The Designation Is Not the Destination

What exactly do we mean when we call ourselves “healthcare providers”?

We’ve been saying it a lot. It appears in association newsletters, school marketing, and Instagram bios of practitioners licensed six months ago. “Massage therapy: evidence-based healthcare.” “Integrative Health Practitioner.”

It feels good to say these things. It felt especially good after COVID lockdowns, when many of us watched our practices evaporate while those deemed “essential” kept working. The designation mattered then and it matters now.

But “Healthcare provider” does not mean the same thing everywhere. Depending on the state, it might mean defined scope and enforceable accountability. It could relate to insurance participation. Maybe it means elevated liability standards.

Worst case, it might mean mostly vibes.

These variations aren’t trivial. Once the label of “healthcare provider” or “healthcare service” enters statute, it stops being branding and starts carrying weight. Or at least, it should. Across the United States, that weight is distributed unevenly.

• Scope: scope of practice defines the specific procedures, actions, and processes that a licensed healthcare professional is legally permitted to perform based on their education, training, and experience. It establishes boundaries to ensure patient safety and competence, and is primarily governed by state-level regulations and licensing boards.

• Statute/statutory: a written law passed by a legislative body or a rule established by an organization or institution

• Regulatory framework: a structured system of laws, regulations, guidelines, and standards established by government agencies or authoritative bodies to govern specific industries or activities. It defines the legal boundaries, compliance requirements, and operational protocols designed to ensure public safety, fair practices, and accountability.

• Practice Act: a healthcare practice act is a state-level legislative law that defines, regulates, and governs the legal scope of practice, licensure requirements, and ethical standards for healthcare professionals. Its primary purpose is to protect public health by ensuring safe, competent care.

• License: official, legally mandated authorization granted by a government agency (state or federal) that permits an individual to work in a specific, regulated profession.

• Regulation: a rule made and maintained by an authority, typically a governmental agency, to control or govern conduct within its jurisdiction.

• Voluntary Certification: a non-mandatory, third-party verification process where products, services, or systems are assessed against specific quality, safety, or sustainability standards.

For more foundational information on massage therapy licensing and regulation, check out our post:

An uncomfortable truth about massage therapy regulation in the United States is that a lot of it happened by circumstance rather than design. This is not unique to massage therapy, but that doesn’t make it a good idea.

When states began licensing massage therapists in earnest through the 1990s and 2000s, they didn’t always begin with a coherent philosophy about what massage therapy was or where it belonged. They wanted to stop things from happening, not make things happen.

They reacted to external forces and started wherever was administratively convenient. Which state board had capacity? Which statute could be amended? Who showed up to the meeting? (Most of the time it wasn’t your average massage therapist.)

In Virginia, for example, massage therapy ended up regulated by the Board of Nursing. This was not the logical result of deliberate planning, but simply where jurisdiction landed. And as a massage therapist who practiced for many years in Virginia, I can tell you it most definitely did not confer any kind of special nursing-adjacent respect or integration. If it had, Healwell may have never been born.

Across the country, massage regulation looks less like a planned city and more like a town that grew without a zoning board. We have a licensing requirement here, a scope clarification there, a healthcare designation tucked into a budget bill. Everything is written by people who are not massage therapists.

The result is a patchwork so varied that a therapist moving from one state to another may find their credential carries entirely different legal weight and creates a completely different relationship with the public and the law where they’re practicing.

The Federation of State Massage Therapy Boards (FSMTB) has attempted to bring coherence through its Model Practice Act. It is a thoughtful document articulating massage therapy as a healthcare profession with defined scope, documentation standards, continuing competence expectations, and disciplinary accountability.

Excuse me if I get a little misty. The document is not just a licensing template, it’s a vision.

