Navigating IMLC & NLC compacts for a telehealth workforce practicing across state lines
Health-occupation licensure in the United States has been a state matter since the 19th century: each of the 50 state boards (plus DC and the territories) sets its own scope of practice, continuing-education rules, background checks, and fees for physicians, nurses, psychologists, therapists, and counselors. Telehealth did not change this patchwork — it simply exposed how poorly a state-by-state system fits a mode of care that has no physical border at all.
Every state medical board, board of nursing, and allied-health board independently defines who may practice within its borders. There is no federal medical license. A physician’s Illinois license authorizes practice in Illinois — full stop. Nursing follows a similar model through each state’s Nurse Practice Act.
This design made sense when "practicing medicine" meant a physical office visit: the state where the clinic sat was self-evidently the relevant jurisdiction. Telehealth breaks that assumption — the clinician may sit in one state while the screen shows a patient hundreds of miles away in another.
The nearly universal legal rule is that the *patient’s* physical location at the moment of the encounter determines which state’s licensing law applies — not the provider’s location, and not where the video platform’s servers happen to sit. That means a single video visit with a patient who is temporarily out of state (traveling, at college, staying with family) can require a license the provider does not hold.
Unlicensed practice of medicine or nursing is a criminal offense in most states, typically a misdemeanor for a first offense but a felony in several, alongside board discipline against the clinician’s home license and possible denial of malpractice coverage for the encounter.
A physician licensed only in Illinois who conducts one video visit with a snowbird patient currently wintering in Florida technically needs an active Florida license for that single encounter — the same requirement as if they had opened a walk-in clinic there.
Telehealth utilization jumped roughly 38-fold above its pre-pandemic baseline (McKinsey, 2021), and it has settled at a permanently higher plateau than before 2020. That surge collided with a licensure system unchanged since the 1900s. Snowbirds, border-county commuters, college students living away from home, and military families reassigned under PCS orders all generate legitimate, recurring demand for care across a state line the clinician is not licensed to cross.
In 2020, nearly every state issued emergency executive orders or board waivers letting out-of-state clinicians treat local patients by telehealth without first obtaining a local license, and CMS relaxed federal Medicare telehealth restrictions in parallel. For roughly three years, the patient-location rule was effectively suspended.
When the federal Public Health Emergency ended in May 2023, most of these state waivers sunset on their own schedules over the following months. Clinicians who had built multi-state telehealth panels during the waiver period suddenly faced the original patchwork again — commentators dubbed the abrupt loss of cross-border authorization the "telehealth cliff."
The demand for cross-state telehealth is not a hypothetical edge case — it clusters around a few recurring, high-volume populations:
• Seasonal residents ("snowbirds") who split the year between two states but want to keep one trusted clinician • Border-county residents whose nearest hospital system sits just across a state line • College students who want to continue care with a hometown provider while at an out-of-state school • Military families relocated under Permanent Change of Station orders, often repeatedly over a career • Rural patients anywhere within reach of a specialist who happens to be licensed one state over
Each of these groups is functionally invisible to a licensure system that assumes patient and provider share a state.
Interstate licensure compacts are the primary structural fix states have adopted so far. The Interstate Medical Licensure Compact (IMLC, launched 2017) and the Nurse Licensure Compact (NLC, its enhanced form effective 2018) let eligible clinicians reach dozens of states through one streamlined process instead of dozens of independent applications — without touching the underlying patient-location rule itself.
A physician who qualifies (unrestricted license in a home "State of Principal License," no pending board actions, board certification or equivalent training) submits one application through the Interstate Commission. The Commission issues a Letter of Qualification, which the physician then uses to apply for a full, separate license in each additional member state they want to practice in.
Critically: IMLC does not create a single "super-license." It still issues one license per state — but the credentialing and background-check burden is centralized, cutting typical approval time from months to roughly three weeks.
NLC takes a different legal approach: instead of fast-tracking separate state licenses, it grants a single multistate license, issued by the nurse’s home state, that is automatically valid for practice in every other member state. There is no per-state application at all once the multistate license is granted — the nurse simply practices under it, subject to each state’s practice laws while physically present there.
