Objective: The onset of the COVID-19 pandemic during spring 2020 necessitated a sudden transition from in-person to telehealth mental health services. Burgeoning literature has supported the use of telehealth services generally, although there is little research related to its use among graduate-level trainees. Method: The present study utilized data collected from a university counseling training center to compare client outcomes, namely ratings of depression and anxiety, between in-person (pre-pandemic; n = 86) and telehealth (pandemic; n = 102) groups. Specifically, we examined treatment format (in-person vs. telehealth) as a moderator of the association between client-reported working alliance and client-reported outcomes. Results: Results showed a significant effect of the working alliance on symptoms of depression and anxiety regardless of format of treatment, such that higher levels of the working alliance predicted lower levels of depression and anxiety. Thus, as working alliance scores increased, client outcomes improved for both in-person and telehealth groups. Conclusion: This study suggests that the working alliance is a meaningful predictor of counseling outcomes for both in-person and telehealth formats, adding further support for use of telehealth counseling, including in counselor training settings. These findings are particularly significant given the increase of telehealth services provided since the onset of the COVID-19 pandemic. Implications for research, practice, and training are discussed.