Frequently
Asked Questions
GENERAL FAQs ABOUT THE COMPACT
What is an interstate compact?
An interstate compact is a legal agreement among participating states that allows them to work closely together to address issues of mutual concern that cross state borders. Hundreds of compacts exist in the United States and they have helped states address everything from shared water use to transportation issues.
In the case of the Interstate Medical Licensure Compact, it is an agreement that allows states to work together to significantly streamline the licensing process for physicians who want to practice in multiple states.
Where did the Interstate Medical Licensure Compact come from?
In recent years, the growth of telemedicine and other technologies has created new opportunities to increase access to health care for patients in underserved or rural areas and to allow them to more easily connect with medical experts. Physicians are increasingly able to use telemedicine to practice in multiple states.
In an effort to maximize the potential of these new health care advances, state medical boards in 2013 began actively discussing the idea of creating an interstate physician licensure compact that could help expand access to health care for patients by streamlining traditional medical-license application processes.
The idea was embraced by a diverse range of state boards, and over the next several years the groundwork was laid for the creation of the Interstate Medical Licensure Compact. With assistance from the Federation of State Medical Boards, a group of state medical board executives, administrators and attorneys drafted a model compact – which was introduced publicly in the fall of 2014. State legislatures soon began adopting it, and in early 2017, the Compact became operational.
More than half of U.S. states, the District of Columbia and the Territory of Guam are now participating in the Compact, and other states are in the process of introducing legislation to adopt it.
What does the Compact do?
The Compact creates a voluntary, expedited pathway to state licensure for physicians who want to practice medicine in multiple states. Eligible physicians can qualify to practice medicine in multiple states by completing just one application within the Compact, receiving separate licenses from each state in which they intend to practice.
These licenses are still issued by the individual states – just as they would be using the standard licensing process – 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 burdens.
The licensing is all state-based. Physicians do not receive a “Compact license” or a nationally recognized medical license through their participation in the Compact.
Only states who have formally joined the Compact can participate in this streamlined licensure process. In order to participate in the Compact, states must pass legislation authorizing it.
Approximately 80% of U.S. physicians meet the criteria for licensure through the Compact.
The Compact sets the qualifications for licensure and outlines the process for physicians to apply and receive licenses outside of their state of principal license. The Compact also establishes and defines the role of the Interstate Medical Licensure Compact Commission – the governing body that administers the Compact -- and sets limits on what the Commission can do.
How does a state join the Compact?
To participate in the Compact, a state’s legislature must introduce and enact a bill authorizing the state to join. The language of the compact must be consistent in each state that joins. States participating in the Compact make an affirmative and informed choice to accept the Compact’s terms – made possible by the formal legislation, adopted and signed into law.
Does the Compact supersede a state’s authority over the practice of medicine in any way?
No. The Compact reflects the effort of the state medical boards to develop a dynamic, self-regulatory system of expedited state medical licensure over which the participating states maintain control through a coordinated legislative and administrative process. Coordination through a compact is not the same as superseding state authority. The Compact does not change in any way a state’s Medical Practice Act, or a state’s full authority in administering its duties of oversight. The Compact simply creates another pathway for licensure.
Who’s in charge of the Compact?
The Compact is an agreement among sovereign states, with the Interstate Medical Licensure Commission serving as an independent coordinating organization that administers the Compact on the states’ behalf. The Commission is made up of representatives from each participating Compact state.
While the Commission oversees the work of coordinating multi-state licensing activity within the Compact, it does not actually issue individual medical licenses. Licenses are issued by the states that participate in the Compact – not by the Commission itself.
Each participating Compact state sends two representatives to the Commission. These commissioners must be either a physician-member of a medical or osteopathic physician licensing board, a public member of such a board, or an executive director or administrator of such a board.
If a state has only one medical board, then both commissioners must come from that board. But if it has two boards -- a medical board and an osteopathic board -- then each board gets one seat.
The Commission is the sole entity administering the Compact’s bylaws, rules, policies, and advisory opinions. No other governmental agency or private entity has control over how the Compact is administered.
The Commission is governed by the terms of the Compact, which provides the authority for the Commission to create bylaws, rules, and policies for self-governance. Commissioners must function within the terms and limitations of the Compact and the bylaws, rules, and policies which the Commission approves. The Commission meets regularly and information about its meetings, activities and policies are posted in this website’s About the Interstate Medical Licensure Compact Commission section.
How can I participate in Interstate Medical Licensure Commission meetings or decisions?
Commission meetings (including meetings of the Executive Committee) are public meetings and are posted through the websites of Compact member states and on this website. Commission meetings are open to the public and include a telephone conference-call line for individuals who cannot attend in person. Information on committee meetings and rules proposals is available at this website.
How can I contact the Interstate Medical Licensure Commission directly?
