# IMLC states in 2026: the full Interstate Medical Licensure Compact list

Source: https://myorbithealth.com/compliance/imlc-states

As of October 2026, 44 states plus the District of Columbia participate in the Interstate Medical Licensure Compact (IMLC), and 6 states do not: California, Massachusetts, New York, Oregon, South Carolina and Virginia. The compact is an expedited application route for physicians (MD and DO) who already hold a full license in a member state. It is not a single national license. Each member state still issues its own license and charges its own fee. Nurse practitioners and physician assistants are not covered; their compacts are separate and, as of October 2026, neither is issuing privileges. The lists below are computed from the same 51-row dataset that powers our state compliance report, dated October 5, 2026. This is general information, not legal advice.

## What the IMLC is, and what it is not

The Interstate Medical Licensure Compact Commission (imlcc.com) describes the compact as a voluntary, expedited pathway to licensure for qualified physicians who want to practice in several states. Operators tend to hear 'compact' and assume 'one license.' That is the wrong mental model, and it leads to bad launch plans.

- **It is separate state licenses, issued faster** — A physician completes one application through the Commission and receives separate licenses from each member state selected. The IMLCC FAQ is explicit that physicians do not receive a compact license or a nationally recognized medical license. Every state license still renews on that state's cycle, carries that state's CME rules, and is disciplined by that state's board.
- **It starts with a state of principal license** — The physician picks a state of principal license (SPL): a member state where they already hold a full license and where they live, practice, work, or file federal taxes. The SPL board verifies eligibility and issues a letter of qualification (LOQ). The LOQ is valid for 365 days. During that year the physician can add states for a request fee plus each state's licensing fee. Per the IMLCC, the base participation cost is $700 plus the cost of each state license.
- **It is MD and DO only, with a clean record** — Eligibility per the IMLCC FAQ: an accredited medical school, ACGME or AOA accredited graduate training, current ABMS or AOABOS board certification, each USMLE or COMLEX component passed within three attempts, and no history of disciplinary action on a medical license. A physician with any license discipline uses the standard path in each state. And the compact changes how a license is obtained, not the rule that the physician must be licensed where the patient is at the time of the visit.

## The 45 IMLC member jurisdictions (44 states plus DC)

Alphabetical. The value column is each jurisdiction's out-of-state telehealth registration status from our dataset, because a compact license is one route into a state and a registration pathway, where one exists, is the other. imlcc.com reported 44 member states, DC and Guam as of September 30, 2026, with Alaska, New Mexico and Rhode Island still implementing and Hawaii and Vermont issuing non-SPL licenses only. Our dataset matches that count.

