February 2026 Legal Intelligencer article by Lamb McErlane attorneys Vasilios J. Kalogredis, Esq. and Sonal Parekh, Esq.

Interstate licensure compacts have rapidly transformed the regulatory landscape governing multistate health care practice. Long viewed as aspirational solutions to workforce shortages and telehealth expansion, these compacts now operate as practical licensing pathways in Pennsylvania following a multi-year legislative and regulatory rollout culminating in full implementation of several compacts on July 7, 2025.

Pennsylvania is now a full participant in three major licensure compacts—covering physicians, nurses, and physical therapists—while earlier participation in PSYPACT remains active for psychologists. These developments materially affect credentialing strategy, telehealth expansion, staffing models, and transactional diligence. Health care attorneys must understand not only which compacts apply, but also the distinct legal mechanics each compact employs – particularly, the critical difference between multistate licensure and expedited state-by-state licensure.

I. Overview

Interstate licensure compacts are statutorily enacted agreements among member states that create coordinated pathways for licensed professionals to practice across jurisdictional lines while preserving each state’s sovereign regulatory authority. They are designed to “streamline the application process” so qualified professionals can demonstrate they meet licensing requirements in multiple states without repeating the full traditional licensure process. Importantly, compacts do not federalize licensure. Each participating state continues to issue and regulate licenses (or privileges), and disciplinary authority remains state-based.

II. Current Pennsylvania Compact Participation as of February 2026.

On July 7, 2025, Pennsylvania became a full participant in the following three compacts: (i) the Interstate Medical Licensure Compact (IMLC) relating to physicians (MDs and DOs); (ii) the Nurse Licensure Compact (NLC) relating to registered nurses (RNs) and licensed practical nurses (LPNs); and (iii) the Physical Therapy Compact (“PT Compact”) relating to physical therapists (PTs) and physical therapist assistants (PTAs). These compacts allow these types of clinicians in Pennsylvania to seek authorization to practice in over 30 states (depending on the profession and compact membership). Pennsylvania regulators implemented the compacts specifically to reduce licensing delays and address workforce shortages by allowing qualified practitioners to begin working as soon as within days, as opposed to after several months. Additionally, the Psychology Interjurisdictional Compact (PSYPACT) was fully implemented in Pennsylvania in 2020, allowing psychologists to obtain telepsychology authority and temporary in-person practice privileges across participating states.

III. Compact-by-Compact Legal Structure.

The IMLC provides an expedited pathway to obtain multiple individual state licenses. Pursuant to the IMLC process, the Physician would designate a State of Principal Licensure (SPL) and obtain a Letter of Qualification. The IMLC would then verify eligibility and transmit credentials to requested member states. Each member state would then issue its own license on an expedited basis. Importantly, the IMLC does not provide a single multistate license. Physicians must still obtain and pay for each state license separately. Physician applicants are still required to satisfy all state-law prerequisites, including education on child-abuse reporting and opioid prescribing.

The NLC, on the other hand, creates a true multistate license. According to the NLC process, the nurse would declare a Primary State of Residence and that state would then issue one multistate license which is recognized by all compact states. This license permits practice (including telehealth) in all NLC jurisdictions without the necessity of obtaining additional licenses. The NLC is the only Pennsylvania compact currently offering automatic cross-border authority without additional licensure applications.

The PT Compact grants “practice privileges” in other member states tied to the physical therapist’s (or physical therapist assistant’s) home-state license. Here, the licensee maintains a home-state license and applies through the PT Compact for authorization to practice in additional states. This creates a hybrid model – neither a single license nor full relicensure – but an authorization layered onto the home license.

The PSYPACT, which was implemented in 2020, allows telepsychology across state lines and temporary in-person practice authority (“TAP”) in participating states. The PSYPACT is structured around interjurisdictional practice certificates as opposed to traditional licensure portability.

IV, Common Misconceptions.

Health care clients frequently misunderstand compact participation. Accordingly, health care attorneys or attorneys counseling health care clients should ensure that clients understand the following.

1. Compacts do not create a national license (although the NLC does create a multistate license). States retain authority to issue licenses or privileges individually.
2. Even under expedited models, physicians must still pay for licensing fees for each requested state.
3. Pennsylvania may impose additional training or compliance obligations before granting licensure. All state-specific requirements remain enforceable.
4. Each compact uses a different regulatory model and, therefore, are not a “one-size-fits-all” process for licensure.
   1. The IMLC provides for expedited individual licenses.
   2. The NLC provides for a single multistate license.
   3. The PT Compact provides for practice privilege tied to a home license.
   4. The PSYPACT provides authority to practice telehealth and TAP.

V. Key Considerations and Impacts of Compact Participation.

As of 2026, Pennsylvania has transitioned from a historically non-portable licensure jurisdiction to an active participant in multiple interstate licensure frameworks. The Commonwealth’s full implementation of the PSYPACT, IMLC, NLC, and PT Compact creates meaningful opportunities for cross-border practice, but only when carefully navigated within each compact’s unique legal architecture.

For health care attorneys, the operative question is no longer whether Pennsylvania participates in licensure compacts, but rather how each compact’s distinct structure affects compliance, reimbursement and operational risk.

Accordingly, attorneys should keep in mind how compact participation may affect client operations and transactions. Set forth below are some key takeaways and considerations to keep in mind when counseling health care clients.

1. 1. Determining which compact model applies is crucial before rendering advice on multistate expansion.
   2. Attorneys should not assume that portability is the same as licensure. As stated previously, not all compacts grant licenses.
   3. Clients should budget for multi-state licensing costs even when utilizing compact pathways.
   4. Compacts materially reduce barriers to multistate telehealth expansion but do not eliminate jurisdiction-specific compliance obligations (such as supervision, prescribing rules, scope-of-practice variance, continued education requirements, etc.).
   5. Because some compacts issue separate licenses, organizations must still enroll providers with payors per state and monitor renewal cycles individually. Credentialing should be reviewed separately from licensure authority.
   6. Compact participation can affect geographic revenue modeling, provider contracting scope, and representations regarding licensure portability.
   7. Because some compacts require state-level approval, premature practice can constitute unlicensed practice despite compact eligibility.
   8. Attorneys should monitor Pennsylvania implementation guidance as compact participation continues to evolve administratively.

If you have any questions relative to compact participation or if we may be of further assistance regarding other health law matters, please feel free to contact Bill Kalogredis, Esq. or Sonal Parekh, Esq.

Read online in the Legal Intelligencer here.

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Vasilios J. (Bill) Kalogredis, Esq. has been advising physicians, dentists, and other healthcare professionals and their businesses as to contractual, regulatory and transactional matters for over 50 years. He is Chairman of Lamb McErlane PC’s Health Law Department. Bill can be reached by email at bkalogredis@lambmcerlane.com or by phone at 610-701-4402.

Sonal Parekh, Esq., is an associate at Lamb McErlane PC who focuses on healthcare transactional matters and a broad range of healthcare regulatory-related issues on behalf of healthcare systems, physicians, dentists, and other healthcare providers, and is a pharmacist by education and training. Sonal can be reached by email at sparekh@lambmcerlane.com or by phone at 610-701-4416.

*This article is for educational purposes only and is not intended to be legal advice. Should you require legal advice on this topic, any health care matter, or have any questions or concerns, please contact Vasilios J. (Bill) Kalogredis, Esq. or Sonal Parekh, Esq.