What the IMLC actually means for healthcare employers (not clinicians)

Most IMLC explainers are written for physicians. Eligibility criteria, how to designate a State of Principal License, what a Letter of Qualification costs. All useful if you're a doctor trying to get licensed in new states.

If you run a telehealth company or manage clinical ops, you need different information: which of your physicians can move through this faster, which states it actually covers, where it breaks down, and how to factor it into expansion planning. This is that piece.

What the IMLC is and what it isn't

The Interstate Medical Licensure Compact is an agreement between participating states that lets eligible physicians apply for licenses in multiple states through one streamlined process rather than separate applications with each state board. It launched in 2017 and currently covers 42 states, Washington D.C., and Guam.

Two things to be clear on.

It's not a single national license. It doesn't grant a physician the right to practice everywhere. Each participating state still issues its own license — the compact just speeds up and coordinates the application process between them. Your physician ends up with separate state licenses. They just get them faster.

It only covers physicians — MDs and DOs. Not nurse practitioners, not PAs, not behavioral health therapists, not registered nurses. Each of those professions has its own compact arrangement at varying stages of adoption. If your workforce includes a mix of clinician types, the IMLC covers one part of it.

The states that actually matter for expansion

Not all 42 IMLC participants work the same way.

Most states are full participants — physicians licensed in those states can designate them as their State of Principal License (SPL), which is the entry point into the compact. Others are partial participants: they'll issue IMLC licenses to physicians coming in from other compact states, but physicians licensed there can't use them as an SPL.

The states not in the compact at all — where you'll need standard licensing regardless — include California, Florida, and New York.

That matters for telehealth. California and Florida are two of the largest patient markets in the country. If your expansion plans include either, the IMLC doesn't help you there. Standard state board applications, standard timelines.

When mapping out which states to enter next, separate your target list into IMLC-covered and non-covered. They have different timelines and different cost structures.

Which of your physicians actually qualify

The physician needs an unrestricted license in an SPL-eligible compact state. They also need current board certification from an ABMS or AOA member board, a clean disciplinary record, no criminal history, and completion of an ACGME or AOA-accredited residency.

For most practicing physicians at established telehealth organizations, those criteria aren't a problem. But there are edge cases. A physician whose primary license is in a non-SPL state, or one with any disciplinary history, can't use the compact pathway. If your roster includes recent graduates, internationally trained physicians, or providers with licensing complications in any state, check each one individually.

The other thing: the physician's SPL must be the state where they live, maintain their primary practice, or where at least 25% of their practice occurs. This matters if you have physicians working remotely across multiple states — the SPL designation has to reflect their actual situation.

What it means for deployment timelines

For eligible physicians going into IMLC-covered states, the compact pathway cuts meaningful time off the process — often weeks. Applications go through the compact's central system rather than each state board independently. Once a Letter of Qualification is issued, it can be used to apply to multiple compact states at once.

For employers that means: if you're expanding into four IMLC states with compact-eligible physicians, those applications can run in parallel rather than sequentially. You're not waiting on one state to finish before starting the next.

For non-compact states, or ineligible physicians, standard timelines apply — which vary significantly by state and can stretch to several months.

This is why it's worth auditing your physician roster for IMLC eligibility before locking in your expansion roadmap. Which states you can enter faster may shape which markets you prioritize.

Where employers get tripped up

Assuming compact means no paperwork. The IMLC reduces admin significantly but doesn't eliminate it. Each state still has its own license fees, renewal requirements, and CME obligations. Once a physician has licenses in six states, tracking those renewals — different expiry dates, different state-specific rules — is its own operational task.

Treating compact and non-compact states the same in your planning. If your Q3 expansion includes two IMLC states and two non-IMLC states, they won't move at the same pace. Build that into your timeline. If you need all four providers ready by a specific date, the non-compact states are your risk.

Assuming all your physicians qualify. Before committing to timelines with clinical leadership or patient volume targets, confirm which providers actually meet the criteria. One physician with a disciplinary flag in any state disqualifies them from the compact pathway entirely.

Ignoring the non-physician gap. APRNs, PAs, and behavioral health therapists aren't covered by the IMLC. If you're building a multi-disciplinary telehealth offering, each provider type has its own licensing pathway. RNs have the Nurse Licensure Compact in NLC states. Psychologists have PSYPACT. Licensed professional counselors have the Counseling Compact. The coverage isn't as wide and the rules differ for each.

How to use IMLC eligibility in expansion planning

Prioritize compact states in early expansion. When you have a choice of which markets to enter first, IMLC-covered states with compact-eligible physicians activate faster. Use that to generate initial revenue from new markets while standard licensing runs in parallel for non-compact targets.

Audit your roster before you plan. Pull your physician list, check compact eligibility for each, and map it against your target state list. The intersection — compact-eligible physicians heading into IMLC states — is your fastest deployment path. Everything outside that intersection runs on a longer clock.

Start non-compact states early. California, Florida, New York — if any are on your roadmap, start standard licensing as soon as possible. Waiting until compact state expansions are wrapped up adds months unnecessarily.

Track renewals centrally. Once physicians have licenses in multiple states, expiry management is real overhead. States renew on different cycles. A lapsed license means a provider who can't practice, which in telehealth means patients who can't be seen and revenue you can't bill.

Bottom line

The IMLC is useful for telehealth companies expanding into multiple states with eligible physicians. It makes the process faster and reduces admin compared to filing with every state board separately. For compact-eligible physicians going into compact states, it's the fastest available path.

But it doesn't solve the whole problem. Non-compact states need standard applications. Non-physician providers need separate pathways. And once licenses are issued, you're still managing them individually across states.

The employers who get the most out of it treat the IMLC as one input into expansion planning — auditing eligibility, mapping it against target markets, running compact and non-compact processes in parallel rather than sequentially.

Frequently asked questions

What is the IMLC and how does it work for employers? The Interstate Medical Licensure Compact lets eligible physicians obtain licenses in multiple states through one streamlined process, across 42 states, D.C., and Guam. For employers, compact-eligible physicians can be deployed into IMLC states faster — often with parallel submissions rather than sequential ones.

Which states are not in the IMLC? As of 2025, California, Florida, and New York are not IMLC participants. Physicians practicing in those states need standard state board applications at standard processing timelines. Several other states have passed legislation but are still in implementation — check the IMLC's official map for current status.

Does the IMLC cover nurse practitioners and PAs? No. The IMLC covers physicians only — MDs and DOs. RNs are covered by the Nurse Licensure Compact in participating states. PAs have their own compact. Behavioral health providers have the Counseling Compact. Each has different state coverage and eligibility requirements.

How long does IMLC licensing take vs. standard licensing? For compact-eligible physicians applying to IMLC states, the process is faster — typically weeks rather than months. Exact timing depends on the physician's SPL state, how quickly the Letter of Qualification is issued, and individual state board processing. Non-compact states and ineligible physicians are on standard timelines, which vary significantly.

What is a State of Principal License? The state a physician designates as their primary license state when entering the IMLC. The SPL must be a compact member state where the physician lives, practices primarily, or conducts at least 25% of their medical activity. The SPL issues the Letter of Qualification that enables applications to other compact states.

Can employers manage IMLC licensing in-house? Yes, but it adds real operational overhead — particularly once you have multiple physicians with licenses in multiple states, all renewing on different cycles. Most telehealth organizations use a licensing service to manage the process end-to-end, covering compact and non-compact states together.

DirectShifts handles multi-state provider licensing for telehealth employers — compact and non-compact states, all provider types, per-license pricing with no monthly retainer. Book a 30-minute call or write to sales@directshifts.com.