Disclosure Requirements for Multi-State Licenses
Multi-state licensure for healthcare providers is certainly not new but it is easier than ever for providers to become licensed if they qualify for a multi-state license compact such as the Nurse Licensure Compact or the Interstate Medical Licensure Compact (IMLC). Multi-state licensure can be extremely beneficial (and necessary) for travel nurses, locum tenens physicians, and providers engaged in providing telehealth services in multiple states.
If you hold more than one license, whether it is active or inactive, there are some important facts you should keep in mind:
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If you have action taken against a license by a state board, you need to be aware of your obligation to report the action to the other states in which you hold a license. Most, if not all, state licensing boards will require an active licensee to report an action taken by another board within a certain time frame. Timely disclosure is crucial to avoid a board from initiating disciplinary action for failure to properly disclose. Some states also require those whose license may be inactive to report other state actions as well; don’t assume because a license is inactive the obligation to report is extinguished.
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Boards can, and often will, take reciprocal action against a licensee for action taken by another board. Most licensing boards have a provision within their laws that allow them to initiate action against a licensee simply based on the fact that discipline was imposed in another state. This can result in a multi-stated licensed provider facing discipline in multiple states and having to again report the action to their other boards.
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Understand the ramifications of a disciplinary action on a license held through a multi-state compact. The IMLC considers disciplinary action to render a physician unqualified to be licensed through the Compact and could result in one or more licenses being cancelled.
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Arrests, criminal charges, and/or convictions also often need to be disclosed, however at what point in the criminal process something needs to be disclosed varies widely by state; it’s best to check with each state in which a provider holds a license.
If you hold a license in multiple states and are the subject of any board action, criminal action, or action taken by another government agency, you should seek assistance in determining your disclosure requirements and to understand the possible ramifications of the action.