Endorsement, Apprentices and Colonic Irrigation

About 29 minutes · ss. 480.041(5) and (7), 456.0145, F.S.; Rules 64B7-25.001(2) and (4), 64B7-25.004 and 64B7-32.005, F.A.C.

7.1 Why there is more than one route

Chapter 5 described the standard route: graduate from a board-approved school, pass an approved exam, be screened, and be licensed. That route serves a new graduate. But the Legislature recognized that there are other people the State wants to license or certify without making them start over:

• therapists who already hold an active license in another state or territory, and want to move to Florida;
• practitioners licensed in a foreign country with similar standards;
• people who learned the profession through an apprenticeship that the State once permitted, and which has now ended; and
• licensed therapists who want to add a specialized service, colonic irrigation, which requires its own certification.

The statute provides for these in two subsections of s. 480.041. Subsection (5) directs the Board to adopt rules establishing apprenticeship training (historically), educational standards, examination and certification for colonic irrigation, and licensing procedures for endorsement. Subsection (7) deals with the end of the apprenticeship route. This chapter takes each in turn.

7.2 Choosing the right route: a decision guide

Because the Act provides more than one path, the first practical question for any applicant is which path fits her situation. Choosing correctly saves time and fees, and choosing wrongly can produce a denial that was avoidable. The table below summarizes the paths. It is a map for orientation, and the statutes, rules and forms control the details.

Notice that the paths are not interchangeable. A person who qualifies for endorsement does not need to repeat school, and a new graduate cannot use endorsement because she holds no license elsewhere. A person who holds a Florida massage license cannot practice colonic irrigation on the strength of that license alone.

A good habit is to begin with a short written statement of your situation: where you are licensed, for how long, whether you have any discipline or pending complaints, which examination you passed and when, and what you want to do in Florida. Then match the statement to the table. If it does not fit any row cleanly, ask the Board before you spend money, and ask in writing.

7.3 Licensure by endorsement: the MOBILE Act

The source of the law. Endorsement is governed by a Chapter 456 statute that applies to many health professions, s. 456.0145, titled the Mobile Opportunity by Interstate Licensure Endorsement Act, or MOBILE Act. Section 456.0145 was created by the 2024 Legislature (ch. 2024-274) and amended in 2025 (ch. 2025-6 and ch. 2025-114). The Board of Massage Therapy implements it through Rule 64B7-25.004. Section 480.041(5)(c) authorizes the Board to adopt rules for practitioners who "meet the requirements for licensure by endorsement under s. 456.0145."

Because it is a recent statute that has already been amended, endorsement is an area where you should always check the current text before you rely on any summary, including this one.

What an applicant must show. Under s. 456.0145(2)(a), the Board (or Department) "shall issue a license" to an applicant who meets all of the following:

1. Submits a complete application.
2. Holds an active, unencumbered license from another state, the District of Columbia, or a U.S. territory, in a profession with a similar scope of practice, as determined by the Board. ("Scope of practice" is defined as the full range of functions, procedures, actions and services a practitioner is deemed competent and authorized to perform under a license issued in Florida.)
3. Has a passing score on a national licensure examination, or holds a national certification recognized by the Board as applicable to the profession. (Subparagraph 3.b offers an alternative for professions that have no national exam; massage therapy has one, so the national exam path applies.)
4. Has actively practiced the profession for at least 2 years during the 4-year period immediately before the application.
5. Attests that he or she is not, when applying, the subject of a disciplinary proceeding in any jurisdiction where licensed, or by the U.S. Department of Defense, for reasons related to the practice.
6. Has not had disciplinary action taken against him or her in the 5 years before applying.
7. Meets any financial responsibility requirement applicable to the profession.
8. Submits fingerprints for background screening under s. 456.0135, if required for the profession. (Massage therapy is among the professions covered; Chapter 6 explains the process.)

The Department "shall verify information submitted by the applicant" using the National Practitioner Data Bank, as applicable.

Who is ineligible. Even if the criteria above are met, s. 456.0145(2)(c) makes a person ineligible for licensure under the MOBILE Act if he or she:

1. Has a complaint, an allegation or an investigation pending before a licensing entity in another state, D.C. or a U.S. territory;
2. Has been convicted of, or pleaded nolo contendere to, regardless of adjudication, any felony or misdemeanor related to the practice of a health care profession;
3. Has had a health care provider license revoked or suspended in another jurisdiction, or has voluntarily surrendered a license in lieu of disciplinary action; or
4. Has been reported to the National Practitioner Data Bank, unless the applicant has successfully appealed to have his or her name removed.

