Connecticut Health Law

If you are a Connecticut physician considering providing telemedicine across state lines, expanding your practice just became significantly easier. On March 15, 2026, the Interstate Medical Licensure Compact Commission (IMLCC) announced Connecticut’s full participation in the Interstate Medical Licensure Compact ("Compact") — opening the door for eligible physicians to obtain streamlined licensure in up to 43 member states.[1]

What Is the Interstate Medical Licensure Compact?

The Compact is an agreement among participating states and territories that expedites physician telehealth licensing and multi-state medical practice. Rather than navigating each state's licensing process independently, qualified physicians can use a single streamlined pathway to obtain licenses in multiple jurisdictions.

To qualify for the Compact, physicians must meet specific criteria, including but not limited to:

• Designating a "State of Principal License" (SPL) and holding an unrestricted license in that state;
• Having no active investigations pending at the time of application; and
• Maintaining a clean record with no criminal history, disciplinary actions, or controlled substance violations.

Once eligible, physicians obtain a “Letter of Qualification” from their SPL, then select and apply for licenses in their desired Compact member states through the IMLCC website.

The Compact does not change a member-state’s qualification requirements for licensure, nor does it change a state licensing board’s authority to impose disciplinary measures against physicians who obtain licensure through the Compact.

Connecticut's Compact Implementation: Phases I and II

In 2022, Connecticut joined the Compact. Phase I of the implementation process enabled qualified physicians in Compact member states other than Connecticut to apply for licensure in Connecticut. (See our prior blog post here). The completion of Phase II this month means that physicians licensed in Connecticut who meet the Compact standards can now apply for licensure in other Compact member states by obtaining a Letter of Qualification from the Department of Public Health.

Regulatory Risks and Compliance Considerations for Multi-State Telemedicine

While the Compact simplifies licensing, physicians looking to practice telemedicine across state lines must keep in mind that there are still a number of regulatory matters to consider and navigate:

• State-Specific Telehealth Laws: Telemedicine is generally governed by the law where the patient is located — not where you practice. Each state has unique telehealth regulations that must be understood and followed.
• Coordinated Disciplinary Action: If any participating state board takes action against your license obtained through the Compact, all Compact member boards are notified and authorized to take similar action — potentially affecting your ability to practice in multiple states simultaneously.
• Prescribing and DEA Requirements: Interstate telemedicine practice often involves additional requirements for prescribing controlled substances, including state-specific DEA registrations.
• Insurance: Physicians need to review and update their medical malpractice, cyber security, umbrella and other types of insurance policies to ensure coverage across state lines.
• Other considerations such as corporate governance, state-specific registration, informed consents, and taxation may also be in play.

In sum, expanding your practice through multi-state telemedicine offers significant opportunities — but the regulatory landscape is complex. From Compact eligibility to state-specific telehealth compliance, the details matter.

If you would like more information about the Compact, please contact a member of Pullman & Comley’s Health Care practice.

[1] See this link for a map from the IMLCC identifying those states currently participating in the Compact.