Direct inquiries to Executive Director Marschall Smith at inquiry@imlcc.net.
The mailing address for the Commission is:
5401 South Prince Street, Office 111
Littleton, CO 80120
FAQs FOR PHYSICIANS
Who is eligible to participate in the Compact?
Any physician from a Compact state who meets the qualifications of the Compact is eligible for licensure in any other Compact state and responsible for obeying all statutory laws and administrative rules of the state.
In order to qualify for Compact participation, physicians must:
- Hold a full, unrestricted medical license in a Compact member state that can serve as a State of Principal License (SPL). (Refer to the Compact map on our homepage to see states the states that are currently participating.)
- At least one of the following also must apply:
- The physician’s primary residence is in the SPL
- At least 25% of the physician’s practice of medicine occurs in the SPL
- The physician is employed to practice medicine by a person, business or organization located in the SPL
- The physician uses the SPL as his or her state of residence for U.S. Federal Income Tax purposes.
- At least one of the following also must apply:
(Note: Physicians must maintain their SPL status at all times. An SPL may be updated after a physician receives a letter of qualification to participate in the Compact.)
- Have graduated from an accredited medical school, or a school listed in the International Medical Education Directory
- Have successfully completed ACGME- or AOA-accredited graduate medical education
- Passed each component of the USMLE, COMLEX-USA, or equivalent predecessor exam accepted by the state medical board in no more than three attempts for each component - Please note: Passing the Canadian Licentiate of the Medical Council of Canada, or the LMCC, DOES NOT meet this requirement
- Hold a current specialty certification or time-unlimited certification by an ABMS or AOABOS board
In addition, physicians must:
- Not have any history of disciplinary actions toward their medical license
- Not have any criminal history
- Not have any history of controlled substance actions toward their medical license
- Not currently be under investigation
Each physician is responsible for making a self-determination of eligibility prior to applying to participate in the Compact, and they must confirm that they understand the Compact rules.
Do physicians who use the Compact licensure process have to participate in Maintenance of Certification (MOC)?
The Compact does not require a physician to participate in MOC at any stage, nor does it require or make mention of the need to participate in MOC as a licensure renewal requirement in any state. Board certification is only an eligibility factor at the initial entry point of participation in the Compact process.
How is a State of Principal License defined?
The “State of Principal License” -- or SPL -- is the Compact member state where a physician holds a license to practice medicine and which has been designated as such by the physician for purposes of registration and participation in the Compact. The SPL is a state in which a physician holds a full and unrestricted medical license. The SPL is also sometimes called a “home state” or “primary state of licensure.”
What does a physician need to do to get a license through the Compact?
Physicians who want to use the Compact to acquire licenses must apply for participation using this website. They are asked to provide demographic and professional information and select a State of Principal License where they already have a license. The State of Principal License must be a state currently participating in the Compact.
Physicians are charged a non-refundable administrative fee when applying to participate in the Compact, and they must pay additional fees for each state in which they would like to be licensed. Physicians must also submit fingerprints to the designated criminal justice agency in their State of Principal License, so that a criminal background check can be conducted.
If you are ready to proceed, please click on the Apply tab.
How much does it cost to participate in the Compact?
The cost to participate in the Compact is $700.00 PLUS the cost of a license(s) in any Compact state where a physician wants to practice. All fees are non-refundable.
Physicians should check their eligibility BEFORE applying. If they are found to be ineligible after starting the application process, their application fee will not be refunded.
Physicians can compare the fee structures for each participating state at our What Does it Cost to Participate in the Compact? page.
What happens when a physician applies?
The physician’s State of Principal License reviews the physician’s application and qualifications, including conducting a criminal background check. If the physician meets all requirements, a formal Letter of Qualification is issued by the State of Principal License, indicating that the physician may participate in the Compact. The physician then selects the states within the Compact where he or she wishes to be licensed. These states, upon receiving the physician’s formal Letter of Qualification, issue a license.
After issuing a license to a physician who has received a Letter of Qualification for the Compact, the medical board that has issued the license may ask for additional, ancillary information to fulfill the requirements of their respective medical practice act and their operational requirements. The license holder is required to comply with these requests, and failure to do so may result in action against the license by the issuing medical board.
What happens if a physician’s eligibility is not confirmed?
Physicians who apply but do not meet the requirements of the Compact may not participate and are notified via email. Physicians who are deemed ineligible and have questions should contact their State of Principal License.
Can a physician apply for more than one license at a time through the Compact?
Yes. A physician can use the Compact process to obtain licenses from any and all participating states.
To see a map of participating states, click here.
A physician is bound to comply with the statutes, rules, and regulations of each Compact state where he or she chooses to practice medicine.
How long is a Letter of Qualification (LOQ) valid?
The Letter of Qualification (LOQ) is valid for 365 days from its date of issuance. There are no waivers of this time limit. A physician who has been issued an LOQ by a State of Principal License may apply for a new LOQ after 365 days from issuance of the initial LOQ.