The fourth item has a built-in exception. If the reported adverse action resulted from conduct that would not violate any Florida law or rule, the Board may (a) approve the application, (b) approve it with restrictions on scope of practice, (c) approve it with probation on conditions the Board specifies (such as treatment, continuing education or reexamination), or (d) deny it. This is one of the few places in the licensing statutes where the Board is given a menu of intermediate options at the application stage.

(The phrase "regardless of adjudication" has the same meaning here as in Chapter 6. The mandatory-denial offenses in s. 480.041(6) also apply to any endorsement applicant, because they apply to every applicant for a new or renewal license.)

Application and fee. Rule 64B7-25.004 provides that the Department issues a license by endorsement to a person who (1) pays the initial licensure fee set in Rule 64B7-27.100; (2) submits a completed application on form DH-MQA-5103 (effective 07/24), "Mobile Opportunity by Interstate Licensure Endorsement" (MOBILE), which the rule incorporates by reference; and (3) demonstrates that the requirements of s. 456.0145(2) have been met. As with the examination application (Chapter 5), use the current version of the form from the Board's website or the Department's portal.

Speed. Section 456.0145(2)(e) imposes a deadline on the State: the Board (or Department) "shall issue a license to a qualified applicant within 7 days after receipt of all documentation required for an application." The clock starts when the file is complete. An incomplete application does not start it, so completeness is the applicant's responsibility.

Truthfulness. Under s. 456.0145(2)(d) the Board "may revoke a license upon finding that the licensee provided false or misleading material information or intentionally omitted material information in an application." A license obtained by endorsement is therefore only as secure as the application behind it. This parallels the honesty rules in Chapter 5, and the same concern runs through the discipline provisions in Chapter 18.

State examination. Section 456.0145(3) allows the Board to require an endorsement applicant to complete a jurisprudential examination on state law, if the chapter or practice act requires such an examination. The Board's rule as we reviewed it does not list a separate state law exam. Earlier staff analyses described a 10-hour Florida laws-and-rules requirement for endorsement applicants, so confirm with the Board whether any current requirement of that kind applies to you.

Reporting. The Department must report each year to the Governor and the Legislature on the number of endorsement applications, approvals, denials (and reasons), and disciplinary matters involving endorsement licensees (s. 456.0145(4)). The Legislature is evidently watching how the MOBILE Act performs, which is another reason to expect further amendments.

7.4 The endorsement criteria, one at a time

The statute lists the endorsement criteria in a compact series, and each item rewards a closer look. This section takes them one at a time and explains what a careful applicant should have ready.

A complete application. The statute begins with the simplest requirement and the one that causes the most delays. The application must be complete, and as the speed provision shows, the Department's clock does not start until it is. Treat completeness as your job. Read the form, answer every question, attach every required document and pay the fee.

An active, unencumbered license. "Active" means the license is currently valid and not expired, inactive or suspended. "Unencumbered" means it carries no restrictions, conditions or probation. A license that is active but on probation is not unencumbered. Before you apply, obtain a verification of your license from the issuing authority, and read it for any notation of restriction. If you hold licenses in more than one place, be ready to document each.

A similar scope of practice. The profession in the other state must have a scope of practice that the Board determines to be similar. Massage therapy is licensed widely, but titles and definitions differ. If your other license is for a related profession, such as bodywork with a different title, ask the Board whether it is similar before you apply.

A national examination or recognized certification. Massage therapy has a national examination, so the examination route applies. Gather your score report or the certification you hold, and know the exact name of the examination you took and the year.

Active practice for at least two of the last four years. The statute looks at the four-year period immediately before the application and asks for at least two years of active practice within it. The look-back protects the public from a therapist whose skills may have lapsed. Gather documents that show practice: employer letters, business records, tax or payroll records and similar proof. Applicants who practiced independently should gather records that show clients were served.

An attestation about pending proceedings. The applicant attests that she is not, at the time she applies, the subject of a disciplinary proceeding in any jurisdiction where she is licensed, or by the Department of Defense, for reasons related to the practice. An attestation is a sworn or signed statement, and its accuracy matters, as the revocation provision shows.

