The map of multi-state medical practice has changed more in the past two years than in the previous two decades. Licensure compacts — cooperative agreements between states that allow clinicians to practice across borders with reduced administrative burden — have expanded significantly, with new member states, new compact categories, and new rules coming into effect throughout 2024 and 2025.
For locum clinicians, the implications are substantial. States that were previously inaccessible without months-long licensing processes are now reachable in days or weeks. For facilities, particularly those in rural or underserved markets, the pool of compactly licensed providers has grown large enough to meaningfully change staffing calculus.
But compacts don't eliminate complexity — they redistribute it. Understanding what's changed, what it applies to, and where friction still exists is essential for clinicians planning their geographic strategy and for facilities trying to forecast recruitment options.
This is the current state of licensure compacts in 2025, and what it means in practice.
What Licensure Compacts Actually Do
Before getting into 2025 changes, it's worth being precise about what compacts do and don't do — because the terminology gets loose in ways that create real confusion.
Licensure compacts do not create a single national license. Each compact state still issues its own license under that state's medical practice act. What compacts do is streamline the application process for clinicians who are already licensed in a member state, allowing expedited processing of additional state licenses without repeating the full credentialing and investigation cycle from scratch.
The practical effect: a physician who might wait 90–120 days for a de novo state license application in some states can receive a compact-facilitated license in the same state in 10–30 days, with reduced administrative burden and often lower cost.
The key distinctions:
- Compact eligibility is separate from compact member state status. A state being a member of a compact doesn't mean every clinician in that state is automatically eligible — each clinician must still qualify individually.
- Primary state of licensure matters. Most compacts require the clinician to designate a "home" or principal license state, and that designation affects eligibility rules.
- Scope of practice is still governed by each individual state. A compact doesn't harmonize what you're allowed to do once you're practicing — that's still determined by the state where you're working.
With that foundation, here's where each major compact stands entering 2025.
The Interstate Medical Licensure Compact (IMLC): Now Covering Most of the Country
The IMLC is the most mature and widely adopted physician licensure compact. It covers MD and DO physicians and osteopathic physicians (with some subspecialty exceptions), and its footprint has expanded steadily since its 2015 launch.
Membership Growth Through 2025
By early 2025, the IMLC had crossed 40 participating member states and territories, representing the majority of the U.S. physician workforce and a significant share of the locum tenens market. Several states that had been holdouts — including some with large populations and significant physician demand — joined or advanced legislation through 2024–2025, substantially expanding coverage.
The geographic effect is meaningful. For a physician holding a principal license in a long-standing member state, the option to obtain compact-facilitated licenses now covers a large proportion of the country, including many of the markets with the highest demand for locum coverage.
How the IMLC Process Works in Practice
A physician seeking IMLC licenses applies through the Interstate Medical Licensure Compact Commission portal. The process requires:
Eligibility determination: The physician must meet the compact's eligibility criteria — active, unrestricted license in a member state; no current board investigations; no criminal history disqualifiers; board certification or ACGME-accredited residency completion in the relevant specialty; graduate of an accredited medical school.
State selection: The physician identifies which member states they want to obtain licenses in through the compact process.
Fee payment: Each member state charges its own licensing fee. The compact doesn't bundle or reduce state fees — it streamlines the process, not the cost structure.
Application processing: The Compact Commission communicates verification to each selected member state. The states issue licenses on their normal schedules, but without requiring independent re-verification of credentials the Commission has already confirmed.
Timeline in practice: physicians who have their documentation organized and meet eligibility requirements typically see compact-facilitated licenses issued within 2–4 weeks per state, compared to 8–16+ weeks for independent applications in many states.
What's Changed in 2025
The most significant 2025 development isn't membership expansion per se — it's the maturation of the verification infrastructure. The Compact Commission has invested in real-time data sharing with state medical boards, meaning license issuance and disciplinary action reporting has become more reliable and faster.
For locum clinicians, this matters because:
- License verification at new facilities is more consistent, since state board data is more current
- Renewal tracking is more systematic — the Commission now provides proactive renewal reminders tied to member state expiration schedules
- Some states have streamlined their internal processing specifically for compact applications, creating different (faster) internal queues for IMLC submissions
The practical upside: a physician with compact licenses in multiple states can now realistically maintain and renew that portfolio with significantly less administrative effort than was required even two years ago.