Some people object saying regulatory agencies shouldn’t set vision. There’s also likely a healthy dose of the “we didn’t create it, so we don’t like it” ethos that is so common in our profession. I don’t know about you, but I don’t have time to reinvent wheels. Let’s not throw the baby out with the practice act. Regardless of where you land on the “who gets to set vision” debate, FSMTB’s Model Practice Act names the responsibilities inherent in claiming healthcare status. It’s actually our profession’s inability to coalesce previously that makes this template so visionary.

The gap we need to address is the difference between what the profession’s infrastructure assumes and what working practitioners understand about their obligations, not what’s in the document. And it’s about if and how practitioners are prepared to meet those obligations.

To explore that gap, let’s take a little field trip to four states that arrived at the “healthcare provider” designation by four very different roads.

Washington State offers one of the clearest examples of healthcare designation functioning as intended. When a massage therapist in Washington calls themselves a healthcare provider, there is a regulatory framework behind that claim that holds up in a stiff wind.

In Washington, massage therapy is regulated under the Department of Health, along with behavioral health counselors and therapists, medical doctors, nurses, chiropractors, dentists, and pharmacists. Licensing requirements are comparatively rigorous. Statutory language clearly connects designation to scope and accountability.

Is their requirement of 500 hours of education sufficient for clinical accountability? Reasonable people can debate that. (You might enjoy our recent piece that invites us to question our attachment to hours of education as a proxy for preparedness.) But the intent is clear, and the structure supports it. The expectation is that practitioners understand they are operating within a healthcare framework with real, clarified responsibility attached.

Let’s be careful though. Washington isn’t a good example because it touches the ceiling; it’s good because it lays the floor.

You don’t arrive at healthcare integration by passing a bill. (Sorry, friends.) You arrive there by building documentation culture, interprofessional fluency, and enforceable standards over time.

West Virginia names massage therapy as a healthcare service in statute but they’re still building the enforcement and integration infrastructure that would provide practical force. Like so many statutes, it’s aspirational, but that also makes it easy to let it lie. We can dust off our hands, spit, and say, “Got ‘er done.”

It’s a good start but scope questions remain contested. West Virginia’s education standards are reasonable but still leave space between classroom preparation and clinical integration. West Virginia shows us that defining ourselves and our work as healthcare is a process.

Regulation is not a proclamation. It’s construction.

Texas took a different route. (Yes, I’m gonna mess with Texas a little.)

Massage therapy is heavily licensed in Texas, with more than 27,000 practitioners in the state. The regulatory structure is primarily aimed toward public safety and licensing accountability.

This is foundational, common, and, in the scheme of healthcare integration and respect, a low bar. That’s not Texas’ fault. Regulation exists first to protect the public and if regulators are leading the charge, that’s where the charge will land us.

If the goal is clear scope, minimum competency, and enforceable discipline, Texas delivers. If the goal is deeper integration into collaborative healthcare systems, not so much.

Both goals are legitimate, but they prioritize different outcomes, leading us back to the question about what we want to be.

California has more massage therapists than any other state, with estimates exceeding 50,000 practitioners. It also operates under one of the most structurally complex regulatory arrangements in the country.

I mean, listen, California’s always been a little wacky. It’s a point of pride. Good on ya, California.

In California, massage therapy is uniquely governed by a private nonprofit entity, not state licensure. Practitioners may obtain voluntary certification through the California Massage Therapy Council (CAMTC) which was created by legal statute. CAMTC works next to the government, but is not part of it. Not all jurisdictions in California require CAMTC certification, and some who do mandate it choose to impose additional requirements for those who do not pursue CAMTC certification.

Voluntary certification is not a state license.

CAMTC successfully advocated for formal healthcare provider recognition in the most recent legislative session. The effort reflected a clear desire for professional legitimacy and possibly it presented an opportunity to CAMTC to have something to show its members. The advocacy was real, but what remains less clear is whether the surrounding infrastructure supports the weight of the designation. At this point, it’s mostly vibes.

