No-one knows how an event judge will interpret a device, so they may not agree that an energized nichrome is what students say it is. Another possibility is for the device to have two identical energized nichrome set-ups, with one as thermal to another form, and the other as EMS to the same other form. Some judges may accept this, while others might not. So, I think this needs a clarification so that everyone is on the same page (students, coaches, and judges).I'm not sure why it couldn't count for thermal, but I'm also not sure why that has a bearing on if it's possible, could you explain a little more.
Some transfers do seem impossible though, as someone said Mechanical to EMS (i know I said I had an idea before, but I realized my idea was mech-therm-ems)