Compacts can help simplify the process for licensees who wish to practice their field in more than one state, so that they can operate under one license and one set of rules. In order to become official, a compact typically must be enacted by at least 7 state legislatures – a process which often takes a tremendous amount of time while a local government navigates what impact will/will not occur as they consider revamping (or even overriding) some of their existing rules in order to capitulate to the compact’s needs.
The IMLC Commission was seated in 2015 and began issuing letters of qualification in 2017. The mission is to increase access to medical care for patients in underserved areas as well as greater access to experts by both the use of telemedicine, and allowing the practice of medicine across state lines. The compact not only eases the licensure process for physicians who are capable of serving multiple states but it also increases communication between licensing boards for standardization. In addition, boards are capable of sharing investigative/disciplinary information of its licensees. All of these are benefits for the consumer by providing greater access to health care as well as a significant boost to public protection by means of greater oversight.
As of June 2019, twenty-nine of the 50 United States are issuing the IMLC, and Georgia, Kentucky, Oklahoma, Pennsylvania, and Vermont have pending implementation. Additionally, the territory of Guam has been issuing the IMLC since 2017 and the District of Columbia passed the IMLC but has delayed implementation of the compact. A complete map of states which have enacted the IMLC can be found here.
In a matter of a few years, the IMLC has expanded rapidly and makes it easier for physicians to provide healthcare across state lines and/or via telemedicine. The process for the IMLC application is very clearly defined at: https://imlcc.org/what-is-the-process/. Any IMLC applicants should heed the explicit instructions as well as warnings throughout the entire process. There is a $700.00 application fee that is non-refundable, and it is imperative that physicians first verify that they qualify to apply for the IMLC.
In order to qualify, physicians must:
- Hold an unrestricted medical license in a compact member state
- and fulfill at least one of the following:
- Primary residence is the State of Principal Licensure (SPL)
- At least 25% of medical practice occurs in the SPL
- Employer is located in SPL
- Use SPL as state of residence for US Federal Income Tax purposes
Once it is well-established that qualifications have been met, the $700 fee is required to be paid in full before the application can begin. Payment link and application can be found here. Applicants who do not qualify, yet question their eligibility, are referred to their SPL and only the SPL. The IMLC Commission does not handle inquiries regarding denied applications.
It is equally critical that the physician maintain their SPL at all times. After receiving their Letter of Qualification (LOQ) for the IMLC, they may redesignate their SPL. While it is possible to “change one’s home state” and still maintain the IMLC, each physician is mandated to be sure they are in full compliance with their SPL regulations.
Applicants can also apply for more than one license at a time, as long as each state is a member of the compact. At a later date, additional states may be included to licensure as long as the request falls within one year of the initial LOQ from their SPL and additional states are compact members. Licensure fees and a handling fee are required for including additional states.
The stringent rules and process for the application for and maintenance of the IMLC show how establishing an interstate compact for physicians has been and continues to be a highly regulated process that serves the public by continual review of licenses, oversight by the commission and the cooperation between members of a compact. The IMLC allows qualified physicians to provide medical care in-person and by means telemedicine to patients who are located in any of the states for which their IMLC applies.