Compact Policies,
Rules and Laws

Introduction

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.)

The Compact Law and Model Legislation

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.

IMLC Commission Bylaws

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.

Compact Rules

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.

Compact Policies

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.

Commission Advisory Opinions

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.

To obtain a word version of any of the documents on this page, please contact the Executive Director at  imlccexecutivedirector@imlcc.net.