Telehealth Licensing Requirements by State (2026): IMLC, Registrations and DEA Rules

For physicians, NPs, PAs and practice owners offering telehealth across state lines. Updated October 22, 2026 · Prepared by Prospyr. Telehealth licensing follows the patient: in every state, a clinician generally needs a license (or a state-issued telehealth registration) from the state where the patient is physically located at the time of the visit, not the state where the clinician sits. The Center for Connected Health Policy puts it this way: telehealth "is considered to be rendered at the physical location of the patient, and therefore a provider typically needs to be licensed in the patient's state." There are three ways to meet that rule: a full license in each state, a faster license through an interstate compact such as the Interstate Medical Licensure Compact (44 member states plus DC and Guam as of September 30, 2026), or one of the limited telehealth registrations a handful of states offer. Prescribing controlled substances adds a federal layer: the DEA's telemedicine flexibilities run through December 31, 2026.

Every rule below links to the statute, regulation or official body it comes from, checked October 22, 2026. State telehealth law changes often, and limits differ by profession, so confirm with the licensing board in the patient's state, or a healthcare attorney, before you see patients there. This is not legal advice.

The rule: license where the patient is

State statutes say so directly. West Virginia's telehealth law states, "The practice of the health care service occurs where the patient is located at the time the telehealth services are provided" (W. Va. Code §30-1-26). California makes unlicensed practice on a patient in California a crime (Cal. Bus. & Prof. Code §2052), and allows out-of-state physicians only narrow exceptions such as consultation with a California-licensed practitioner (§2060).

In practice that means:

• Record the patient's location at every visit. A patient who lives in Texas but joins a video visit from Florida is a patient in Florida for that visit.
• Licensing is per profession. A physician compact license does not cover the NP or PA on the same visit; each clinician needs their own authority in the patient's state.
• Scope and prescribing rules follow the patient's state too. A license lets you practice there; the state's telehealth, consent, prescribing and supervision rules still apply.

Your options for practicing across state lines

Interstate Medical Licensure Compact (IMLC)

The IMLC is a faster pathway to full medical licenses in member states. It is not a single national license: "The Commission does not issue a 'Compact license'," and each state still issues its own (IMLC).

Members. The IMLC home page reports 44 member states plus 2 US territories (DC and Guam), information as of September 30, 2026:

• State of principal license (SPL) members, processing applications and issuing licenses (39 states, DC and Guam): Alabama, Arizona, Arkansas, Colorado, Connecticut, Delaware, Florida, Georgia, Idaho, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland, Michigan, Minnesota, Mississippi, Missouri, Montana, Nebraska, Nevada, New Hampshire, New Jersey, North Carolina, North Dakota, Ohio, Oklahoma, Pennsylvania, South Dakota, Tennessee, Texas, Utah, Washington, West Virginia, Wisconsin and Wyoming.
• Issuing licenses but not serving as an SPL (2): Hawaii and Vermont.
• Passed, implementation in process (3): Alaska, New Mexico and Rhode Island.
• Legislation introduced: New York.
• Not members: California, Massachusetts, Oregon, South Carolina and Virginia, among others. A physician treating patients in these states needs that state's own license.

Who qualifies. According to the IMLC, you must hold a full, unrestricted license in a member state that can serve as your state of principal license, and that state must be where you live, where at least 25% of your practice occurs, where your employer is located, or the state you use for federal income tax residence. You also need:

• graduation from an accredited medical school or one listed in the International Medical Education Directory;
• completion of ACGME- or AOA-accredited graduate medical education;
• passing scores on each component of the USMLE, COMLEX-USA or equivalent in no more than three attempts per component;
• current specialty certification (or time-unlimited certification) from an ABMS or AOABOS board;
• no discipline on any license, no criminal history, no controlled-substance actions, and no open investigation.

The IMLC says "Approximately 80% of U.S. physicians meet the criteria."

Cost. "The initial cost to participate in the Compact is $700.00 PLUS the cost of a license(s) in any Compact state where a physician wants to practice. All fees are non-refundable" (IMLC fees). State license fees through the Compact vary widely; the IMLC lists, for example, $75 for Alabama, $355 for a Florida MD license and $895 for Texas.