- **Alabama:** Limited (full license required; exception only for irregular practice (fewer than 10 days or 10 patients per year) or consultation)
- **Alaska:** Limited (out-of-state physician may provide ongoing or follow-up care to established patients only; no general registration)
- **Arizona:** Yes (out-of-state telehealth provider registration with the applicable regulatory board (A.R.S. 36-3606))
- **Arkansas:** No (full Arkansas license required; consultation exceptions only)
- **Colorado:** Yes (out-of-state telehealth provider registration with the applicable regulator, effective January 1, 2026)
- **Connecticut:** No (temporary telehealth registration for out-of-state behavioral health providers expired June 30, 2025; full license required)
- **Delaware:** Yes (interstate telehealth registration from the Division of Professional Regulation for providers licensed in non-compact states)
- **District of Columbia:** Unverified (FSMB (Sept 2024) marks DC as requiring registration; CCHP (Aug 2026) shows only limited-period and consultation exceptions; verify with DC Health)
- **Florida:** Yes (out-of-state telehealth provider registration (Fla. Stat. 456.47); no in-person care or office in Florida)
- **Georgia:** Yes (telemedicine license for physicians licensed in another state (O.C.G.A. 43-34-31.1); telemedicine only)
- **Hawaii:** No (full license required; consultation with a Hawaii-licensed physician only)
- **Idaho:** Limited (license exemptions for established patient relationships, follow-up, and qualifying out-of-state mental or behavioral health providers)
- **Illinois:** Limited (temporary permit tied to a sponsoring entity (225 ILCS 60/49.5), scheduled for repeal January 1, 2027; otherwise full license)
- **Indiana:** No (telehealth certification for out-of-state practitioners terminated July 1, 2024; Indiana license required)
- **Iowa:** No (full Iowa license required; consultation exception only)
- **Kansas:** Yes (telemedicine waiver from the Board of Healing Arts, issued within 15 days of a complete application, fee up to $100)
- **Kentucky:** No (Kentucky license or compact privilege required; consultation exceptions only)
- **Louisiana:** Yes (telemedicine permit (a limited license) from the Louisiana State Board of Medical Examiners)
- **Maine:** Limited (interstate telehealth registration covers consultative services only ($500 fee); full license for direct care)
- **Maryland:** No (full license required; consultation and narrow statutory exceptions only)
- **Michigan:** No (full license required; exceptional-circumstance consultation and border exceptions only)
- **Minnesota:** Yes (annual interstate telehealth registration with the Board of Medical Practice; no office or in-person visits in Minnesota)
- **Mississippi:** Yes (license to practice medicine across state lines (telemedicine) from the State Board of Medical Licensure)
- **Missouri:** No (full license required; informal or episodic consultation exceptions only)
- **Montana:** No (full license required; occasional-case exception only)
- **Nebraska:** No (full license required; consultation exception only)
- **Nevada:** Yes (telemedicine license issued under NRS 630.261 to physicians licensed in another state)
- **New Hampshire:** No (full license required; consultation and border-physician exceptions only)
- **New Jersey:** No (full New Jersey license, certification or registration required)
- **New Mexico:** Yes (telemedicine license from the New Mexico Medical Board (an expedited full license is also offered))
- **North Carolina:** No (full license required; unlicensed out-of-state practice is a Class I felony)
- **North Dakota:** Limited (exemption for continuity of care with established patients of an out-of-state physician)
- **Ohio:** Limited (one-year follow-up exemption for established patients and a border exemption; otherwise full license)
- **Oklahoma:** Limited (special and temporary licenses exist but are not telehealth-specific; full license generally required)
- **Pennsylvania:** Limited (extraterritorial license for physicians practicing in adjoining states near the border; no general telehealth registration)
- **Rhode Island:** No (full license required; narrow exceptions (federal service, air ambulance, seven-day consultation))
- **South Dakota:** No (full license required, or employment by a licensed facility)
- **Tennessee:** No (full Tennessee license required)
- **Texas:** No (full Texas license required; out-of-state telemedicine license closed to new applicants since September 1, 2022)
- **Utah:** Limited (narrow exemptions only (noncommercial care; 45-day transitional mental health therapy))
- **Vermont:** Yes (interim telehealth registration with the Office of Professional Regulation; telehealth only)
- **Washington:** Limited (out-of-state practitioners allowed for consultation, specialty assessment or follow-up with established patients temporarily in state)
- **West Virginia:** Yes (interstate telehealth registration; no practice from a physical location in the state)
- **Wisconsin:** Limited (temporary credential tied to a health care employer while a permanent credential application is pending)
- **Wyoming:** No (full license required; consultation up to 12 days per year)

## The 6 non-member states and what to do there

These 6 states are not in the compact: California, Massachusetts, New York, Oregon, South Carolina and Virginia. Together they hold a large share of the US population, so most national brands cannot skip them. Here is the practical route in each.

