The Interstate Medical Licensure Compact Commission is the sole entity authorized to administer the Compact. In doing its administrative work, the Commission must not only follow the language of the Compact, but also the rules and policies it creates to govern itself.
All of the Commission’s governance materials are included at this website. Click on each of the headings below for a brief description of what you’ll find in each section.
(Note: When searching for an answer to a particular question related to the Compact, you may have to look in multiple places. The Compact law may require something without stating who is responsible or how it is to be accomplished. Compact Rules might provide the specifics of “who” and “how.” And a Commission Advisory Opinion might provide even more detail into how the Commission interprets a specific term or approaches a specific kind of decision.)
Each state that joins the Compact must enact the same legislation as every other state that has joined previously. The model legislation is included here in its entirety and can be downloaded - Compact Law
In addition to enacting the core Compact law, some states might need to enact additional statutory language to govern the selection of the Commissioners that will serve as its representatives to the Commission. Some states also have had to amend their original physician licensure laws to require the criminal background checks the Compact mandates. But the primary Compact law remains the same for every state.
The IMLC Commission Bylaws formally define the governance structure of the Compact Commission. The Commission adopted the original bylaws at its first meeting in October 2015. Among other things, the Bylaws provide the authority for the Commission to elect officers, form committees, engage in financial transactions, dissolve the Compact and perform other basic functions.
The Bylaws do not address state licensure of physicians or the Commission’s business processes. The Commission can amend the Bylaws under the terms of Article X—and has done so—but most of the language included in the Bylaws to date has remained unchanged from its original form.
- IMLC – Bylaws Index - Amended November 17 2020
- IMLC – Bylaws – Article I – Purpose
- IMLC – Bylaws – Article II – Membership
- IMLC – Bylaws – Article III – Officers - Amended November 17 2020
- IMLC – Bylaws – Article IV – Commission Personnel
- IMLC – Bylaws – Article V – Qualified Immunity, Defense, and Indemnification
- IMLC – Bylaws – Article VI – Meetings of the Commission
- IMLC – Bylaws – Article VII – Committees - Amended November 17 2020
- IMLC – Bylaws – Article VIII – Finance
- IMLC – Bylaws – Article IX – Withdrawal, Default, and Termination
- IMLC – Bylaws – Article X – Adoption and Amendment of Bylaws
- IMLC – Bylaws – Article XI – Dissolution of the Compact
Just as states use administrative rules to implement statutory law and provide important details, the Commission writes rules to add detail to provisions of the Compact. This function of the Commission is specifically allowed by Section 12 of the Compact.
The Commission’s first rule was a 2016 rule outlining its rulemaking process—a “Rule on Rulemaking.” Since adopting that rule, the Commission has adopted seven chapters of rules that guide its business processes and the interactions of the Commission and its staff with the member states within the Compact.
- IMLCC – Rules Index 11-17-2020
- IMLCC Rule – Chapter 1 Rule on Rulemaking – Adopted June 24 2016
- IMLCC Rule – Chapter 2 Administrative Rule on Information Practices – Amended June 27 2017
- IMLCC Rule – Chapter 3 Administrative Rule on Fees – Amended May 22 2017
- IMLCC Rule – Chapter 4 – State of Principal License – Amended November 19 2019
- IMLCC Rule – Chapter 5 – Expedited Licensure – Amended September 15 2020
- IMLCC Rule – Chapter 6 – Coordinated Information System, Joint Investigations and Disciplinary Actions – Adopted November 16 2018
- IMLCC Rule – Chapter 7 – Rule on Compliance and Enforcement – Adopted November 16 2018
- IMLCC Rule – Chapter 8 – Rule on Notice of Licenses Upon Withdrawal or Termination of Membership in the Compact – Adopted November 19 2019
- IMLCC Rule – Chapter 9 – Rule on Exemption from Disclosure of Records – Adopted November 19 2019
- IMLCC Rule - Chapter 10 - Rule on Annual Assessment - Adopted November 17 2020
The Compact also allows the Commission to create policies about personnel or other areas that help achieve the purposes of the Compact.
As with rules, the Commission first adopted a policy on making policies so that there were clear guidelines. IMLC policies address areas such as conflict of interest, the creation of IMLC annual reports, the establishment of reserve funds, and staff response to requests for records and information.
- IMLC – Policies Index
- IMLC – Policies #1 – Policy on Policies
- IMLC – Policies #2 – Policy on Conflicts of Interest
- IMLC – Policies #3 – Policy on Executive Committee Spending Authority - Rescinded March 2021
- IMLC – Policies #4 – Policy on Annual Report
- IMLC – Policies #5 – Policy on IMLCC Reserve Funds
- IMLC – Policies #6 – Policy on Records and Information Requests
- IMLC - Policies #7 - Policy on Changes to IMLCC webpage
- IMLC - Policies #8 - Policy on Capital Assets
Section 12 of the Compact authorizes the Commission to issue advisory opinions interpreting areas of its rules or bylaws that require further clarification. This can be done at the request of a member board or state.
The Commission has approved advisory opinions on issues such as specialty board certification, graduate medical education, requirements for state of principal licensure designation, and discipline of physicians in non-Compact states.
Each of these documents sets out the basis for issuing the opinion and the questions being addressed, followed by the actual opinion.
- IMLC – Advisory Opinions Index
- IMLC – Advisory Opinions – Unnumbered December 18 2015 - Maintaining board certification
- IMLC – Advisory Opinions – Opinion Number 01-2017 - Graduate Medical Education Requirements
- IMLC – Advisory Opinions – Opinion Number 02-2017 - State of Principal LIcense requirements
- IMLCC LETTER – Arizona Medical Board – May 16, 2018 – ACGME approved fellowship
- ILMCC – Advisory Opinions – Opinion Number 07-2018 - Physicians disciplined by non-member boards
- ILMCC – Advisory Opinions – Opinion Number 09-2018 - Issue #1 = Qualification to act as a State of Principal License (SPL), Issue #2 = relationship between an SPL and Letters of Qualification (LOQ) issued, Issue #3 = meaning of the word "terminate" in reference to IMLCC Rules
- IMLCC - Advisory Opinions - Opinion Number 09-2020 - Authority of a member state to challenge a State of Principal License's decision to issue a Letter of Qualification
To obtain a word version of any of the documents on this page, please contact the Executive Director at firstname.lastname@example.org.