Nurses, NPs and PAs

• Nurse Licensure Compact. 43 jurisdictions have enacted the NLC, which lets RNs and LPN/VNs with a multistate license practice, including by telehealth, in other member states. It does not cover advanced practice registered nurses. Per the NLC map, implementation is still pending in Guam, Massachusetts and the US Virgin Islands.
• Nurse practitioners and other APRNs. The APRN Compact is not operating (NCSBN APRN Compact). An NP treating patients by telehealth needs an APRN license in each patient's state and must meet that state's collaboration or supervision rules.
• PA Licensure Compact. "As of August 28, 2026, there are 29 Compact Member States... No states are actively issuing privileges yet," and the Commission projects privileges "will be available in early 2027" (PA Compact). Until then, PAs need a license in each patient's state.
• Behavioral health. Psychologists have PSYPACT, and counselors have the Counseling Compact, which lists 11 states live for privileges. Check each compact's map for current members.

States with telehealth registrations or telehealth-only licenses

A few states let clinicians licensed elsewhere provide telehealth without a full license. Each one has eligibility rules, and most bar you from opening an office or seeing patients in person in the state.

Other states have telemedicine permits or limited licenses that we could confirm only through CCHP's summaries of the state rule, not on the board's own site, including Louisiana (telemedicine permit), Georgia (telemedicine license), New Mexico (telemedicine license) and Maine (consultative telemedicine registration). See the CCHP cross-state licensing tracker and check with the board before relying on them. Vermont's telehealth license and registration have been in statute pending rules, so confirm with the Vermont Office of Professional Regulation which pathway is open now.

Not an option in Texas. According to CCHP's summary of Texas rules, a physician may not provide telemedicine to patients in Texas without a full Texas license, except physicians who already held an out-of-state telemedicine license on September 1, 2022.

Common exceptions: consultation and follow-up care

Most states allow some telehealth without a local license, but the exceptions are narrow:

• Physician-to-physician consultation. The out-of-state physician advises a locally licensed clinician who keeps authority over the patient's care. Examples: Florida §456.47(6), Arizona §36-3606(E), Kansas 65-28,135(f) and California §2060.
• After-care for an in-person procedure. Arizona exempts "after-care specifically related to a medical procedure that was delivered in person in another state" (A.R.S. §36-3606(E)). This matters for plastic surgery practices whose patients travel for surgery and recover at home.
• Continuity of care. Several states, including Ohio, Virginia, Idaho and North Dakota, allow follow-up with an existing patient for a limited period, according to CCHP. The conditions (a prior in-person visit, the same condition, a time limit) differ by state.
• Emergencies and low volume. Florida exempts emergencies, and Arizona exempts providers with fewer than ten telehealth encounters in the state in a calendar year.

Prescribing controlled substances by telehealth: DEA rules for 2026

The DEA's COVID-era telemedicine flexibilities are still in force, but they are temporary. The Fourth Temporary Extension (90 FR 61301, December 31, 2025) "is effective January 1, 2026 through December 31, 2026." Through that date, DEA-registered practitioners may prescribe Schedule II to V controlled substances by telemedicine without a prior in-person evaluation, if the other conditions in the rule are met.

• What comes next. DEA proposed a special registration for telemedicine in January 2025 (90 FR 6541). As of October 22, 2026, the Federal Register shows no final special registration rule and no fifth extension. Plan for either outcome before January 1, 2027.
• Buprenorphine. A separate final rule allows an initial six-month supply of buprenorphine for opioid use disorder by telemedicine, including audio-only, after a review of the state prescription drug monitoring program (90 FR 6504). DEA delayed its effective date to December 31, 2025 (90 FR 13410).
• DEA registration in each state. DEA's registration Q&A states that "a DEA registration based on a State license cannot authorize controlled substance dispensing outside the State," and that a practitioner practicing in multiple states needs a separate registration in each. A practitioner registration for Schedules II to V costs $888 for three years (21 CFR 1301.13).
• State limits still apply. Florida, for example, bars telehealth prescribing of Schedule II drugs except for psychiatric disorders, hospital inpatients, hospice patients and nursing home residents (Fla. Stat. §456.47(2)(c)). Weight-loss, hormone and wellness programs should check both DEA and state rules for every controlled medication they prescribe.

