THE INTERSTATE MEDICAL LICENSURE COMPACT: FREQUENTLY ASKED QUESTIONS
Prepared by the Interstate Medical Licensure Compact Commission
WHAT IS AN INTERSTATE COMPACT?
An interstate compact is a legal agreement among states. In the case of the Interstate Medical Licensure Compact (also referred to here as the IMLC or just “the compact”), it’s an agreement that addresses the licensing of physicians across state lines.
WHERE DID THE IMLC COME FROM?
A group of state medical board executives, administrators and attorneys wrote the language of the IMLC in 2013 and 2014. The national Federation of State Medical Boards also was involved and helped facilitate the creation of the compact. But no one “owns” the IMLC.
WHAT DOES THE IMLC DO?
It creates a new “expedited” pathway to state licensure for experienced physicians who have outstanding practice histories. It sets the qualifications for licensure and outlines the process for physicians to apply and receive licenses in states where they’re not currently licensed. The IMLC also details the role of the governing IMLC Commission and sets limits on what the Commission can do.
HOW DOES A STATE JOIN THE COMPACT?
The state Legislature must pass a bill authorizing the state to join the compact. Then the Governor must sign it. The language of the compact must be identical in each state.
WHO’S IN CHARGE OF THE COMPACT?
The compact creates a Commission made up of two representatives from each adopting state. 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. Only the Commission can enforce the IMLC through its bylaws, rules, policies, and advisory opinions. No other governmental agency or private entity has control over how the IMLC is implemented.
IS THE COMPACT IN FORCE NOW?
Yes. Once seven states adopted it, the compact became active and in force. The Commission was seated in October 2015, and began issuing Letters of Qualification in April 2017.
WHAT WILL A PHYSICIAN HAVE TO DO TO GET A LICENSE THROUGH THE COMPACT?
The compact states that a physician must apply to a state within the compact where the physician already has a license. That state becomes the physician’s State of Principal License or “home state.” The home state reviews the physician’s qualifications and shares the results with the Commission. The Commission then notifies the “receiving state(s)” within the compact where the physician wishes to be licensed.
WHAT ARE THE RESPONSIBILITIES OF THE PHYSICIAN IN THE LICENSING PROCESS?
Submitting an application and paying whatever fees are assessed. It’s also possible the physician might be asked by the home state to provide evidence to verify “state of principal license. The practice of medicine occurs where the patient is located at the time of the physician-patient encounter and, therefore, requires the physician to be under the jurisdiction of the state medical board where the patients located.
WHAT ARE THE RESPONSIBILITIES OF THE “HOME STATE” IN LICENSING?
Conducting the review of the applying physician’s qualifications under terms of the compact; informing the Commission of the results.
WHAT ARE THE RESPONSIBILITIES OF THE IMLC COMMISSION IN LICENSING?
Mostly, the Commission will act as an information exchange between a home state/state of principal license and a receiving state. The compact also envisions the Commission as the entity that collects fees from physicians and transfers licensure fees to receiving states. The Commission also will collect data about physician applications for licensure and actual licensure via the IMLC.
WHAT ARE THE RESPONSIBILITIES OF THE “RECEIVING STATE” IN LICENSING?
Issuing licenses to qualified physicians once notified by the Commission and depositing license fees when received from the Commission. State medical boards participating in the Compact are required to share complaint/investigative information with each other. The license to practice medicine may be revoked by any or all of the compact states.
CAN A PHYSICIAN APPLY FOR MORE THAN ONE LICENSE AT A TIME THROUGH THE COMPACT?
Yes, but all states chosen must have adopted the compact. A physician practicing under the Compact is bound to comply with the statutes, rules, and regulations of each compact state wherein he/she chooses to practice medicine.
WHAT IF A PHYSICIAN WANTS TO ADD ANOTHER LICENSE LATER? DOES THE PROCESS REPEAT?
Under the IMLC, the process would repeat exactly as it operated the first time. However, the
Commission could write rules about this subject. (None are contemplated at this time.)
HOW LONG DOES A “HOME STATE” CERTIFICATION LAST ONCE IT’S SENT TO THE COMMISSION?
The letter of qualification is valid for one year.
HOW CAN I PARTICIPATE IN COMMISSION MEETINGS OR DECISIONS?
Commission meetings (including meetings of the Executive Committee) are publicized through the participating states and on the IMLCC.org website. Commission meetings are open to the public and include a telephone conference call for individuals who cannot attend in person. Video conferencing has been used during face to face commission meetings.