No disciplinary action in the five years before applying. This look-back is longer than the practice look-back. Read your own disciplinary history, and if any action was taken, even a minor one, find out when. Do not guess.

Financial responsibility, if the profession requires it. Some professions require liability coverage or a similar financial arrangement. Ask the Board whether any financial responsibility requirement applies to massage therapists, and if so how to document it.

Fingerprints for screening. Massage therapy is covered by the screening provisions, so the applicant submits fingerprints under section 456.0135, as Chapter 6 explained.

The criteria are cumulative. The applicant must meet all of them, and missing one is enough to stop the application. That is why a checklist is so useful.

7.5 The ineligibility list, one at a time

The statute also lists circumstances that make a person ineligible for endorsement even if she meets every criterion above. They deserve the same close reading.

A complaint, allegation or investigation pending elsewhere. The word "pending" is the key. A matter that has been resolved is evaluated differently, under the five-year discipline look-back. A matter that is open makes the applicant ineligible until it is resolved. If you have a pending matter, the safe course is to wait for resolution and not to apply.

A conviction or plea related to the practice of a health care profession. The statute reaches any felony or misdemeanor related to the practice of a health care profession, including a plea of nolo contendere regardless of adjudication. The same phrase that you learned in Chapter 6 appears here, with the same meaning. Notice that the focus is on offenses related to health care practice, which is a different test from the mandatory denial list.

Revocation, suspension or voluntary surrender. A health care license revoked or suspended in another jurisdiction, or voluntarily surrendered in lieu of disciplinary action, makes the applicant ineligible. The surrender provision closes a loophole. A person who gives up a license to avoid a disciplinary finding cannot treat the surrender as a clean record.

A National Practitioner Data Bank report. A report to the data bank makes the applicant ineligible unless she has successfully appealed to have her name removed. The statute also provides a limited exception, discussed above, when the reported conduct would not violate any Florida law or rule. In that case the Board has a menu of choices: approve, approve with restrictions on scope, approve with probation on conditions, or deny.

The mandatory denial list in Chapter 6 also applies to every applicant. An endorsement applicant who has a listed disposition is subject to the same rule as any other.

7.6 The seven-day clock and what starts it

The statute requires the Board or Department to issue a license to a qualified applicant within seven days after receipt of all documentation required for an application. It is one of the shortest deadlines in the licensing statutes, and it is easy to misunderstand.

The clock does not start when you mail the application. It starts when all required documentation has been received. A file with a missing verification, an unpaid fee, an unanswered question or an unfinished screening does not start the clock. The clock also does not start because the applicant thinks the file is complete. The Department decides whether documentation is complete, and if it asks for more, the clock waits.

The deadline applies to a qualified applicant. An applicant who is not qualified, or whose file raises a question about eligibility, may not receive a license within seven days, and the deadline does not require the Department to approve an application that does not meet the criteria.

What does this mean in practice? First, an applicant should aim for a complete file, because completeness is the only thing she controls. Second, she should keep a record of the date she submitted each item and the date the Department confirmed receipt, so that she knows when the clock began. Third, if the Department takes longer than seven days after confirming a complete file, she should ask in writing about the status, citing the statute.

7.7 Practitioners licensed in other countries

Section 480.041(5)(c) contains a second endorsement-type provision. It directs the Board to adopt rules specifying licensing procedures for practitioners who "hold an active license and have practiced in any foreign national jurisdiction which has licensing standards substantially similar to, equivalent to, or more stringent than the standards of this state." This is separate from the MOBILE Act, which speaks of other U.S. jurisdictions. If you are licensed outside the United States, start with the Board and review Division 64B7 for the procedure and documentation it requires, because this is an area where the Board's own rules and forms control.

7.8 Military members and spouses

Several Florida licensing rules give special treatment to members of the armed forces and their spouses, including exemptions from some renewal requirements during an absence caused by military duty. The Board's renewal rule includes such a provision (Chapter 9 teaches it), and its authority lines cite s. 456.024, a Chapter 456 provision that addresses licensing matters for military members and spouses. If you are in that situation, read s. 456.024 and the Board's renewal rule, and ask the Department about the documentation required.

7.9 Keeping up with changing law

Endorsement offers a useful lesson about research, because it is a field in which the law has changed quickly. The statute was created in 2024, amended twice in 2025, and the Board's rule and form are dated to match. A summary written a year ago, including a classmate's notes, may be out of date.

