Understanding the Interstate Medical Licensure Compact: License Portability for Physicians

What is the IMLC?

The growth of telehealth and other technologies has given rise to new opportunities and avenues by which rural areas and underserved populations can access healthcare. The IMLC allows physicians to maximize the potential of these healthcare advances.  In 2013, state medical boards began discussing the idea of an interstate licensure compact. The compact model was introduced in 2014 and state legislatures began adopting it soon thereafter.  The IMLC  became operational in April 2017. (General FAQs | Interstate Medical Licensure Compact).

Due to the pandemic, the demand for telehealth has increased exponentially. A study performed by the US Department of Health and Human Services showed a 63-fold increase in Medicare telehealth utilization since the beginning of the pandemic. (New HHS Study Shows 63-Fold Increase in Medicare Telehealth Utilization During the Pandemic). The IMLC offers an expedited pathway to licensure for qualified physicians who want to practice in multiple states. The IMLC streamlines the licensing process and negates the need to apply, pay for, and maintain multiple state licenses. In order to participate in the Compact, states must pass legislation authorizing it.

The Compact licenses are still issued by the individual states, but because the application for licensure in these states is routed through the Compact, the overall process of gaining a license is significantly streamlined. Physicians receive their licenses much faster and with fewer obstacles. 

The Compact currently includes 34 states, the District of Columbia, and the Territory of Guam. In these jurisdictions, physicians are licensed by 47 different medical and osteopathic boards. Physicians apply through the Compact to receive a Letter of Qualification from their State of Principal License (SPL).  Physicians cannot obtain licenses through the Compact unless they have an SPL and are issued a Letter of Qualification.

Why is the IMLC important for telemedicine providers?

Since the inception of the COVID-19 pandemic, the healthcare environment has been rapidly changing.  Due to the influx of patients in all healthcare settings and the need for social distancing, the demand for healthcare professionals and alternative access points to healthcare has risen dramatically as evidenced by the 63-fold increase in usage of Medicare telehealth since 2020. License portability helps ease this burden by enabling eligible physicians to obtain a Compact license to practice medicine in all participating compact states, if they wish, and to provide telemedicine across state lines. 

What are the eligibility requirements?

A physician can qualify to practice medicine across state lines within the Compact if they meet the Compact’s eligibility requirements. The physician may apply through the Compact for licensure in multiple states, receiving separate licenses from each Compact state in which they intend to practice. 

There are two types of eligibility requirements: SPL eligibility and general eligibility.

More information about SPL and general eligibility can be found here: Physician Information | Interstate Medical Licensure Compact.

SPL Eligibility:

1. Hold a full, unrestricted license in a state that is a member of the Compact and
2. At least one of the following:
1. Primary residence is in the SPL
2. At least 25% of their practice of medicine occurs in the SPL
3. Their employer is located in the SPL
4. They use the SPL as their state of residence for US Federal Income tax purposes
3. Have graduated from an accredited medical school, or a school listed in the International Medical Education Directory
4. Successfully completed ACGME- or AOA- accredited graduate medical education
5. Passed each component of the USMLE, COMPLEX-USA, or equivalent in no more than three attempts for each component (LMSS does not meet this requirement).
6. Hold a current specialty certification or time-unlimited certification by an ABMS or AOABOS board
7. Not have any history of disciplinary actions toward their medical license
8. Not have any criminal history
9. Not have any history of controlled substance actions toward their medical license
10. Not currently be under investigation (General FAQs | Interstate Medical Licensure Compact)

Map from imlcc.org

States and jurisdictions participating in the IMLC as of 5/19/2022:

• Alabama
• Arizona
• Arkansas
• Colorado
• Delaware
• Florida
• Georgia
• Idaho
• Iowa
• Kansas
• Kentucky
• Louisiana
• Maine
• Maryland
• Mississippi
• Montana
• Nebraska
• New Hampshire
• North Carolina
• North Dakota
• Oklahoma
• South Carolina
• South Dakota
• Tennessee
• Texas
• Utah
• West Virginia
• Wisconsin
• Wyoming

Compact legislation has been introduced in the following states:

• Missouri
• Virginia
• North Carolina
• Massachusetts
• Connecticut
• Rhode Island
  

Each physician is responsible for determining their eligibility before applying to participate in the Compact, and they must confirm that they understand the Compact rules.

What are the Compact rules?

The IMLC Commission writes rules to detail the provisions of the Compact and guide its business processes and interactions.  There are currently ten chapters of rules that can be found here: Policies & Laws | Interstate Medical Licensure Compact.

What does it cost?

The initial cost to participate in the Compact is $700 in addition to the cost of a license in the compact state where the physician wants to practice. (Application Cost | Interstate Medical Licensure Compact).

How does a physician apply to get a Compact license?

The application for a compact license must be made through the IMLCC website.  The application can be found here: Apply License | Interstate Medical Licensure Compact. Non-refundable administrative fees apply upon application and fingerprints must be submitted so that criminal background checks can be completed.

Additional information can be found here:

• IMLC: Interstate Medical Licensure Compact
• National Center for Interstate Compacts:https://compacts.csg.org/
• American Telehealth Association: https://www.americantelemed.org/