IMLC Limitations That Still Apply
The IMLC doesn't cover everything. Common areas where it doesn't help:
- Subspecialty restrictions: Some states have compact carve-outs for specific subspecialties or practice settings. Physicians in pathology, radiology, and certain telehealth-only practices should verify coverage before relying on compact processing.
- Physician assistant (PA) coverage: The IMLC covers MDs and DOs; physician assistants are covered under a separate compact (PA Licensure Compact, discussed below).
- DEA registration: Multi-state DEA registration is separate from state licensing and must be obtained independently for each state where the physician will prescribe. This remains a meaningful friction point for multi-state practice.
- Hospital privileging: Compact licensure doesn't substitute for facility credentialing and privileging. A physician with a compact-facilitated license still needs to complete each facility's privileging process before practicing there.
The Nurse Licensure Compact (NLC): The Most Established Multi-State Nursing License
The NLC predates the IMLC by more than a decade. It operates differently than physician compacts in one important way: instead of expediting the application for individual state licenses, the NLC issues a single multistate license to eligible nurses that allows them to practice in all member states.
NLC Coverage in 2025
The NLC had approximately 42 member states entering 2025, making it the compact with the widest geographic reach. For RNs and LPNs/LVNs practicing across state lines — including those doing travel nursing, locum per-diem shifts, or telehealth — the NLC multistate license represents the most operationally simple solution to multi-state practice.
The multistate license is obtained through the nurse's primary state of residence. If that state is a member of the NLC, the nurse receives a license that is valid across all member states simultaneously.
What Changed for NLC in 2025
The NLC's 2025 changes are primarily around:
Criminal background check standardization: The NLC compact rules require FBI criminal background checks for new multistate licenses issued after a specified date. The rollout of this requirement has been phased across states, and as of 2025, most member states are fully implementing the standardized background check process. For nurses, this means the background check process is more uniform — and the results are recognized across the compact rather than requiring state-by-state repetition.
Enforcement coordination: The NLC has expanded its investigation and discipline coordination infrastructure, meaning disciplinary actions in one compact state are now more systematically reported and recognized across the compact. This is a compliance consideration for facilities relying on compact-licensed nurses — a disciplinary action that previously might have gone undetected across state lines is now more likely to be visible.
Telehealth nursing clarifications: Several states have issued updated guidance on how NLC licensure applies to telehealth nursing practice, clarifying that a nurse practicing telehealth is subject to the rules of the state where the patient is located, not where the nurse is physically situated. This has significant implications for telehealth-heavy staffing models.
NLC for Locum and Flexible Nursing Practice
The NLC multistate license is particularly valuable for nurses working in locum or flexible capacity because:
- No per-state application required (the multistate license covers all compact states)
- License maintenance is centralized through the primary state
- Facilities in NLC states can credential NLC-licensed nurses with a single license verification rather than requiring individual state licenses
The primary limitation: nurses must maintain their primary residence in an NLC member state to hold a multistate license. Nurses who relocate to a non-compact state lose their multistate license and must obtain individual state licenses for the non-compact state and any other states where they wish to work.
The APRN Compact: The Newest and Most Consequential Change for 2025
If there's a single licensure development in 2025 with the greatest long-term impact on the locum and flexible staffing market, it's the activation and early expansion of the Advanced Practice Registered Nurse Compact.
Background
APRNs — nurse practitioners, certified registered nurse anesthetists, clinical nurse specialists, and certified nurse midwives — have historically been among the most complex categories to manage in multi-state practice. Each state has its own APRN scope of practice rules, prescriptive authority frameworks, and licensure requirements. A nurse practitioner wanting to practice across even two or three states has traditionally faced a significantly more complex licensing challenge than an RN operating under the NLC.
The APRN Compact was designed to address this, allowing compact-eligible APRNs to obtain a multistate privilege to practice across member states, similar in structure to the NLC model for RNs.
Where Things Stand in 2025
The APRN Compact reached activation threshold (sufficient member states to implement) and began issuing compact privileges in 2024. As of 2025, the compact is operational in its initial member states with additional states actively advancing enabling legislation.
