Many Rishonim hold that both the tefillin shel yad and shel rosh must be fully on the body; there cannot be a chatzitza beneath any part of their surface. Although the tefillin do not directly touch all points around the curve of the head, a chatzitza is not permitted in that area either. Other Rishonim are not concerned with a chatzitza beneath the tefillin. Although they agree that the tefillin shel yad should not be worn on top of one’s shirt, their reason for this is different; they hold that the tefillin should not be visible to others and should be covered by a jacket, sleeve, or the like. The halacha follows the first opinion.
ה. [שו"ע כז, ד, ומשנ"ב יג, יד, יז ו]