Here, There, and Everywhere: Interstate Medical Licensure Compact

  • Thursday, April 12, 2018

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State Licensure: new options in cross-border practice

Since the inception of physician licensing, licenses have been granted by state agencies, on a state-by-state basis. Physicians who wished to work across state lines, or in more than one jurisdiction, had to obtain a separate license in each state.

Over time, and as interstate travel became more common, many states expanded the categories of licenses available to cover such circumstances as working at a summer camp, or volunteering in a state where one had a vacation home. Most recently, the advent of telehealth has raised interesting questions of where the physician on the transmitting end is “practicing”, and what that means for licensure.

The Interstate Medical Licensure Compact (“IMLC”) seeks to ease and perhaps regionalize physician licensing. What are the outlines of the Compact?
 

Basic Framework of the IMLC

The IMLC is voluntary, and is enacted (accepted) on a state-by-state basis. It creates an accelerated licensing process for physicians who wish to practice in more than one state. The IMLC process requires less paperwork, and takes less time both for the applicant to complete and for the licensing agency to process. Currently, 22 states are involved. New Hampshire is actively processing IMLC applications, and is an “originating state” – not only does NH accept IMLC applications from other states, its physicians are eligible to apply for IMLC licenses in other jurisdictions. Legislation is pending in Vermont, and although physicians whose licenses originate in Maine are not yet eligible for IMLC in other states, physicians from outside Maine may use the IMLC process to practice in Maine.
 

How it Works

A physician applying for IMLC processing in another state must hold a full, unrestricted license in a member state that is currently participating as an originating licensure state (like NH, see above). Further, you must either be a legal resident of the originating state, have a primary residence there, spend at least 25 percent of your practice time there, or have an employer located in that state. You must also have graduated from an accredited medical school (or a listed international school), have completed accredited graduate medical education, and passed each component of the USMLE or equivalent within three attempts. You must hold current specialty certification by a United States board, and have no history of licensing discipline, controlled substance conditions on your license, or have a criminal history. Further, applying licensees must not currently be under investigation for any of the above.

If these conditions are met, you may apply for an accelerated license process through the IMLC website. The website also contains extensive information about renewals, qualifications, and other resources.
 

Takeaways

The IMLC is not available in every state, and is not right for everyone. However, if your practice frequently crosses state lines it may be a time and cost efficient way to obtain multi-jurisdictional licensing.

Mark D. Attorri

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