This is why nursing workforce mobility across compact states is generally faster and less administratively heavy than physician mobility, even though both rely on the same underlying compact concept.
Mechanically, IMLC = many licenses issued faster; NLC = one license valid in many states. Clinicians frequently conflate the two, which is itself a common source of accidental non-compliance.
Once the IMLC/NLC template proved workable, other professions built their own versions of the same enabling-legislation structure:
• PSYPACT — telepsychology and temporary in-person practice across member states • Counseling Compact — licensed professional counselors • Social Work Licensure Compact • PT Compact — physical therapists and PT assistants • Audiology and Speech-Language Pathology Interstate Compact • EMS Compact — paramedics and EMTs
Each compact requires a threshold number of state legislatures to adopt identical enabling language before it activates, so the map of "which profession is portable in which state" is uneven and still filling in year by year.
Compacts dramatically shrink the friction of multi-state practice, but they do not eliminate it. Several of the largest patient populations in the country sit in states that remain outside IMLC or NLC, and even inside compact states, licensure is only one of several compliance layers — payer credentialing, corporate-practice-of-medicine rules, and controlled-substance prescribing each add their own state-specific requirements.
Compact membership is voluntary at the state level, and adoption has been uneven. Several of the country’s most populous states — including California and New York — have historically remained outside IMLC, meaning a compact license in 41 other states still leaves two of the largest patient markets requiring a fully separate, traditional application.
Because compact coverage is state-legislature-dependent rather than federally mandated, a provider’s "reachable" map can also shift over time as individual states join, delay, or (rarely) exit a compact.
Even a fully licensed multi-state provider still faces state-specific requirements that a compact does not touch:
• Payer credentialing and Medicaid enrollment, negotiated separately in every state • Corporate-practice-of-medicine restrictions that limit how a telehealth company can employ or contract with clinicians in certain states • Informed-consent and prescribing-disclosure language that varies by state statute • Mandatory reporting and continuing-education rules tied to the license itself
Each layer multiplies the operational overhead of true nationwide reach, independent of the licensure question.
Prescribing controlled substances by telehealth carries an additional layer of federal oversight under the Ryan Haight Act, which historically required an in-person medical evaluation before most controlled-substance prescriptions. Pandemic-era DEA flexibilities suspended that requirement, and — much like state licensure waivers — those flexibilities have been repeatedly extended rather than allowed to lapse, with a permanent "special registration" framework for telehealth prescribing still pending final rulemaking as of the mid-2020s.
The result is a second, federally-controlled compliance clock running in parallel with state licensure status, and providers must track both.
A compliance risk score is not just "licensed or not" — it compounds licensure gaps with payer, corporate-practice, and controlled-substance exposure, which is why holdout states carry disproportionate operational risk even when they represent a minority of the map.
When a clinician leverages compact licensure to its fullest, the effect compounds: dramatically shorter time-to-license, a service area that can multiply many times over relative to a single state, and continuity of care for exactly the mobile populations — seasonal residents, students, military families — that a state-bound license structurally fails.
Full compact participation turns a rigid, state-bound workforce into an elastic one: a specialist shortage that spikes in one member state can be met, almost immediately, by clinicians already licensed and practicing in neighboring compact states. Patients keep the same clinician across a move, a semester away at college, or a winter spent in another state — continuity that the pre-compact system simply could not offer.
Compacts solve most of the volume problem but not all of it: non-member states, profession-by-profession compact coverage (a physician’s compact does nothing for a psychologist colleague), and the parallel federal controlled-substance question all remain open. Policy proposals for broader licensure portability — including federal recognition of any valid state license, modeled on how attorneys and some other professions already operate — continue to circulate in Congress and state legislatures without full adoption.
One corner of the system already works the way portability advocates want the whole system to work: physicians and nurses employed by the Department of Veterans Affairs or the uniformed services can practice under a single federal authorization in any VA facility nationwide, regardless of which single state originally issued their license. It is a working proof-of-concept that broader portability is administratively feasible — the remaining barrier is legislative, not technical.
The gap between where compacts stand today and full nationwide portability is best measured not in technology, but in how many more state legislatures adopt the same enabling language — exactly the dynamic the Compact Adoption Rate slider in this simulator is modeling.