Medicine and the Law

The Interstate Medical Licensure Compact Commission

Expanding your practice opportunities

BY Marschall S. Smith

Minnesota physicians represent about 300 of the applications and 2,000 licenses—placing the Minnesota Board of Medical Practice squarely in the middle, volume wise, of the 39 member states processing applications. Information published by the Federation of State Medical Boards indicated that nationally about five percent to seven percent of all licensed physicians in the United States hold licenses and practice in more than one state. So far, the Compact’s processing numbers indicate that, on average, about two percent of those physicians used the Compact process to obtain those multiple licenses. The processing information in Minnesota is reflective of these national trends. The Compact is generally a word-of-mouth organization, but we are working on a promotional video to provide information to hospital groups and physician organizations who can spread the word, driving the participation number up with the hope of doubling over the course of the next two to three years.

How it Works

The IMLCC became a legal organization when, on April 15, 2015, the Governor of Alabama signed legislation authorizing establishment of the IMLCC in that state. With this action, Alabama became the seventh state to authorize the IMLCC, creating a legal threshold that made it possible for the implementation of the IMLCC to proceed. The 39 member jurisdictions are made up of 37 states, one territory and the District of Columbia. The remaining 13 states and three territories are in various stages of the joining process. There are currently three states with active legislation. And there has been interest expressed by six states and one territory about joining the Compact in the upcoming legislative season. We are actively working with medical boards, physician associations, hospital groups and patient advocacy organizations to close the loop with full participation.

Generally, all requested licenses are issued in seven to ten days.

The key to the process is to establish eligibility. The first step is for a physician to establish a State of Principal License or SPL. The physician must hold a full, unrestricted license issued by the SPL, and either live or work in the SPL. This is the key to the expedited nature of the Compact process. The SPL has already gathered and holds the primary sourced information for the static data elements required by all member boards, i.e., medical school attended, USLME/COMPLEX attempts, GME training dates and completion information, etc. A physician using the Compact process must always maintain an SPL, and there are processes to change or “Redesignate” the SPL that can be done at any time without cost after the Letter of Qualification has been issued. Changing an SPL does not impact the Letter of Qualification.

The next step is to pre-qualify yourself. There are nine questions asked that will be verified by a primary source by the SPL. The detailed descriptions and requirements are found on the Compact webpage, in the educational videos and in the on-line application. A summary of these nine elements is:

• Graduated from an accredited medical school. 
• Successfully completed ACGME or AOA accredited graduate medical education.
• Passed each component of the USMLE or COMLEX-USA in no more than 3 three attempts for each component.
• Hold board a current ABMS or AOABOS board certification.
• Have no disciplinary actions reported to the National Practitioner Data Bank (NPDB).
• A clean criminal history.
• Have no actions taken against your controlled substance permission/license.
• Not have any current or pending board investigations.
• Submit to a fingerprint-based FBI background check.



There is a non-refundable application fee of $700.00 to apply for the Compact process. The application fee is used to operationalize the single online application process and is quickly recouped by the ability to start work quicker. Additionally, it is more cost effective than applying for two or more state licenses when the costs related to obtaining the primary source data for each application are required by each state when using the traditional method.

This first step generally takes about 30 to 45 days, with the majority of the processing time taken experienced in obtaining the results from the FBI fingerprint-based background check.

Generally, all requested licenses are issued in seven to ten days.

The Next Steps

Once the SPL has finalized its eligibility determination, the physician is notified via email that a Letter of Qualification has been issued. About 9% of applications are determined not to meet the eligibility requirements, with the most common reasons being not holding a current active board certification or still in residency. The physician logs back into their account, selects the states from which they wish to obtain a license and pays the licensing fee owed for that license (as determined by each state). Generally, all requested licenses are issued in seven to ten days. The Letter of Qualification is valid for 365 days, which can be used at any time to obtain additional licenses. The result is that a physician can obtain and hold 1 to 38 licenses, with a single on-line application, in 37 to 55 days on average (processing times vary and depend on application completeness and member boards).

The cost for a license from a state varies from state to state and board to board. The cost to obtain a full unrestricted license is the same whether it is through the Compact or traditional path. In the “About” tab on the Compact’s webpage, a list of the license costs by state are detailed, with a range of $60.00 to a high of $817. The Nevada DO board has suspended license fees for 12 months starting in July 2022, so the cost for a license from that state is a nominal $0.01, which is refunded shortly after the license is obtained. The cost for renewals is not listed, as not all states have standardized renewal fees; however, the cost is the same as for traditionally obtained licenses.

The top five specialties of physicians using the Compact process are: Internal Medicine, Family Medicine, Psychiatry and Neurology, Radiology and Emergency Medicine. Internal Medicine represents about 30% of the specialties. The number of physicians who use the Compact fall into three broad groups that are about equal in number: Locum Tenens physicians, telemedicine physicians and physicians extending their practice to a nearby state or region. The most recent example of Compact process usage is found in situations where patients in need of highly specialized care or complex conditions can now more readily receive coordinated post-treatment care with their local physician working remotely with their out-of-state treating physicians licensed in the state where the patient resides. This helps the patient avoid costly travel expenses and increases the quality of care as it is coordinated rather than handed off.

States who have joined the Compact have experienced an average of 10% to 15% increase in their physician workforce. Patients in rural, frontier and medically underserved areas benefit by increasing the pool of available physicians through telemedicine provided by a physician licensed in their state. Hospitals in rural and frontier areas are able to keep their doors open and even expand hours due to the increased number of licensed physicians, many of whom can provide those services remotely.  

Inside the IMLCC Numbers