Most physicians have a single medical license allowing them to practice in one state. Still, one can collect quite an assortment of licenses. There are 50 states in the United States. There’s the District of Columbia. And five inhabited territories (American Samoa, Guam, Puerto Rico, US Virgin Islands, and Northern Mariana Islands).
Do the math. One could accrue 56 medical licenses.
To apply and renew one by one would require lots of administrative work. And cost.
Some of this problem was streamlined about a decade ago, via the Interstate Medical Licensure Compact.
Recognizing that physicians will increasingly practice in multiple states as a result of telemedicine, U.S. state medical boards in 2013 began actively discussing the idea of creating the Compact in order to help streamline 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 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 April 2017, the Compact became operational.
What are the mechanics?
Physicians who are eligible 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. The Commission does not issue a “Compact license” or a nationally recognized medical license for physicians.
Only states and territories who have formally joined the Compact can participate in this streamlined licensure process. In order to participate in the Compact, states and territories must pass legislation authorizing it.
You first designate a “master license” known as State of Primary Licensure (SPL). You must hold an unrestricted license to practice medicine in your SPL. A SPL cannot be just any state. You must have some bona fide ties to that location, checking at least one of the following boxes.
- 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.
One can change the location of a SPL – called redesignating – after the physician received a Letter of Qualification to participate in the Compact. One must always maintain an SPL to continue in the Compact.
Other qualifications to participate:
- Graduated from an accredited medical school, or a school listed in the International Medical Education Directory or its equivalent such as the World Directory of Medical Schools
- Completed ACGME- or AOA-accredited graduate medical education
- Passed each component of the USMLE, COMLEX-USA, or equivalent in no more than three attempts for each component (Please note that 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
Note, these requirements are more stringent than just getting a license on its own. You need to be board certified, and if not grandfathered with lifetime certification, participate in maintenance of certification.
Next, there are some showstoppers.
- No history of disciplinary actions toward their medical license
- No criminal history
- No history of controlled substance actions toward their medical license
- Not currently under investigation
You have to self-certify before applying. And you have to confirm you understand the rules.
Discipline can include a public reprimand, suspension, probation or revocation.
It’s not clear if enrollment in a Physicians Health Program due to controlled substances forecloses participating in the Compact. Presumably, if one voluntarily enrolls as a diversionary pathway, it is allowed. The disqualifying term is: “Has never had a controlled substance license or permit suspended or revoked by a state or the United States Drug Enforcement Administration.” Model Statute, Section 2, paragraph (k)(8).
Once you’re in, what about renewal? What happens if the Board opens an investigation related to a complaint? While being under investigation precludes a first-time application, it does not sidestep renewing.
The requirements for a physician’s renewal are found in the IMLC Model Statute, Section 7. There are 4 eligibility criteria plus compliance with a member board’s professional development or CE requirements:
SECTION 7. RENEWAL AND CONTINUED PARTICIPATION
a. A physician seeking to renew an expedited license granted in a member state shall complete a renewal process with the Interstate Commission if the physician:
- Maintains a full and unrestricted license in a state of principal license;
- Has not been convicted, received adjudication, deferred adjudication, community supervision, or deferred disposition for any offense by a court of appropriate jurisdiction;
- Has not had a license authorizing the practice of medicine subject to discipline by a licensing agency in any state, federal, or foreign jurisdiction, excluding any action related to non-payment of fees related to a license; and
- Has not had a controlled substance license or permit suspended or revoked by a state or the United States Drug Enforcement Administration.
b. Physicians shall comply with all continuing professional development or continuing medical education requirements for renewal of a license issued by a member state.
Being under investigation is a disqualifying event only in the application process for a Letter of Qualification (LOQ) – IMLC Model Statute, Section 2, paragraph (k)(9).
Being under investigation is not a disqualifying event for renewing a license within the IMLCC process.
The list of participating states is dynamic. As of the date this was written, the Compact included 40 states, the District of Columbia, and Guam.
An important point to remember. If you are disciplined (license revoked, surrendered, suspended, or surrendered in lieu of discipline) in one state/territory, it could mushroom to reciprocal action in other states/territories. Though each member state may have some discretion.
6.6 State Authority regarding Disciplinary Actions A member board authorized or required to impose an automatic licensing action against a Compact physician, under IMLC Statute, Section 10(b) and (d), may immediately terminate, reverse, or rescind such automatic action pursuant to the Medical Practice Act of that state.
What if you do something prohibited in one state, but allowed in another? If you are treating a patient in the more restrictive state, you must follow the rules of THAT state.
Because of the provisions of the Compact as enacted, each state is assured that the licenses issued by their respective compact member state board, whether via the Compact process or traditional (single state licensure) process. The terms of the Compact place the same obligation to comply with each member state’s medical practice act when treating patients in their respective state. Each state has the sole authority over the practice of medicine within its borders as established by its own medical practice act and licensure and discipline processes. The principles of medical licensure portability and sovereignty of each member state’s medical practice act remains unchanged.
Disciplinary actions could mushroom from one state to many. But because of each state’s discretion to apply its own Medical Practice Act rules, discipline in one state does not automatically activate discipline in all states.
The IMLC is a process to provide increased licensure portability to licensure. Still, it is not an actual license. Each state and territory ultimately decides the rules related to the practice of medicine within its borders.
What do you think?
