Under the Interstate Medical Licensure Compact, as Washington enacted it in chapter 18.71B RCW, the physician files the application for an expedited license and the principal-state board evaluates it. The health system runs everything around that filing: who qualifies, which licenses each physician holds, when each renews and what happens to all of them if one board acts. Integral Healthcare Solutions (IHS) drafts that operating workflow for a health system or telehealth group. IHS does not prepare or file a physician's application.
IHS is a consulting firm, not a law firm.
Last updated: November 2026
What is Interstate Medical Licensure Compact operations?
Compact operations is the internal program a health system builds to decide which physicians take the Compact route, track every license each one holds, and keep renewals, continuing education and credentialing in line.
The governing text is Chapter 18.71B RCW, Interstate Medical Licensure Compact (page opened 2026-11-05), Washington's enactment. IHS opened that chapter only, not the interstate commission's rules or any other state's enactment, so each statement here is limited to the Washington text, and another state's enactment may differ.
The Compact "creates another pathway for licensure and does not otherwise change a state's existing medical practice act" (18.71B.010). It also affirms that the practice of medicine occurs where the patient is located at the time of the physician-patient encounter (18.71B.010). A member state issuing an expedited license may impose a fee for a license issued or renewed through the Compact (18.71B.060(1)). The physician carries the application and the health system carries the tracking; that split is IHS's reading of 18.71B.050(1), an inference from the text.
Who qualifies for the expedited route?
A physician must meet the requirements in the definition of "physician" in 18.71B.020(11) to receive an expedited license (18.71B.030(1)). All nine must hold. In IHS's words, summarized:
- A graduate of a medical school accredited by the Liaison Committee on Medical Education or the Commission on Osteopathic College Accreditation, or listed in the International Medical Education Directory or its equivalent.
- Passed each USMLE or COMLEX-USA component within three attempts, or a predecessor examination that a state medical board accepts as equivalent.
- Completed graduate medical education approved by the Accreditation Council for Graduate Medical Education or the American Osteopathic Association.
- Holds specialty certification, or a time-unlimited specialty certificate, recognized by the American Board of Medical Specialties or the American Osteopathic Association Bureau of Osteopathic Specialists.
- Holds a full and unrestricted license issued by a member board.
- Has never been convicted, or received adjudication, deferred adjudication, community supervision or deferred disposition, for any offense (a felony, gross misdemeanor or crime of moral turpitude) by a court of appropriate jurisdiction.
- Has never held a medical license subjected to discipline by a licensing agency in any state, federal or foreign jurisdiction, excluding an 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 Drug Enforcement Administration.
- Is not under active investigation by a licensing agency or law enforcement authority in any jurisdiction.
Under 18.71B.030(2) a physician who falls short may obtain a license in a member state by complying with all laws and requirements, other than the Compact, that govern licensure in that state.
How does a physician pick the state of principal license?
Under 18.71B.040(1) a physician designates a member state in which the physician holds a full and unrestricted license, and that state must be one of four. It is the state of primary residence; or the state where at least twenty-five percent of the practice of medicine occurs; or the location of the physician's employer; or, only if none of those three qualifies, the state designated as the state of residence for federal income tax purposes. A physician may redesignate at any time as long as the new state meets the same tests (18.71B.040(2)).
The facts change when a physician moves, changes employers or shifts patient volume. Under 18.71B.050(6) an expedited license is terminated if the physician fails to maintain a license in the state of principal licensure for a nondisciplinary reason without redesignating, so the tracker must hold the facts behind each designation.
What happens after filing, and why does one board's action reach all licenses?
The principal-state board evaluates eligibility and sends the interstate commission a letter of qualification verifying or denying it (18.71B.050(2)). It performs a criminal background check that includes fingerprint or other biometric results compliant with Federal Bureau of Investigation requirements, with the exception of federal employees who have a suitability determination (18.71B.050(2)(b)). An eligibility appeal goes to the state where the application was filed and is subject to that state's laws (18.71B.050(2)(c)). Eligible physicians then register with the interstate commission and pay applicable fees, and each selected member board issues a license consistent with its own medical practice act (18.71B.050(3) and (4)).
Discipline travels under 18.71B.100:
- Any disciplinary action by a member board against a physician licensed through the Compact is deemed unprofessional conduct that other member boards may act on (18.71B.100(1)).
- If the principal-state license is revoked, surrendered in lieu of discipline or suspended, every license issued through member boards automatically takes the same status, and reinstatement at the principal state leaves the others encumbered until each board acts (18.71B.100(2)).
- If any member-board license is revoked, surrendered in lieu of discipline or suspended, the physician's other member-board licenses are suspended automatically for ninety days upon entry of the disciplining board's order, though a board may end its own suspension early (18.71B.100(4)).
Member boards must also report to the interstate commission any public action or complaint against a physician who has applied for or received an expedited license (18.71B.080(2)).
Who needs it and what triggers it
- A health system or telehealth group adds physicians who see patients in several states. Each patient state counts, because practice occurs where the patient is located.
- Renewal dates diverge, because an expedited license is valid for a period consistent with that member state's licensure period (18.71B.050(5)).