A sound research routine has four habits. First, go to the primary source: the current text of the statute on the Legislature's website and the current rule in the Florida Administrative Code. Second, note the date of what you read, and look for the history notes that show when a provision was created or amended. Third, check the form the rule incorporates and confirm that you are using the version the rule names. Fourth, when the text is ambiguous or a change seems recent, ask the Board or the Department in writing.

There is also a habit of skepticism worth building. Be cautious about any source that does not say when it was written, and about any source that describes the law as settled in an area where the Legislature is evidently still adjusting it. The annual report that the Department must make to the Governor and the Legislature on endorsement shows that lawmakers are watching how the statute performs. When lawmakers are watching, further changes are likely.

Finally, build the habit of recording what you relied on. If you advise a colleague or make a decision about your own license, write down which provision you read and when. Should the law change, you will know what to recheck.

7.10 The apprenticeship route: closed

For many years, Florida allowed a person to qualify for a massage license through a supervised apprenticeship, sponsored by a licensed massage therapist, as an alternative to attending a school. Rule 64B7-29 (titled Apprenticeship) was written for that pathway, and the rule chapter still contains provisions on the apprenticeship training program and on changing sponsors or ending an apprenticeship.

That pathway has ended. The key provision is s. 480.041(7):

"A person issued a license as a sponsor, a route that has closed.">massage apprentice before July 1, 2020, may continue that apprenticeship and perform massage therapy as authorized under that license until it expires. Upon completion of the apprenticeship, which must occur before July 1, 2023, a massage apprentice may apply to the board for full licensure and be granted a license if all other applicable licensure requirements are met."

Three facts follow from the text:

• No new apprentices. The statute permits only those who held an apprentice license before July 1, 2020 to continue. No one can begin a massage apprenticeship today.
• A deadline for completion. Any apprenticeship had to be completed before July 1, 2023.
• A final route to licensure. On completing the apprenticeship, the apprentice could apply for a full license, subject to "all other applicable licensure requirements," which included screening and the exam.

Because the deadline has passed, there is no longer any lawful way to qualify through the massage apprenticeship. Anyone who today offers to "take you on as an apprentice" so that you can practice, or who says you can practice under their license while you learn, is describing something the law no longer permits (and, if you practice, you would be practicing without a license, as Chapter 20 explains).

Why does this still matter? For three reasons:

1. Older materials. Handouts, websites and even some forms may still refer to apprenticeship as an option. Treat them as out of date.
2. Existing licensees. Some therapists in practice today were licensed through the apprenticeship. Their licenses are as valid as any other.
3. A different use of the word. The Act's definition of "apprentice" (Chapter 2) refers to a person approved to study colonic irrigation, not to the old route to licensure. Colonic irrigation apprenticeship still appears in the Board's rules (Rule 64B7-29.007), as one way to meet the training requirement discussed next.

7.11 Recognizing and answering outdated offers

Because the apprenticeship route closed relatively recently, outdated offers and outdated materials still circulate. A new graduate may meet them at a job interview, on a website or in a conversation with an older therapist who remembers how things used to work. Knowing how to respond is part of professional judgment.

An outdated offer may take several forms. An employer may say, "Work under my license until yours comes through." A school or website may describe apprenticeship as an alternative to attending school. A colleague may suggest that a license is a formality and that practice can begin while the paperwork is processed. Each of these assumes a rule that no longer exists.

A good response has three parts. First, decline politely and clearly. You might say, "I understand that used to be allowed, but under section 480.041(7) the apprenticeship route has closed, and I cannot perform massage therapy before my own license is issued." Second, offer an alternative that is lawful, such as starting work on the date the license is issued, or doing tasks that do not constitute massage therapy, such as front-desk work, if the employer has such positions and the tasks genuinely are not massage therapy. Third, protect yourself by recording what was offered and what you said. If the offer persists, consider whether this is an employer you want to work for.

It is useful to remember that the person who makes such an offer may be sincere. Many people learn the rules once and do not follow changes. A courteous correction, with a citation, often resolves the matter. If it does not, the facts should guide you: the apprenticeship deadline has passed, and practicing without a license carries the consequences Chapter 20 describes.

Existing licensees who qualified through the apprenticeship before it closed are fully licensed. Treat them with the same respect as any other licensee. Their route was lawful when they took it.