Medicare telehealth

Separate from licensing, Medicare's location rules for telehealth are extended: "Through December 31, 2027, beneficiaries can receive Medicare telehealth services anywhere in the United States and territories," according to the CMS telehealth FAQ updated October 2026. This changes where Medicare pays for telehealth, not which license you need.

A checklist before you see patients in a new state

1. Confirm where patients will be during visits, and record the location at the start of each one.
2. Pick the pathway for each clinician: full license, IMLC, NLC, a state telehealth registration, or a statutory exception that truly fits.
3. Check the state's telehealth practice rules: consent, the standard of care, whether a prior in-person visit is required, and NP or PA supervision.
4. Register with the DEA and the state prescription monitoring program in each state where you will prescribe controlled substances.
5. Track renewals and CE for every license, registration and DEA registration.
6. Confirm malpractice coverage extends to patients in each state.

Where Prospyr fits

Prospyr is practice software for med spas, plastic surgery and wellness practices. Its telehealth visits run inside the same system as online booking, digital intake and consents, charting and e-prescribing, and multi-location support helps practices that operate in more than one state. Prospyr does not issue licenses or decide whether a clinician may treat a patient in a given state; that stays with your clinicians and counsel. For telehealth consent rules, see telehealth consent laws by state.

Frequently asked questions

Do you need a license in every state for telehealth?

Generally, you need authority to practice in each state where your patients are located during visits: a full license, a compact license or privilege, or a state telehealth registration. Narrow exceptions exist for consultation with a locally licensed clinician and, in some states, follow-up care.

Which states allow telehealth across state lines without a full license?

Arizona, Delaware, Florida, Kansas, Minnesota, Nevada, Oregon, Vermont and West Virginia have statutory telehealth registrations, waivers or telehealth-only licenses for clinicians licensed elsewhere, each with eligibility rules and limits. Several other states have telemedicine permits or limited licenses. None of them is automatic: you apply first.

What type of license do most states require for telemedicine across state lines?

A full, unrestricted license in the state where the patient is located. Physicians in IMLC member states can get those full licenses faster through the Compact, but each state still issues its own license.

How many states are in the Interstate Medical Licensure Compact?

The IMLC reports 44 member states plus DC and Guam as of September 30, 2026. Of those, 39 states, DC and Guam can serve as a state of principal license; Hawaii and Vermont issue licenses only; and Alaska, New Mexico and Rhode Island are still implementing.

Can nurse practitioners do telehealth across state lines?

Only with an APRN license in the patient's state. The Nurse Licensure Compact covers RNs and LPN/VNs, not APRNs, and the APRN Compact is not operating.

Can you prescribe controlled substances by telehealth in 2026?

Yes, under the DEA's temporary flexibilities, which run through December 31, 2026, provided you hold a DEA registration for the state and follow that state's prescribing rules. Watch the Federal Register for a further extension or a final special registration rule.

Sources

• Center for Connected Health Policy: cross-state licensing
• Interstate Medical Licensure Compact: home page and member map
• IMLC: information for physicians
• IMLC: what does it cost
• Nurse Licensure Compact
• Nurse Licensure Compact map (PDF)
• APRN Compact
• PA Licensure Compact: news
• PSYPACT
• Counseling Compact
• Arizona Revised Statutes §36-3606
• Delaware Code Title 24, Chapter 60
• Florida Statutes §456.47
• Kansas Statutes 65-28,135
• Minnesota Statutes §147.032
• Nevada Revised Statutes Chapter 630
• Oregon Revised Statutes Chapter 677
• Vermont Statutes 26 V.S.A. §3054
• West Virginia Code §30-1-26
• Vermont Office of Professional Regulation
• California Business and Professions Code §2052
• California Business and Professions Code §2060
• DEA: Fourth Temporary Extension of COVID-19 Telemedicine Flexibilities (90 FR 61301)
• DEA: Special Registrations for Telemedicine, proposed rule (90 FR 6541)
• DEA: Expansion of Buprenorphine Treatment via Telemedicine Encounter (90 FR 6504)
• DEA: delay of effective date to December 31, 2025 (90 FR 13410)
• DEA Diversion Control Division: registration Q&A
• 21 CFR 1301.13: registration fees
• CMS: Medicare telehealth FAQ, October 2026 (PDF)

Editorial method and corrections