Upon request for a new letter of qualification, a physician will not be required to demonstrate current specialty board certification.
What if a physician wants to add another license later? Does the process repeat?
At any time during the one-year period when a Letter of Qualification is valid, a physician can return to this website and request additional Compact member states for licensure. The physician will be required to pay licensure fees for each of the states chosen plus a $100 fee for requesting additional state licensure -- in addition to the state’s licensing fee. The Interstate Medical Licensure Commission then notifies the new states that the physician is eligible for licensure. The license issuance process is the same as for initial state selections.
If the LOQ expires, the physician will need to reapply and pay a new application fee. If a license is requested for an additional state(s) during that year, the $100 application fee plus the state application fee is due.
How does a physician renew licenses received through the Compact?
Participating Compact physicians receive a separate notice from each state where they are licensed when it is time to renew that license. Participating physicians must renew licenses obtained through the Compact by using the Compact website. They can click on the Renew tab in the “Go” bar at the top of the Compact homepage. There, they will be asked to complete a short form at the Renew page and pay their renewal fee. They then complete a short attestation and affidavit, and receive a payment receipt. Upon completion of the renewal process, an email is sent to the renewing state to verify that the physician has complied with all renewal requirements. After verification, the renewing state communicates directly with the physician to confirm licensure.
What are the responsibilities of the physician in the application and licensing process?
The physician’s main responsibilities are to accurately and fully complete the application process at this website, paying the application fee, and submitting fingerprints so a national criminal background check can begin. The physician may also need to provide information to the selected SPL that supports the designation of the Compact member state as his or her SPL.
In order for the physician to designate a particular Compact member state as his or her SPL, the physician must hold an unrestricted medical license issued by that state and be able to verify at least one of the following:
- The physician’s primary residence is in the Compact member state
- At least 25% of the physician’s practice of medicine occurs in the Compact member state
- The physician’s employer is located in the Compact member state
- The Compact member state is the physician’s state of residence for U.S. Federal Income Tax purposes
Once a license is issued, the physician comes under the jurisdiction of the licensing state’s statutes, rules and Board regulations. Under the Compact, the location of medical practice is the state where the patient is located. All laws and regulations of the patient’s state apply.
Does my Graduate Medical Education (GME) need to be ACGME or AOA accredited? What if my GME was outside the United States?
In order to established eligibility, a physician must have successfully completed ACGME or AOA accredited graduate medical education. Generally, this means that the GME was completed at an institution located in the United States or its territories. There are ACGME or AOA accredited GME programs outside of the United States, but that must be confirmed with your program prior to applying to use the compact process. Additionally, confirm that the program was accredited at the TIME you were in attendance.
This situation most often impacts physicians who attend GME in Canada. Although those programs are accepted by many member boards and qualify for board certification, unless they are ACGME or AOA certified, they do not qualify for participation with the Compact.
FAQs FOR STATES
What are the responsibilities of the State of Principal License in licensing?
Under the terms of the compact, the SPL must conduct the primary-source verification of the applying physician’s qualifications, verify eligibility and either issue a Letter of Qualification to the Interstate Medical Licensure Commission or notify the Commission that the applicant is ineligible.
What are the responsibilities of the Compact licensing states in licensing?
After a physician has been approved for licensure with a Letter of Qualification from the SPL and selects the Compact states where he or she wants to be licensed, these “licensing states” receive a notification from the Interstate Medical Licensure Commission.
When a licensing state receives a Letter of Qualification for a physician seeking licensure in that state via the Compact, the licensing state is expected to process the LOQ and issue the license promptly. This means each licensing state must have procedures and processes in place to enter information associated with the LOQ into its information database, generate a license, and account for license fees received. A licensing state also must report the licensure to the Interstate Medical Licensure Commission.
Each licensing state must notify the licensee 90 days in advance when a license issued via the compact is due to expire. Licensing states also are expected to work with the Commission to facilitate timely renewal of licenses granted via the Compact.
After issuing a license to a physician holding a Letter of Qualification, the issuing state medical board may ask for additional information to fulfill their respective medical practice act and their operational requirements. The license holder is required to comply with these requests, and failure to do so may result in action against the license by the issuing board.
What are the responsibilities of the Interstate Medical Licensure Commission in licensing?
The Commission acts as an information repository and exchange between member states. The Commission collects fees from physicians and transfers licensure fees to member states. The Commission also collects data about physician applications for licensure and actual licensure via the Compact.
What are the responsibilities of the Compact licensing states beyond licensing?
All state medical and osteopathic boards participating in the Compact are required to share complaint/investigative information with each other. If any participating board takes action against the physician who received a license via the Compact, all boards within the Compact are notified and authorized to take similar action through their regular complaint process.