7.12 Colonic irrigation certification

Colonic irrigation, as Chapter 2 explained, is defined in s. 480.033(5) as a method of hydrotherapy used to cleanse the colon with the aid of a mechanical device and water, and it falls within the Act's definition of massage therapy. But the Legislature required more than the ordinary massage license for it. Section 480.041(5)(b) directs the Board to adopt rules "providing for educational standards, examination, and certification for the practice of colonic irrigation, as defined in s. 480.033, by massage therapists."

Only for licensed massage therapists. The certification is for licensed massage therapists. Rule 64B7-25.001(2) says that "prior to the practice of colonic irrigation, any licensed massage therapist must be certified." You cannot be certified in colonic irrigation without first holding the massage license, and a massage license alone does not authorize colonic irrigation.

How to be certified. Under Rule 64B7-25.001(2), the Department issues the certification to a person who:

• pays the certification fee set in Rule 64B7-27.100;
• submits a completed application on form DH-MQA 1247, "Application for Colonic Irrigation Certification" (Rev. 03/2024);
• provides proof of completing a training program in one of three forms: (i) a colonic irrigation program at a board-approved massage school meeting Rule 64B7-32.005; (ii) a program with an approved provider or school in another state, territory or jurisdiction that is equal to or more stringent than the Florida minimum; or (iii) a colonic irrigation apprenticeship under Rule 64B7-29.007; and
• presents certification to the Board of successful completion of an approved examination for colonic irrigation. Under Rule 64B7-25.001(4), the approved examination is the National Board for Colon Hydrotherapy Examination (NBCHE).

The training program. Rule 64B7-32.005 sets the minimum standards for a school's colonic irrigation program. A program must include all of the following required hours, completed at no more than 6 hours per day and 30 hours per calendar week:

That is 100 hours in all. In addition, the program instructor "must be a licensed massage therapist who is certified in colonic irrigation," and a board-approved school "must receive approval prior to offering colonic irrigation training" by submitting documentation of the program to the Board.

Fees. The statute caps the colonics examination fee and reexamination fee at $100 each, and the fee for an apprentice at $100 (s. 480.044(1)(h), (i), (j)). The amounts actually charged are set by rule.

Two connections to other chapters. The Board's rule on sexual misconduct expressly states that nothing in it prohibits colonic irrigation by a licensed therapist certified under Rule 64B7-25.001(2) (this is picked up in Chapter 16). And separate rules govern the equipment and sterilization an establishment must maintain to offer colonic irrigation, and where the service may be performed (Chapters 11 and 13).

A note on finding the rule. If you search the Florida Administrative Code for Chapter 64B7-31, titled Colonic Irrigation, you will find only a repealed rule (the former colon hydrotherapy rule, repealed in 2017). The working rules for colonic irrigation are scattered in other places: certification in Rule 64B7-25.001(2) and (4), training in Rule 64B7-32.005, and apprenticeship in Rule 64B7-29.007. This is a good illustration of the research habit from Chapter 1: a chapter heading in the Code is not proof that the rules you need are in it.

7.13 The colonic irrigation pathway, step by step

The certification pathway has several parts that must come together in the right order. Laying them out as a sequence shows what a therapist would do, and where she should ask questions.

Step one: hold the massage license. The certification is for licensed massage therapists. A person who is not licensed cannot be certified, and an applicant for a massage license cannot use the colonic pathway to avoid completing the ordinary licensure steps.

Step two: choose a qualifying training program. The rule recognizes three forms of training. The first is a colonic irrigation program at a board-approved massage school that meets Rule 64B7-32.005. The second is a program with an approved provider or school in another state, territory or jurisdiction that is equal to or more stringent than the Florida minimum. The third is a colonic irrigation apprenticeship under Rule 64B7-29.007. Before you enroll, confirm that the program qualifies, and remember that a school must receive approval from the Board before it may offer the training.

Step three: complete the training and keep proof. The school should provide documentation of your completion. As with massage school, check that the name and dates match your application.

Step four: pass the approved examination. The rule names the colonic irrigation certification, abbreviated NBCHE.">National Board for Colon Hydrotherapy Examination. Register according to the testing organization's directions and arrange for the result to be certified to the Board.

Step five: apply. The application is on the form the rule names, with the fee set in Rule 64B7-27.100. Use the current version of the form.

Step six: wait for the certification. Do not begin practicing colonic irrigation until the Department has issued the certification. As with the license, a pending application does not authorize the service.

