NALTO Multiview Briefing #1 — Interstate Licensure Compact
Key Facts About the Interstate Medical Licensure Compact

In early October, a bipartisan group of U.S. senators endorsed the Interstate Medical Licensure Compact. In a letter to the Federation of State Medical Boards (FSMB), the lawmakers stated, “As strong supporters of the state-based system of physician licensure, we believe the Compact represents a significant step forward in the licensure of physicians and we applaud the work of the FSMB and its member boards in this area.”

The senators are just the latest group to endorse the Compact. The licensure model that enables physicians to move swiftly between participating states certainly has been piqued the interest of the locum tenens industry.

Compact Overview

In September 2014, FSMB, a national group representing individual state medical boards, released its final model of the Interstate Medical Licensure Compact, an agreement between state medical and osteopathic boards to accept each other’s licenses as equivalent of their own. Shortly thereafter bills to adopt the Compact were passed by state governments. In fact, on earlier this month, Wisconsin became the 12th state to ratify the Compact, and many more boards have endorsed it with hopes their legislatures also will vote to enact the Compact.

With a quarter of the country now involved with the Interstate Medical Licensure Compact, it behooves locum tenens companies to review the key components.

• The Compact does not change states’ existing Medical Practice Acts. Even though legislation is required to officially adopt the Compact, each state’s Medical Practice Act, which grants licenses to practice medicine within its borders, remains unaltered. That means each state medical board retains oversight authority as it pertains to patient protections and physician accountability. This applies to any doctor practicing medicine in the state, including locum tenens providers.
• Participating medical boards retain disciplinary authority. Because medical boards maintain their authority, they have the power to investigate complaints registered against any physician practicing within its state, including those who hold Compact licenses. The boards issue disciplinary action based on its rules and regulations. However, each Compact member agrees to share all findings and sanctions levied against physicians with all other Compact states.
• Physicians must obtain a Compact license in their home state. Industry estimates state that approximately 80% of licensed physicians in the United States could be eligible for Compact licensure. In order to take advantage of its mobility, physicians must meet a litany of qualifications, starting with the fact that a principal —or “home state” — license must be issued by a Compact member. A home state is defined as the state in which 25% of a physician’s practice takes place, or location of employer, or official residence as noted for federal taxes. Keep mind, locum tenens physicians are not employees of their staffing companies, so location of a locum tenens agency does not affect home state definition.

Additionally, physicians must provide verification of the following:

• Graduate of accredited medical school
• Passed USMLE or COMLEX
• ABMS specialty certification or a time-unlimited specialty certificate
• Full AND unrestricted medical license issued by a Compact member state medical board
• They have never been convicted, received adjudication, deferred adjudication, community

supervision or deferred disposition for any offense by a court of appropriate jurisdiction

• No discipline on any state medical license
• No discipline related to a controlled-substance license
• Not under active investigation by any licensing agency

Plus, physicians are required to adhere to all renewal and CME requirements issued by their home state.

Many, if not all, of these criteria are typically verified by locum tenens companies as a result of the credentialing process.

Participation in the Compact is voluntary.
If individuals prefer to follow the traditional route of a single state license, that’s still an option in every state regardless of Compact membership. However, if a single-state license-holder wishes to accept locum tenens opportunities in other states, then he or she must apply for and obtain that state’s license.

Also, the Compact license is only accepted in other Compact states. If providers agree to locum tenens contracts in non-Compact states, they must obtain that specific license.

Further Appeal
Since its debut, the Compact has accumulated numerous supporters, including:

• American Medical Association
• American Osteopathic Association
• American College of Physicians
• American Academy of Family Physicians
• American Academy of Pediatrics
• American Academy of Neurology

Proponents insist the Compact benefits facilities and patients, too. The greater mobility of physicians between member states may allow for clinicians to reach underserved communities in a more streamlined fashion. The Compact also might encourage locum tenens professionals to accept assignments in locations they previously may not have considered due to the additional licensing burden. For that matter, the Compact could be a deciding factor to encourage doctors to try locum tenens, especially if a prolonged license application process is perceived as a deterrent.

As legislatures reconvene in 2016, there’s potential for more states to join the Compact—as of midDecember, eight have bills pending. And, further expansion means greater flexibility, which is always a benefit to the locum tenens industry.