One of the biggest misconceptions we run into when onboarding telehealth providers is the assumption that because they're not physically in another state, they don't need to be licensed there. I understand the logic. But it's wrong — and the consequences of getting this wrong can be serious.
We've handled telehealth credentialing for over a hundred providers across all kinds of specialties — psychiatry, primary care, behavioral health, dermatology. Here's what we've actually learned from working in the trenches on this, not just reading the regulations.
🌐 The fundamental rule of telehealth licensure: You must be licensed in the state where the patient is located at the time of service — not where you are sitting. If your patient is in Florida and you're in New York, you need an active Florida medical license for that visit to be legal and billable.
What This Means Practically
If you see telehealth patients across 8 states, you need active medical licenses in all 8 of those states. And then you need to be separately credentialed with each state's payers. So a provider who was credentialed with BCBS of North Carolina is not automatically credentialed with BCBS of Florida. They are separate payer relationships with separate re-credentialing cycles.
We had a psychiatrist come to us who had been seeing patients in 6 states via telehealth for nearly a year. She had a license in 3 of those states. The other 3 she was seeing patients in were states where she simply had no license at all. Technically, every one of those visits was unlicensed practice — which is both a billing compliance issue and a medical board issue. Sorting that out was a months-long project.
The IMLC: The Shortcut That Actually Works
The Interstate Medical Licensure Compact (IMLC) is a genuine game-changer for multi-state telehealth if you qualify. If your home state participates in the compact and you meet the eligibility criteria, you can get expedited licenses in other member states without going through the full application process in each one individually.
As of 2025, 40+ states participate in the IMLC for physicians. There are also separate compacts for nurses (NLC), PAs, and other professions. The IMLC won't work for everyone — you need certain qualifications and your primary state of practice must be a member — but for providers who do qualify, we've gotten multi-state licensure done in as little as 30–45 days through the compact vs. 90–120 days doing it state by state.
Payer Credentialing Is Still State-By-State
Even if the IMLC rapidlly gets you licensed across multiple states, you still have to go through the credentialing process with payers in each state's market. A "national" insurer like UnitedHealthcare still has state-specific provider networks. Being enrolled with UHC in Texas does not mean you're enrolled with UHC in Pennsylvania — those are separate enrollment applications, separate timelines, and separate relationships.
This is the part telehealth providers most consistently under-estimate. You can be licensed iin 10 states in relatively short order using the IMLC. But then you still need to credential with each payer in each of those 10 states. Depending on your specialty and payer mix, that could be 40 to 80 separate applications.
The Checklist for Setting Up a Multi-State Telehealth Practice
- Map your patient states. Every state where patients will be located needs a license. This isn't optional.
- Check IMLC eligibility first. It could save you months. Go to imlcc.org to verify whether your states participate and if you qualify.
- Get DEA registration right. DEA registration is also often state-specific for controlled substance prescribing. The MATE Act changed some requirements — confirm what applies to your specialty.
- Update CAQH with all states. Your CAQH ProView profile needs to reflect every active state license. This is what payers pull when they credential you in new markets.
- Build a market-by-market credentialing plan. Prioritize payers by patient volume in each state and submit in parallel where possible.
Telehealth Credentialing Across Multiple States Is Our Specialty
We've done this over 100 times. We know which states move fast, which payers have telehealth-specific panels, and how to run multiple state credentialing projects in parallel to get you billing faster. Let's talk about your specific footprint.
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