The significance for the locum market cannot be overstated: nurse practitioners and other APRNs are among the fastest-growing segments of the flexible healthcare workforce. Rural hospitals, urgent care networks, and telehealth platforms have increasingly relied on NP coverage for primary care, urgent care, and specialty support. The administrative friction around multi-state NP licensing has been one of the most consistent complaints from both NPs trying to work broadly and facilities trying to hire them.
The APRN Compact's activation materially lowers that barrier.
Practical Implications for APRN Locum Practice
For NPs and other APRNs considering or already practicing in locum capacity:
Access to compact states becomes streamlined: Rather than filing separate applications in each state, eligible APRNs can obtain compact privileges through their primary state and practice across member states without additional full-application processes.
Prescriptive authority still varies: The APRN Compact facilitates compact privileges, but prescriptive authority rules — including controlled substance prescribing — remain state-specific and are not fully harmonized by the compact. This is a meaningful nuance: an NP can have a compact privilege to practice in a state but still face state-specific restrictions on what they can prescribe or under what supervisory arrangement.
Supervision requirements differ: Some compact member states maintain physician oversight or collaboration requirements for APRN practice that differ from other states. Compact membership doesn't standardize these — it standardizes the license/privilege pathway.
Coverage is growing but not universal: The APRN Compact is in early expansion as of 2025. Clinicians and facilities should verify current member state lists directly, since they will continue to change as additional states ratify participation.
The PA Licensure Compact (PALC): Physician Assistants Gain Ground
Physician assistants have historically had even fewer multi-state practice options than physicians or nurses. State PA licensing requirements vary significantly, and there was no analog to the IMLC for PAs until the PA Licensure Compact was developed and began activating.
2025 Status
The PALC has been activating with an expanding member state list. As of 2025, the compact is operational in its founding member states with additional states advancing legislation.
For PA-staffed locum positions — which are particularly common in surgical and specialty support roles — the PALC creates the same kind of streamlined multi-state access the IMLC provides for physicians. A PA with a compact privilege can practice in member states without filing full independent applications in each.
The practical constraints that apply to the IMLC apply here as well: DEA registration remains per-state, facility privileging still happens independently, and scope of practice is still governed by individual state law.
Telehealth Practice Across State Lines: Where Compacts Matter Most
The post-COVID normalization of telehealth has made multi-state licensure more operationally critical for a broader range of clinicians than ever before. State licensure compacts have become a significant factor in how telehealth-heavy practices and platforms staff and operate.
The Core Rule
The baseline legal position is clear: a clinician practicing telehealth is subject to the licensing requirements of the state where the patient is located — not where the clinician is physically sitting. This was true before COVID, was temporarily suspended under public health emergency waivers in many states, and reasserted itself as those waivers expired.
For telehealth-based locum practice, this means:
- A physician conducting telemedicine visits for patients in 10 different states needs to be licensed in all 10 states
- An NP holding telehealth NP sessions for patients in states where they don't hold a compact privilege is practicing unlicensed in those states
- The patient location, not the platform location or the clinician location, determines which state's laws apply
How Compacts Help With Telehealth
This is exactly the friction point where compacts create the most value. A physician holding IMLC-facilitated licenses in 12 member states can see telehealth patients in all 12 states legally. Without the compact, obtaining 12 state licenses independently would take a year or more and significant expense.
The IMLC, NLC, and APRN Compact all include telehealth practice within their scope — a compact privilege or compact-facilitated license covers telehealth practice in that state, not just in-person practice.
Some states have also developed telehealth-specific registration categories — lighter-weight alternatives to full licensure for clinicians doing only telehealth who don't intend to do in-person practice in that state. These are not part of the compact frameworks, but they represent a parallel pathway that can be useful where compact membership hasn't yet extended.
What Facilities Running Telehealth Programs Should Know
Facilities operating telehealth programs or supplementing in-person care with telehealth coverage need to ensure their coverage staff holds appropriate licensure for every state where patient encounters occur. This seems obvious but is a common compliance gap — particularly when telehealth programs expand to serve patients in new states without corresponding license verification.