The training program has a defined structure. The next table shows the hours the rule requires.

The rule limits instruction to no more than six hours per day and thirty hours per calendar week. That limit has a practical consequence. At thirty hours a week, a 100-hour program cannot be completed in fewer than four calendar weeks, because three weeks would provide at most ninety hours. A program that advertises completion in a long weekend does not meet the rule. The instructor must be a licensed massage therapist who is certified in colonic irrigation, and the school must receive the Board's approval before offering the training.

7.14 Safety, scope and honest advertising for colonic irrigation

Colonic irrigation involves a mechanical device, water and the digestive system of a client. Because of that, the safety and professional obligations that apply to every massage therapist apply with special force.

Scope still applies. Chapter 3 taught that a massage therapist may not diagnose, prescribe or claim to treat disease. Certification in colonic irrigation does not change those limits. A certified therapist who tells a client that she has a particular digestive disease, or who recommends that a client stop medication, is outside her scope, as she would be with any other service. The certification covers the service. It does not widen the license into medical practice.

Screening the client carefully. The training program includes history, clinical records, indications and contraindications, which shows how important careful intake is. A therapist who learns that a client has symptoms that call for medical evaluation should refer the client rather than proceed. When a finding is outside her competence, the correct response is to notice, stop or modify, refer and record, as Chapter 3 described.

Equipment and sterilization. The training includes sterilization and equipment training, and other rules govern what an establishment must maintain in order to offer the service and where it may be performed. Chapters 11 and 13 cover those requirements. A therapist who is certified but works in a setting that does not meet the establishment rules cannot lawfully offer the service there.

Honest claims. Advertising and conversation with clients must be accurate. Chapter 17 explains advertising rules. As a matter of professional honesty, a therapist should not claim that any service cures disease or removes toxins, because such claims are not supported and they invite complaints. Describe the service for what it is, state your certification accurately, and let clients make informed choices.

Informed consent. A client should understand what the service involves, what to expect, what the risks are and what alternatives exist before she agrees. Consent practices are covered in Chapter 10. Record how consent was obtained.

The point of this section is that the certification adds a service and adds obligations. It does not relax the ordinary duties of a licensed therapist. It increases them.

7.15 Finding the right rule: a research lesson

The note in the original text about Chapter 64B7-31 is worth another look because it teaches a skill. If you search the Florida Administrative Code for the chapter titled Colonic Irrigation, you will find only a repealed rule. A student who stopped there might conclude that colonic irrigation has no rules, or that certification is not required. Both conclusions would be wrong.

The working rules are in other places. Certification is in Rule 64B7-25.001, subsections (2) and (4). Training is in Rule 64B7-32.005. Apprenticeship for colonic irrigation is in Rule 64B7-29.007. The lesson is that the title of a chapter in the Code is a clue, not a guarantee. The way to find the rules that govern a topic is to search by subject, to follow cross-references, to read the authority lines at the end of each rule, and to read the statute that tells the Board what to adopt. In this case, the statute is section 480.041(5)(b), which directs the Board to adopt rules for educational standards, examination and certification for colonic irrigation by massage therapists.

A sound research method for any topic has five steps. Begin with the statute that grants the authority. Find the rules that implement it by searching for the key terms. Check the authority and history lines to see which statute each rule implements and when it changed. Look for forms the rules incorporate. Confirm the current version of everything before you rely on it.

7.16 Frequently asked questions

I hold an active license in another state but I am on probation there. Can I use endorsement? The statute requires an unencumbered license, and probation is a condition. Ask the Board how it treats your situation before you apply, and answer the application's questions truthfully.

I have been licensed for ten years but did not practice for the last three. Does that matter? It may. The statute asks for at least two years of active practice within the four years before the application. Describe your practice history accurately and ask the Board how it evaluates your situation.

May I begin working in Florida while the endorsement application is pending? No. The license must be issued first. The seven-day deadline runs from receipt of all documentation, and until the license is issued you may not practice.

Is my license in a foreign country enough? The statute provides a separate provision for practitioners from countries with substantially similar or stricter standards, and the Board's rules and forms control the procedure. Contact the Board early and ask what documents it requires.

I am a military spouse. Is there anything special? Florida has provisions for military members and spouses in the licensing statutes. Read section 456.024 and the Board's renewal rule, and ask the Department what documentation applies to your situation.

