the revised compact:
hard-codes exclusion into statute,
ties the compact’s future to specific organizations,
and invalidates decades of legitimate licensure pathways simply because AMTA insists entities be expressly named.
This is not inclusive.
It’s not evergreen.
And it’s certainly not unity.
Why This Must Be Stopped Before Any State Introduces It
Introducing the revised compact in 2026 would create:
Eligibility confusion across states
Barriers for thousands of practitioners
Unnecessary conflict between exam eras
Permanent rigidity in statute (instead of fixable rulemaking)
A compact that is less adoptable and less fair than the original IMpact
The original compact was intentionally drafted to avoid all of these problems.
The revised compact reintroduces them all.
True Inclusion
Let's be very clear: the only truly inclusive compact is the original IMpact.
The original IMpact:
Protects every therapist from every exam era
Respects state authority
Preserves the Commission’s power to define fair eligibility
Keeps exam politics out of statute
Ensures future-proof policy
Reflects best practices used in every other professional interstate compact
Focuses on public protection — not organization naming-dropping
How We Move Forward
1. CSG must rescind or table the revised compact language.
At minimum, it must not be introduced in any state legislature for 2026 to allow time for the proposed revisions to be vetted by the profession and stakeholders.
2. States should continue adopting or drafting the original IMpact language.
It is the only version that maintains fairness across exam eras. It has had a successful enactment rate since model legislation was finalized in 2023; five states have joined IMpact, three have carry-over legislation pending for 2026, and nine other states are currently drafting legislation to introduce in the new year.
3. AMTA must reconsider its endorsement.
The revised language contradicts AMTA’s stated concerns and creates new inequities.
4. The profession must stand united around a single message:
If we want a compact that truly serves the massage profession, we must support the original IMpact — the only model designed to include everyone.
Support IMpact
This moment is not about exam politics.
Or grand-parenting clauses and cut-off dates.
It’s not about choosing sides.
It’s not even about re-litigating the 1990s, 2000s, or 2010s.
We already have an inclusive, durable, and fair compact.
It has been threatened by a more rigid one that excludes thousands of legitimate practitioners.
And now we need to course-correct — before it becomes law.
The profession deserves better than a rushed revision.
We deserve a compact built for everyone.
And that compact is still — unequivocally — the original IMpact.
Accompanying Vlog: https://youtube.com/shorts/UVwVVc4Dg1k?si=UgAShVmQ1TNlJybg
Peace and Healing,
Kirby Clark Ellis, MTI, BCTMB
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