Compact licensure doesn't change the underlying requirement; it makes it more feasible to meet. Facilities should:
- Track patient encounter states alongside clinician license inventories
- Verify compact privileges and individual state licenses are current before scheduling
- Build license expiration tracking into credentialing workflows (as opposed to treating it as a one-time check at onboarding)
What This Means for Locum Clinician Strategy
The expanding compact landscape changes the calculus for clinicians structuring multi-state locum practice. Here's how to think about it strategically.
Build Your Primary License Carefully
Your primary license state — the home state for compact purposes — matters. It affects:
- Which compacts you can participate in (some compacts require the primary state to be a member)
- How straightforward your ongoing maintenance will be
- The specific eligibility rules that apply to your compact licenses
If you're early in building your locum practice and don't have strong geographic roots, it's worth considering primary licensure in a state that is a member of the relevant compacts for your profession, has favorable processing times, has reasonable ongoing maintenance requirements, and has reciprocity or recognition arrangements you care about.
This isn't a decision to optimize past the point of return — you can always add licenses in non-compact states later. But your principal license state does have downstream effects worth thinking through.
Map Your Target Markets Against Compact Coverage
Before investing in a multi-state license portfolio, match your geographic targets to current compact member state lists. For physician locum practice:
- IMLC members now cover most of the country, but not all
- States that are not IMLC members require independent full applications, with all associated timeline and cost implications
- Some high-demand markets — specific urban medical centers, critical access hospitals, specialty facilities — may be in non-compact states or may have state-specific licensing requirements that don't align with standard timelines
Building a realistic timeline for license acquisition is essential for avoiding gaps in assignment availability. Clinicians who wait until they have an assignment confirmed in a new state to begin licensing typically face 60–120 day delays. The right model is proactive licensing — obtaining licenses in target states before you need them, not in response to an offer.
Keep Your Credentialing Documentation Current
Compact processing relies on the verification infrastructure being accurate and current. That means your documentation — primary source verification, board certifications, DEA registrations, malpractice history, medical education transcripts — needs to be current and accessible.
The most common source of IMLC application delay isn't the Compact Commission's processing time; it's incomplete or outdated documentation submitted by the applicant. Clinicians with currency in their document portfolio clear compact applications faster than clinicians who need to chase down expired or missing records mid-application.
As covered in 5 Credentialing Bottlenecks That Delay Locum Placements, documentation gaps are the primary driver of placement delays — and this applies equally to the compact context.
Understand DEA Registration as a Separate Requirement
DEA registration doesn't follow compact rules. If you need controlled substance prescribing authority in multiple states, you need separate DEA state registrations for each one. There has been ongoing regulatory development around a proposed DEA Special Registration for telemedicine prescribing that would simplify this somewhat for telehealth-specific prescribing, but as of 2025 this remains a parallel process from state licensing.
For multi-state locum practice involving any prescribing, the DEA registration portfolio is a distinct planning element from the state licensing portfolio.
What This Means for Facilities
The compact expansion changes recruitment and compliance dynamics for healthcare facilities. The impact depends on your setting, patient population, and staffing model.
Expanded Addressable Pool for Compact-Member State Facilities
If your facility is in an IMLC member state, you now have access to a larger pool of physicians who can be compact-licensed in your state relatively quickly. This is most significant for:
- Rural facilities that have historically struggled to attract locum coverage because the licensing burden relative to assignment length deterred physicians from obtaining licenses
- Critical access hospitals needing flexible coverage in short windows where long licensing timelines made locum sourcing impractical
- Telehealth programs expanding to reach patients in new service areas
The expansion of the APRN Compact is particularly relevant for facilities relying on NP coverage — the most constrained piece of the locum puzzle in many markets.
Multi-State Systems Gain Coordination Flexibility
Health systems operating across multiple states benefit from compact expansion in a specific way: clinicians who are already in your network and hold licenses in one state can now be credentialed at your facilities in other compact-member states with significantly less lag. This enables:
- Flexible deployment of clinical staff across system facilities in response to volume variation
- Contingency coverage arrangements that don't require anticipating licensing needs months in advance
- More rapid onboarding of clinicians who have worked with the system in other markets
For large health systems with multi-state footprints, the compact landscape makes internal redeployment a more practical tool.
