Woes Continue for Those Seeking Multistate Medical Licenses

Andrew N. Wilner, MD


March 08, 2019

In the United States, medical licensure falls under the purview of state law. Consequently, private practice physicians who wish to treat patients in more than one state must obtain multiple state licenses.

Unfortunately, physicians must struggle with an archaic, byzantine licensing process. An application may require a citizenship statement, education and training verifications, fingerprinting for an FBI criminal background check, an in-person interview, notarized documents, passport-sized photographs, proof of board certification, a report from the National Practitioner Data Bank, and a response to confidential inquiries regarding one's mental and physical health, as well as hefty fees. Medical boards may demand all of these requirements even if the physician is already licensed in another state and performing without censure.

Communication with medical boards to clarify requirements or check an application's status can be agonizingly slow. For example, I recently waited a month to receive an email response from one state board. A model of efficiency is the Florida medical board, which proudly proclaims that it returns phone calls within 24 hours and emails within a week. The licensing process may drag on for weeks to months, potentially delaying employment, depriving patients of medical care, and derailing careers.

Medical license renewals require much less effort. However, reinstating an expired license may require starting from scratch with an entirely new application. I suffered that fate when I discovered that my Massachusetts license renewal was only 2 days overdue! Because of the difficulty in obtaining a new license, many physicians reluctantly pay renewal fees for unused licenses, just in case they need them in the future.

No Guarantee

State medical boards wield enormous discretion regarding the issuance of a medical license. Even highly qualified physicians have no guarantee that a state will grant them a license. For instance, on its medical license application, the Arizona Medical Board reminds physicians, "A license to practice medicine in Arizona is a privilege, not a right. Please do not assume that licensure is a mere formality or that granting of a license is automatic."

Because the state board holds all the cards, applicants must comply with every request, no matter how unreasonable or redundant. Similarly, physicians must tolerate bureaucratic delays without complaint, for fear of jeopardizing the process. In the past, when physicians tended to put down roots in one location, they submitted to this ordeal only once or twice during their careers.

Radical Changes in Medical Practice

Three radical changes in medical practice have increased the necessity for physicians to carry multiple state licenses. The first is the growing acceptance of telemedicine, where doctors provide medical care via audio or video chat. Telemedicine has proven cost-effective, particularly in Midwestern states, where physical distance between physicians and patients can obstruct medical care.

To practice telemedicine, doctors must possess a medical license not only in their home state but in each state where they serve patients. Consequently, a telemedicine doctor may require a half-dozen, dozen, or even more state licenses.

The second significant change is the unprecedented increase in physicians' professional mobility. Until 2016, more than half of physicians owned their practices. Ownership obligated doctors to establish themselves in their communities. Today, clinics and hospitals employ an increasing number of physicians. Standard employee contracts bind physicians for only a year or two. Such brief arrangements do little to instill loyalty and facilitate job impermanence.

Finally, more physicians than ever practice locum tenens. These physicians take temporary assignments in different locations to supplement (moonlighting) or even replace (full-time locums) their regular jobs. Because these assignments may be anywhere in the country, locum tenens physicians must carry several licenses if they are to be eligible for upcoming opportunities in different states.

The Interstate Medical Licensure Compact

You may have heard of the new Interstate Medical Licensure Compact (IMLC), which falls short of true license reciprocity but does facilitate the process of obtaining an additional state license in some cases. The IMLC began to issue letters of qualification in April 2017.

Participation in IMLC is not open to all physicians. To benefit from IMLC, a physician must already hold a license in one of the 24 IMLC member states. Eligibility requires that a physician fulfill a long list of requirements. Here are some of them:

  • Pass the US Medical Licensing Examination or Comprehensive Osteopathic Medical Licensing Examination within three attempts;

  • Successfully complete graduate medical education;

  • Hold specialty certification by the American Board of Medical Specialties or the American Osteopathic Association's Bureau of Osteopathic Specialists;

  • Possess a full and unrestricted medical license by a member state;

  • Has never been convicted, received adjudication, deferred adjudication, received community supervision, or deferred disposition for any offense by a court of appropriate jurisdiction;

  • Has never held a license authorizing the practice of medicine subjected to discipline by a licensing agency in any state, federal, or foreign jurisdiction, excluding any action related to nonpayment of fees related to a license;

  • Has never had a controlled substance license or permit suspended or revoked by a state or the US Drug Enforcement Administration; and

  • Is not under active investigation by a licensing agency or law enforcement authority in any state, federal, or foreign jurisdiction.

An IMLC application requires a fee of $700 in addition to the state medical license fee. Although this is a step in the right direction, the IMLC falls short of the inherent simplicity of a single federal medical license.


An increasing number of physicians need more than one state medical license to deliver patient care. This change in practice pattern has resulted from the growth of telemedicine, the decline of physician practice ownership, and the increased demand for locum tenens doctors by hospitals and clinics.

Cumbersome state licensing impedes the flexibility of the physician workforce. The IMLC is a great idea that has not realized its promise. Nonetheless, physicians licensed in one of the 24 IMLC member states who require an additional state license should consider this service. More information is available at

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