A voluntary certification model does not function the same way as a licensing board embedded within a Department of Health. Oversight authority, enforcement mechanisms and integration pathways differ. Motivations differ.

The issue for California is a lack of structural alignment. When a healthcare designation rests on a framework that does not uniformly mandate licensure, does not fully centralize disciplinary authority within a health-oriented state agency, and does not clearly integrate with healthcare regulatory systems, that designation functions more as recognition of professional status than as a comprehensive infrastructure shift that confers respect, parity, and meaningful accountability.

In a state of this size and influence, structure matters.

Across these four states, the designation of “healthcare provider” is doing different things. These functions are not automatically bundled together– in fact, they are often a la carte. A state can activate one or two without the others. But if we want the designation to matter and lift us to the place we imagine it can, we need to be willing and able to integrate all functions.

• What it does: Defines scope, enforces discipline, protects consumers

• What makes it work: Clear statutory scope, enforceable standards, oversight authority

• What it does: Allows insurance participation and integrated care collaboration

• What makes it work: Recognized credentials, documentation standards, overall system integration

• What it does: Raises expectations for clinical reasoning and professional negligence accountability

• What makes it work: Defined standard of care, aligned education, legal clarity

• What it does: Signals where the profession believes it belongs

• What makes it work: Successful advocacy — but not necessarily structural change

The regulatory landscape is shaped continuously through legislation, rulemaking, and interpretation. Those processes are often long and complicated, but they’re also public which means you can be a part of them. Historically, many regulatory decisions have been shaped by administrators, lobbyists, and a small number of engaged stakeholders (like franchises or other businesses). This happens not because practitioners were excluded, but because most were busy practicing.

That’s understandable but it has heavy consequences.

If a healthcare designation is going to carry substance rather than symbolism, participation in building the structure becomes part of professional responsibility. I know that’s hard. I know we’re all busy, but abdicating this responsibility guarantees we’re increasingly working in a reality created by someone else who doesn’t understand what we do.

Schools that teach foundational education did not create this regulatory variation, but those schools are where human preparation first meets legal expectations. When a state designates massage therapists as healthcare providers or calls what they do a healthcare service, that creates expectations and responsibilities about documentation, scope clarity, ethical reasoning, and standard of care. Those expectations should be shaping curriculum.

Educational programs are where future practitioners either become fluent in those expectations or remain unaware of them. This is not criticism. It’s reality. When legal identity shifts, the curriculum must respond.

Program directors operate under real constraints, but that doesn’t change this dynamic. If students are graduating into a healthcare-designated state, they deserve preparation for what that means:

• An open-eyed understanding of the difference between licensing minimums and a standard of competency

• Scope clarity

• A working understanding of liability implications

• Knowledge of responsibility, ethics, and functioning in a culture that relies on documentation.

• Familiarity with guiding frameworks like the FSMTB Model Practice Act

This is not about turning massage programs into nursing programs. It is about alignment with a future we continually say is one of healthcare. When statutory language evolves but education does not, that lands on new graduates and the cost of their lack of preparation lands on all of us.

That is a structural gap we have the capacity to address.

An effort for immediate national uniformity would be the worst case of carts and horses confused about their positions. We can’t fix this tomorrow, but we can fix it.

When we recognize the cost of this chaos we can begin to move toward coherence. It’s like we’re Cameron from Ferris Bueller’s Day Off. We’ve been paralyzed by anxiety while chaos swirls around us. It’s time to kick the Ferrari through the window and snap out of this spell of indecision and inertia.

The designation is not the destination. Showing up as healthcare providers is a structural, incremental, and intentional process in which we must engage.

If we claim healthcare status, we have to be willing to create and adhere to healthcare structure in education, documentation, and accountability.

When we define and reinforce that kind of structure, it strengthens the profession. When we emphasize recognition without reinforcing structure, the designation is fragile.

The table exists. The question is not whether we are invited to sit at it. The question is whether we are prepared to support the responsibility that comes with tucking in.