Compliance Responsibilities Don't Change
Compact licensure simplifies the acquisition pathway for clinicians, but it doesn't relax facilities' verification obligations. Facilities are still required to:
- Verify active, unrestricted licensure in the applicable state before permitting practice
- Complete facility-level credentialing and privileging processes
- Monitor for disciplinary actions and license changes through primary source or monitoring services
- Track license expiration and require timely renewal
Compact-facilitated licenses are real state licenses subject to the same verification requirements as independently obtained licenses. The compact changes how the license was obtained; it doesn't change what the facility needs to confirm.
Where compact membership does simplify facility-side processes is in the reliability of primary source verification — NLC and IMLC both have enhanced data sharing with state boards that can make verification faster and more reliable than contacting individual state boards directly.
Understand the Non-Compact States in Your Market
If you operate in or near a state that is not yet a member of the relevant compact, you need to plan around independent licensing timelines for those positions. The compact expansion has been substantial, but there are still meaningful gaps — states with large populations or significant healthcare activity that are not yet in the compact framework.
For facilities in non-compact states, the operational implication is straightforward: longer licensing timelines mean earlier starts to the recruitment process for positions requiring out-of-state clinicians. If your facility is non-compact and you're sourcing locum coverage from clinicians who will need to obtain a new license in your state, build 90–120 days of licensing runway into your planning.
Remaining Friction Points and What's Still Being Worked Out
The compact expansion is real and consequential, but it doesn't resolve every challenge in multi-state locum practice. Here's where friction still exists.
Scope of Practice Variation Persists
Compacts facilitate licensure portability. They do not harmonize what clinicians are authorized to do once licensed. Scope of practice variation — particularly significant for APRNs and PAs — remains a state-by-state reality.
A nurse practitioner with APRN Compact privileges in multiple states may face:
- Full practice authority (practice independently without physician oversight) in some states
- Reduced practice authority (some form of physician collaboration agreement required) in others
- Restricted practice authority (more extensive physician supervision requirements) in still others
This variation doesn't change with compact membership. For facilities hiring NPs, this means verifying applicable scope rules in the practice state regardless of whether the NP holds a compact privilege. For NPs themselves, it means that obtaining compact privileges doesn't resolve the question of what you're legally authorized to do — that's still state-specific.
Malpractice Insurance Needs Multi-State Attention
Multi-state compact licensing raises corresponding questions about malpractice insurance. Policies need to cover practice in each state where the clinician practices. For clinicians building a multi-state compact portfolio, reviewing policy coverage geography is a necessary step — and something that often gets delayed until after an assignment is booked rather than in advance.
Tail coverage considerations also apply: if a clinician practiced in multiple states under compact licenses, claims arising from any of those states need to be covered. Working with a broker familiar with locum and multi-state practice malpractice structures is advisable for clinicians with broad multi-state portfolios.
DEA Registration Remains Fragmented
Noted above, but worth reiterating: DEA registration has not kept pace with the compact model. Multi-state prescribing authority still requires separate registrations in each state, the DEA special registration framework for telehealth prescribing has been in development with a complicated regulatory history, and the administrative burden of managing multiple DEA registrations is substantial.
For locum clinicians who prescribe — which is virtually all physicians and most APRNs — DEA registration management is the piece of multi-state compliance infrastructure that remains least resolved by the current compact framework.
Compact Member States Are Still Growing
The compact landscape as of early 2025 is better than it's ever been and worse than it will be. States continue to advance enabling legislation. Compacts that are newly activated (APRN Compact, PALC) will continue adding member states through 2025 and beyond.
The implication: a geographic target that requires independent full licensing today may be compact-accessible in 12–18 months. Clinicians building long-term multi-state practices should track legislative progress in their target states, particularly for the APRN Compact and PALC, which are in earlier expansion phases.
How Platform Infrastructure Is Responding
For locum clinicians and facilities navigating this landscape, the operational complexity of managing multi-compact, multi-state license portfolios has created demand for platform-level support that wasn't as critical when multi-state licensing was less common.