- **California:** Full California license, no registration pathway, only narrow consultation and emergency exceptions. Route California patients to a provider who is already licensed there.
- **Massachusetts:** Full license required; the Board of Registration in Medicine says there is no special telemedicine license. Contract providers already licensed in the state.
- **New York:** Full licensure and registration required; the only exception is occasional consultation. New York has introduced IMLC legislation per imlcc.com, but there is no shortcut until it passes.
- **Oregon:** The one non-member with an open door: a license to practice medicine across state lines under ORS 677.139, plus exemptions for established patients. A separate credential, not an IMLC letter.
- **South Carolina:** Full license required. The continuity-of-care exception covers established out-of-state specialty patients between in-person visits, which does not fit a new-patient telehealth funnel.
- **Virginia:** Full license required; the consultant exemption does not cover direct patient care. Virginia is in the PA Compact but not the IMLC, so MD/DO coverage still means a Virginia license.

## How the compact interacts with out-of-state telehealth registration

Registration pathways are a different tool. A state that offers one lets a physician licensed elsewhere register to deliver telehealth to its residents without a full license, usually telehealth-only with no office or in-person care in the state. Our dataset shows 14 such jurisdictions; 13 are also IMLC members and Oregon is the exception. Two cautions. Delaware's registration is written for providers licensed in non-compact states. And several registrations bar any physical presence, which matters if a brand later adds in-person exams. Decide per state whether the compact license (full scope, slower) or the registration (narrow scope, faster) fits the program.

- **Arizona:** Yes (out-of-state telehealth provider registration with the applicable regulatory board (A.R.S. 36-3606))
- **Colorado:** Yes (out-of-state telehealth provider registration with the applicable regulator, effective January 1, 2026)
- **Delaware:** Yes (interstate telehealth registration from the Division of Professional Regulation for providers licensed in non-compact states)
- **Florida:** Yes (out-of-state telehealth provider registration (Fla. Stat. 456.47); no in-person care or office in Florida)
- **Georgia:** Yes (telemedicine license for physicians licensed in another state (O.C.G.A. 43-34-31.1); telemedicine only)
- **Kansas:** Yes (telemedicine waiver from the Board of Healing Arts, issued within 15 days of a complete application, fee up to $100)
- **Louisiana:** Yes (telemedicine permit (a limited license) from the Louisiana State Board of Medical Examiners)
- **Minnesota:** Yes (annual interstate telehealth registration with the Board of Medical Practice; no office or in-person visits in Minnesota)
- **Mississippi:** Yes (license to practice medicine across state lines (telemedicine) from the State Board of Medical Licensure)
- **Nevada:** Yes (telemedicine license issued under NRS 630.261 to physicians licensed in another state)
- **New Mexico:** Yes (telemedicine license from the New Mexico Medical Board (an expedited full license is also offered))
- **Oregon:** Yes (license to practice medicine across state lines (ORS 677.139); exemptions for established patients)
- **Vermont:** Yes (interim telehealth registration with the Office of Professional Regulation; telehealth only)
- **West Virginia:** Yes (interstate telehealth registration; no practice from a physical location in the state)

## NP and PA coverage: the APRN and PA compacts are not live

The IMLC does nothing for nurse practitioners or physician assistants. Each has its own compact, and as of October 2026 neither issues a usable multistate privilege.

- **PA Licensure Compact** — pacompact.org lists 29 member states as of October 2026: Alabama, Alaska, Arizona, Arkansas, Colorado, Connecticut, Delaware, Iowa, Kansas, Maine, Michigan, Minnesota, Missouri, Montana, Nebraska, New Hampshire, New Jersey, North Carolina, North Dakota, Ohio, Oklahoma, Rhode Island, South Dakota, Tennessee, Utah, Virginia, Washington, West Virginia and Wisconsin. The seven-state activation threshold was met in April 2024, but the Commission is still building its data system and projects granting compact privileges in early 2027. Until then a PA needs a full license in every state where patients are located.
- **APRN Compact** — NCSBN news releases confirm 4 enacting states: Delaware, North Dakota, South Dakota and Utah. The compact needs seven to activate, so it is not in force, and NCSBN said at its 2026 APRN Roundtable that it is redesigning the compact. aprncompact.com publishes no member list; secondary sources that count five or more states could not be confirmed and are not used here. NP coverage is still a state-by-state licensing exercise.
- **What that means for a launch plan** — If your clinical model leans on NPs or PAs, the compact headlines do not shorten your timeline. The question is whether your provider partner already holds the licenses. The companion hub on NP practice authority covers the scope-of-practice side.