- The system uses the Compact route for some physicians and standard licensure for others and needs a written rule for the choice.
How IHS helps
Thomas G. Goddard, JD, PhD, IHS founder and former URAC Chief Operating Officer and General Counsel, leads the work. This is Program Development, one of three IHS practice lines with Accreditation Consulting and Compliance Services, because the system builds a new internal process. For the counselor version, see Counseling Compact operations.
The process
- Gap assessment. IHS reads how your medical staff office tracks licenses and renewals today and ties each step to the Washington text.
- Drafting. IHS drafts an eligibility pre-screen on the nine criteria, a principal-state worksheet, a multistate license tracker design, a renewal and continuing education procedure, a board-action response procedure, medical staff office roles and a handoff to credentialing.
- Mock review. IHS tests the workflow on sample physician files.
What you supply
You supply your physician roster, patient-location data, current license tracker, credentialing and payer enrollment process, medical staff office roles and counsel's review of telemedicine laws.
The real limit
IHS does not apply for any physician, does not contact state boards or the interstate commission and does not give licensure advice.
What to have ready
Gather these before the first session; each ties to chapter 18.71B RCW as read on 2026-11-05.
- A roster of physicians with every state in which each one sees patients, since practice occurs where the patient is located (18.71B.010).
- Your current license tracker, with issue and renewal dates by state.
- Counsel's written summary of the nine eligibility criteria in 18.71B.020(11).
- For each physician, the facts for naming a state of principal license: primary residence, where at least twenty-five percent of practice occurs, employer location and, last, federal income tax residence (18.71B.040(1)).
- Physicians who will use standard licensure instead (18.71B.030(2)).
- The continuing education record for each license (18.71B.070(2)).
- Your process for learning of a board action and removing a physician from the schedule (18.71B.100).
- The tracker owner in the medical staff office.
With the list in hand, the free introductory call is where IHS walks through it with you.
How it compares
A health system can license a physician through the Compact or through a state's ordinary process.
Standard state licensure is the alternative for a physician who does not meet the Compact criteria (18.71B.030(2)).
The Compact adds a route and removes none, so a system can run both and needs one tracker that holds each.
What it costs
Three costs apply. First, the Washington text says a member state issuing an expedited license may impose a fee for a license issued or renewed through the Compact, and that the interstate commission collects renewal fees and distributes them to the member board (18.71B.060 and 18.71B.070). The chapter states no amounts, and IHS did not open a fee schedule. Verify current fees with each board and the interstate commission.
Second, IHS scopes each engagement after a free introductory call, based on the number of physicians and states and how far your current tracker is from the workflow.
Third, your own staff time and counsel time.
What this is not
- It is not legal or licensure advice. IHS is a consulting firm, not a law firm.
- It is not a physician application. IHS does not prepare or file one and does not decide whether a physician is eligible.
- It is not a guarantee that any board will issue or renew a license.
Frequently asked questions
What is the Interstate Medical Licensure Compact?
In the Washington enactment, chapter 18.71B RCW, the Compact "creates another pathway for licensure and does not otherwise change a state's existing medical practice act" (18.71B.010).
Who is eligible for an expedited license?
A physician must meet all nine criteria in 18.71B.020(11), including passing each USMLE or COMLEX-USA component within three attempts, a full and unrestricted license, no conviction or deferred disposition for a felony, gross misdemeanor or crime of moral turpitude, no disciplined license (a fee-nonpayment action is excluded) and no active investigation. Counsel confirms each result.
What is the state of principal license?
It is the member state a physician designates, where the physician holds a full and unrestricted license. It must be the state of primary residence, the state where at least twenty-five percent of practice occurs, or the employer's location; only if none qualifies, the state of residence for federal income tax (18.71B.040(1)).
Who files the application?
The physician files with the member board of the state selected as the state of principal license (18.71B.050(1)). That board evaluates eligibility and issues a letter of qualification to the interstate commission. The text names the physician as the filer. IHS does not prepare or file applications.
Where does the practice of medicine occur?
The Washington text affirms that it occurs where the patient is located at the time of the physician-patient encounter (18.71B.010). The chapter does not address state telemedicine laws, which counsel reviews.
How do renewals work?
A physician renews through the interstate commission if all four conditions in 18.71B.070(1) hold: a full and unrestricted license in the state of principal license, and no conviction, no discipline (a fee-nonpayment action is excluded) and no controlled-substance suspension or revocation as listed there. Each license's continuing education requirements also apply. The commission collects renewal fees and distributes them to the member board, which then renews the license (18.71B.070(2) to (4)).
What happens to every license if one is disciplined?
If the principal-state license is revoked, surrendered in lieu of discipline or suspended, all member-board licenses automatically take the same status (18.71B.100(2)). If any member-board license is revoked, surrendered in lieu of discipline or suspended, the other licenses are suspended automatically for ninety days upon entry of the disciplining board's order (18.71B.100(4)).
Does the Compact replace credentialing and payer enrollment?
On IHS's reading as of 2026-11-05, no. The chapter concerns licensure, so credentialing, privileging and payer enrollment stay separate steps that depend on a license. Counsel confirms the reading.