Modern locum staffing platforms are building infrastructure to:
- Track clinician license status across multiple states with expiration alerts
- Automate license verification at point of match (rather than requiring manual verification for each placement)
- Maintain visibility into compact eligibility status for clinicians in the network
- Flag scope-of-practice variations at the point of assignment matching so that facilities and clinicians are working from accurate information
The administrative overhead of multi-state practice hasn't disappeared with compact expansion — it's been redistributed toward platforms that can handle it systematically rather than leaving it to clinicians and facilities to manage manually.
If you're evaluating locum platforms, the sophistication of their license tracking and compact-eligibility infrastructure is a meaningful differentiator — particularly if you're building a practice that spans multiple states or if your facility is operating across a multi-state health system.
Getting Started With Compact Licensure: Practical Steps
For clinicians who want to take advantage of the expanded compact landscape, here's a practical starting sequence.
For Physicians (IMLC)
Verify your eligibility: Review the IMLC eligibility criteria on the Compact Commission's website. Key requirements are an active, unrestricted license in a member state; no pending investigations or disciplinary history; board certification; accredited medical education.
Confirm your principal state: Identify your primary license state. If you're licensed in multiple states and one is an IMLC member while others are not, the IMLC application would be filed through the member state.
Organize your documentation: Primary source documents (board certification letters, medical school diplomas/transcripts, DEA registrations, malpractice history letters) should be current and accessible. Gaps in documentation are the primary source of application delays.
Select your target states: Choose which member states to add through the compact process. You're not limited in quantity, but each adds a fee.
Submit and track: The Compact Commission portal provides status tracking for applications in progress.
For RNs and LPNs (NLC)
Determine your primary state of residence: If you live in an NLC member state, you can apply for a multistate license through that state's board of nursing. If you live in a non-compact state, you need individual state licenses for each state where you want to practice.
Apply for the multistate license: Through your primary state board of nursing. The process is similar to applying for a single state license but results in a multistate privilege.
Understand the residency-based rule: If you move to a non-compact state, your multistate license is affected. Track this proactively if your living situation may change.
For NPs and APRNs (APRN Compact)
Check current member states: The APRN Compact is in active expansion as of 2025. Verify which states are currently members and which are in progress.
Determine your primary APRN license state: Compact privileges flow from your principal license.
Review scope of practice rules in target states: Obtaining compact privileges doesn't substitute for knowing the applicable scope rules in each state where you'll practice.
Looking Ahead: The Compact Landscape in 2026 and Beyond
The trajectory of the compact movement is toward broader participation and more streamlined infrastructure, not away from it. Several factors are accelerating this:
Workforce shortage pressure: The continued shortage of physicians and APRNs in underserved areas creates political and economic pressure for states to remove unnecessary barriers to clinical deployment. Compact membership increasingly frames as a workforce development measure rather than just an administrative convenience.
Telehealth normalization: Telehealth practice now represents a meaningful portion of clinical activity, and multi-state licensure is the only legal pathway to telehealth practice across state lines. States without compact membership face economic pressure from telehealth providers who route their operations through states with simpler licensing pathways.
DEA registration reform: The ongoing discussion around telehealth prescribing and multi-state DEA registration has not yet resolved, but the pressure to simplify this continues. A Special Registration pathway for telehealth prescribing — if implemented — would remove the most significant remaining administrative fragmentation in multi-state practice.
For clinicians building locum careers and facilities designing flexible staffing models, the direction of travel is clear. The question isn't whether multi-state practice will become more accessible — it's how quickly the remaining barriers will fall and whether your practice or your facility is positioned to take advantage of the access expansion as it arrives.
Understanding how to navigate this landscape is part of what Locum Tenens 101 covers for clinicians earlier in their exploration of flexible practice. And for a realistic picture of what locum assignments actually look like once you're in them — including the logistics of being new to a state — What to Expect During Your First Locum Tenens Assignment covers the ground-level experience in detail.
The compact expansion is the most significant structural change to multi-state clinical practice in years. Getting ahead of it — building the license portfolio, understanding the rules, structuring your practice or your staffing model to take advantage of the access it creates — is one of the clearest opportunities in locum medicine right now.
Rediworks helps clinicians track and manage multi-state license portfolios and matches them with facilities looking for compactly licensed providers. If you're building a multi-state locum practice or sourcing clinical coverage across state lines, the platform is built for exactly this kind of complexity.