Do I need colonic irrigation certification to work at a spa that offers the service? If you will perform colonic irrigation, the rule says you must be certified before you practice it. If you will only perform ordinary massage, you do not. Ask the employer exactly which services you will be assigned.

Can I finish the colonic training in a weekend? The rule caps instruction at six hours per day and thirty hours per calendar week, and requires a 100-hour program. A weekend program cannot meet both limits.

7.17 More scenarios to practice

Scenario E: The lapsed practice. Priya has held a clear Texas license for nine years. For the last three years she has not worked as a massage therapist. She wants to apply for endorsement. What should she consider?

Discussion. The statute requires at least two years of active practice during the four years immediately before the application. If she practiced for less than that during the look-back period, she may not meet the criterion. She should describe her history accurately, gather records of the practice she did have, and ask the Board how it evaluates her situation. She should not claim practice she did not have.

Scenario F: The surrendered license. Luis surrendered his license in another state after a complaint was filed, before any hearing. He says the surrender means there is no discipline on his record, and he applies for endorsement. Is he correct?

Discussion. No. Section 456.0145(2)(c) makes an applicant ineligible if she has voluntarily surrendered a license in lieu of disciplinary action. The surrender provision exists so that giving up a license to avoid a finding cannot be treated as a clean record. Luis should not rely on the argument, and he should answer the application's questions truthfully.

Scenario G: The incomplete file. Keisha applies for endorsement and receives no license after two weeks. She points out that the statute requires issuance within seven days. What should she check?

Discussion. The seven days run from receipt of all documentation required for the application. She should ask the Department whether her file was complete and, if not, what is missing. If it was complete on a specific date, her records should show it, and she can ask in writing why the license has not issued. If the file was incomplete, the clock has not started.

Scenario H: The weekend colonics course. A school advertises a "100-hour colonic irrigation certification in one weekend." A licensed therapist asks whether it will qualify. What should she say?

Discussion. The rule limits instruction to six hours per day and thirty hours per calendar week, so a 100-hour program cannot be completed in a weekend. In addition, a school must have the Board's approval before offering the training, and the training is only one part of certification, which also requires passing the approved examination and submitting the application. She should decline the program and look for one that is approved or equivalent.

Scenario I: The uncertified colonics service. A licensed therapist works at a wellness clinic that offers colonic irrigation. The owner says, "You are licensed, so you can do it." What is the correct response?

Discussion. The rule requires certification before a licensed massage therapist may practice colonic irrigation. The license alone does not suffice. She should decline to perform the service until she is certified, and she should explain the rule to the owner. The owner may also be exposed if she assigns the service to someone who is not certified, as Chapter 3 explained about delegation.

Chapter summary

The Act provides several routes besides the ordinary examination route. Endorsement, governed by the MOBILE Act in section 456.0145 and Rule 64B7-25.004, allows a person with an active, unencumbered license in another U.S. jurisdiction to be licensed in Florida without starting over, provided she meets all of the criteria: a complete application, a similar scope of practice, a national examination or recognized certification, at least two years of active practice in the last four, an accurate attestation, no discipline in the previous five years, any applicable financial responsibility and fingerprints for screening.

Certain circumstances make an applicant ineligible: a pending complaint or investigation elsewhere, a conviction or plea related to health care practice, a revocation, suspension or surrender of a license in another jurisdiction, and a report to the National Practitioner Data Bank unless successfully appealed, subject to a limited exception. The Board or Department must issue a license within seven days after receipt of all documentation for a qualified applicant. The Board may revoke a license obtained through false or misleading information.

A separate provision directs the Board to adopt rules for practitioners licensed in foreign jurisdictions with similar or stricter standards, and Florida licensing rules include special provisions for military members and spouses.

The apprenticeship route to a massage license is closed. Section 480.041(7) allowed only those licensed as apprentices before July 1, 2020 to continue, and required completion before July 1, 2023. The word "apprentice" still matters because outdated materials circulate, because some current licensees qualified that way, and because the Act's definition of apprentice refers to a person approved to study colonic irrigation.

Colonic irrigation requires certification before a licensed massage therapist may practice it. The Department issues the certification to a therapist who pays the fee, submits the application, proves completion of a qualifying 100-hour training program or equivalent, and presents certification of passing the colonic irrigation certification, abbreviated NBCHE.">National Board for Colon Hydrotherapy Examination. The ordinary scope limits, safety duties and honest-advertising duties continue to apply.