Trend Analysis
Expedited Licensure Reaches 44 Jurisdictions
The Interstate Medical Licensure Compact (IMLC) has grown to include 44 member jurisdictions—42 states, the District of Columbia, and the Territory of Guam. For physicians seeking to practice across state lines, particularly those in telemedicine or locum tenens work, the Compact represents a significant reduction in licensing burden.
In some states, the traditional licensing process can take six months or longer. But with the Compact, if a provider meets the requirements, the process can be cut down to a matter of days or weeks.
Current State of the Compact
Participating Jurisdictions (2026)
As of January 2026, the IMLC includes 44 member jurisdictions. Notable recent additions include North Carolina, which implemented the IMLC pathway in January 2026.
States Not in the Compact
Notable non-member states include:
- California (largest physician workforce)
- New York
- Massachusetts
- Florida (though pending)
These states represent significant physician populations and telemedicine markets, making their absence particularly impactful.
States with Limited Participation
Connecticut, Hawaii, and Vermont are not considered "States of Principal Licensure." This means you cannot enter into the Compact through a CT, HI, or VT license—though you can obtain licenses in those states through the Compact if you have an SPL elsewhere.
Recent Developments
Michigan Withdrawal
In a significant development, Michigan is withdrawing from the Compact. Pursuant to MCL 333.16189, the withdrawal is effective March 28, 2026.
Michigan remains active until that date and will continue to:
- Issue licenses under the Compact
- Process license renewals under the Compact
- Serve as a valid State of Principal License
However, absent further legislative action, those licenses may no longer be valid after March 28, 2026. Physicians with Michigan IMLC licenses should monitor this situation closely.
New Implementations
Recent states completing implementation include:
- North Carolina (January 2026)
- Alabama (now eligible as SPL)
- Rhode Island (implementation completed after delays)
Pending States
Arkansas and Rhode Island have passed legislation to join the Compact, but implementation is still in process or has experienced delays in some cases.
Federal Incentives
CMS Rural Health Transformation Program
CMS is now incorporating a scoring system that rewards states participating in interstate licensing compacts as part of the Rural Health Transformation (RHT) Program. This includes:
- The Interstate Medical Licensure Compact
- The PA Licensure Compact
- Other healthcare professional compacts
This federal incentive may encourage additional states to join the Compact.
Who Can Use the Compact
Eligibility Requirements
To qualify for IMLC expedited licensure:
- Hold a full, unrestricted medical license in a member state
- Be board certified or within 5 years of residency completion
- Have no history of disciplinary actions
- Have passed USMLE or COMLEX within attempt limits
- Designate one state as State of Principal License (SPL)
Estimated Eligibility
About 80% of U.S. physicians already meet the criteria for licensure through the Compact, making it accessible to the majority of the physician workforce.
What the Compact Does—and Doesn't Do
What IMLC Provides
The Compact provides:
- Expedited application process: Single application for multiple states
- Faster processing: Days to weeks instead of months
- Standardized verification: One verification process
- Reduced paperwork: Avoid duplicate applications
What IMLC Is Not
Important clarification: The IMLC is not a single national license. Each state still issues its own license with:
- Its own renewal cycle
- Its own renewal fees
- Its own CME requirements
- Its own regulations
You will have multiple licenses, each governed by the issuing state's rules.
Practical Benefits
For Telemedicine Providers
Telemedicine providers treating patients in multiple states benefit significantly:
- Faster licensing in new states
- Simplified expansion of service areas
- Reduced administrative burden
- Quicker response to market opportunities
For Locum Tenens Physicians
Locum physicians working across states can:
- Accept assignments more quickly
- Reduce time between assignments
- Expand geographic flexibility
- Maintain more active licenses more easily
For Healthcare Organizations
Employers benefit from:
- Faster onboarding of multi-state providers
- Easier expansion of telemedicine services
- Reduced credentialing delays
Challenges and Limitations
Non-Member States
The absence of California and New York limits the Compact's utility:
- Large patient populations in those states
- Significant telemedicine markets
- Still require traditional licensing process
Ongoing Credential Management
The Compact simplifies initial licensing but doesn't eliminate ongoing requirements:
- Multiple renewal cycles to track
- Different CME requirements per state
- Separate renewal fees
- State-specific regulations to follow
Not All Physicians Qualify
The 20% of physicians who don't meet Compact criteria include:
- Those with disciplinary history
- Those not board certified (outside residency window)
- Those who exceeded exam attempt limits
- Those with restricted licenses
The Future of Medical Licensing
Continued Expansion
The trend suggests continued Compact expansion:
- More states considering joining
- Federal incentives encouraging participation
- Telemedicine growth driving demand
Other Healthcare Compacts
The IMLC model is expanding to other professions:
- Nurse Licensure Compact (NLC)
- Psychology Interjurisdictional Compact (PSYPACT)
- Physical Therapy Licensure Compact
- PA Licensure Compact
Technology Integration
Future developments may include:
- Better integration with credentialing systems
- Automated verification processes
- Real-time license status tracking
Using the Compact Effectively
Application Process
- Verify you meet eligibility requirements
- Determine your State of Principal License
- Apply through IMLCC portal
- Select states for expedited licensure
- Pay applicable fees
- Receive licenses (typically 2-4 weeks)
Strategic Considerations
- SPL selection: Choose carefully—it's where you primarily practice or reside
- State selection: Apply for states where you'll actually practice
- Timing: Consider when licenses will be needed for assignments
- Renewal tracking: Set up systems to track multiple renewals
Conclusion
The Interstate Medical Licensure Compact has reached 44 jurisdictions, covering the majority of U.S. states and making multi-state licensure significantly more accessible. For telemedicine providers and locum physicians, the Compact reduces what was once a months-long process to a matter of weeks.
However, the Compact is not a panacea. Major states like California and New York remain outside, Michigan is withdrawing, and each license still requires individual renewal and CME compliance. The Compact simplifies initial licensure but doesn't eliminate the ongoing complexity of maintaining multiple state licenses.
For physicians who meet the eligibility criteria—approximately 80% of the profession—the IMLC remains the fastest path to multi-state practice. Monitor developments as the Compact continues to evolve, and integrate Compact licenses into your broader credential management strategy.
Key Takeaways
- 44 jurisdictions: 42 states plus DC and Guam
- 80% eligible: Most physicians meet Compact criteria
- Days not months: Expedited processing vs. traditional licensing
- Not a single license: Each state still issues separate license
- Michigan withdrawing: Effective March 28, 2026
- Federal incentives: CMS rewarding Compact participation
References
[1]: Interstate Medical Licensure Compact - Official Website https://imlcc.com/
[2]: CompHealth - Interstate Medical Licensure Compact States List 2026 https://comphealth.com/resources/interstate-medical-licensure-compact
[3]: Weatherby Healthcare - IMLC Providing Expedited Licensure in 42 States https://weatherbyhealthcare.com/blog/interstate-medical-licensure-compact
[4]: Telehealth.org - Telehealth Licensure 2025-2026 https://telehealth.org/news/telehealth-licensure-2025-2026-cross-state-practice-and-compacts/