## How MyOrbitHealth covers all 50 states without you chasing LOQs

MyOrbitHealth is a technology company; it does not practice medicine. The medical layer is delivered by licensed providers under an MSO and friendly-PC structure, and licensing is their problem to hold, not yours.

- **Network built for the state map** — The Provider Network has 2,400+ board-certified MD, DO, NP and PA providers across 38+ specialties and all 50 states, with live availability and intelligent load balancing so a visit is routed only to a provider licensed where the patient is. Average response is under six minutes during business hours, with 24-hour visit availability.
- **Credentialing you can audit** — Every provider goes through NCQA-standard primary-source credentialing with monthly OIG and SAM exclusion screening. Malpractice coverage is occurrence-based with $1 million per occurrence and $6 million aggregate limits. Bring-your-own-providers is supported if you already have clinicians under contract.
- **Compliance stack behind it** — HIPAA compliant with a BAA in every contract, SOC 2 Type II, EPCS with two-factor identity proofing, and a LegitScript-certified pharmacy network shipping to all 50 states. 50+ digital clinics run on the platform. Check any state at /tools/state-legality-checker, or see /provider-network.

## FAQ

### How many states are in the IMLC in 2026?
44 states plus the District of Columbia per our October 2026 dataset, which matches imlcc.com's count of 44 member states, DC and Guam as of September 30, 2026. The 6 non-members are California, Massachusetts, New York, Oregon, South Carolina and Virginia.

### Is an IMLC license a national license?
No. The IMLCC FAQ states that physicians receive separate licenses from each state and that there is no compact license or nationally recognized medical license. The compact speeds the application; it does not merge the licenses.

### What is a letter of qualification?
It is the document your state of principal license issues after verifying you meet the compact's eligibility criteria. It is valid for 365 days, and you use it to request licenses from other member states during that year.

### Can nurse practitioners or physician assistants use the IMLC?
No. The IMLC is for MD and DO physicians only. The PA Licensure Compact has 29 member states per pacompact.org but projects issuing privileges in early 2027. The APRN Compact has 4 enacting states per NCSBN and needs seven to activate.

### Which states let an out-of-state physician register for telehealth without a full license?
Our dataset lists 14: Arizona, Colorado, Delaware, Florida, Georgia, Kansas, Louisiana, Minnesota, Mississippi, Nevada, New Mexico, Oregon, Vermont and West Virginia. Most are telehealth-only with no physical presence allowed.

### Does the compact make Texas or Florida easier?
Both are IMLC members. Florida also has a telehealth registration under Fla. Stat. 456.47. Texas closed its out-of-state telemedicine license to new applicants in September 2022, so Texas is compact or full license only.

### Does MyOrbitHealth get my physicians licensed through the compact?
No. MyOrbitHealth supplies providers who already hold the licenses, through its 2,400+ provider network covering all 50 states. Bring-your-own providers keep their own licenses and are credentialed to the same standard.

## Launch in every state your customers live in

Skip the LOQ spreadsheet. MyOrbitHealth's provider network already covers all 50 states, with NCQA-standard credentialing and a compliance stack you can hand to your lawyer. Book a call at https://myorbithealth.com/book or review the network at /provider-network.

Book a call: https://myorbithealth.com/book

Go deeper: [Telehealth licensing by state: the full 2026 map](https://myorbithealth.com/blog/telehealth-licensing-by-state), [How to find a 50-state physician network](https://myorbithealth.com/blog/find-50-state-physician-network), [State telehealth compliance report 2026: the 51-jurisdiction dataset](https://myorbithealth.com/blog/state-telehealth-compliance-report-2026), [Collaborating physician agreements explained](https://myorbithealth.com/blog/collaborating-physician)

_General information, not legal or medical advice._

_Source: https://myorbithealth.com/compliance/imlc-states_