Where Telehealth Care Happens: Patient Location, Licensure and the Interstate Medical Licensure Compact
The first compliance question for any telehealth clinic is not what you prescribe but where your patient is sitting. In general, the practice of medicine is treated as happening in the patient's state, which means the physician needs authority to practice there.
Key Highlights
- The general principle is that the practice of medicine occurs where the patient is located, and the physician must be licensed or appropriately authorized by that state's board.
- California requires a California license for patients located in California, with narrow exceptions. Florida deems care to occur where the patient is and offers a registration route for some out-of-state providers.
- The Interstate Medical Licensure Compact speeds licensing in member states but is not a national license: each state still issues its own license and physicians remain subject to each state's laws.
- A multi-state telehealth practice needs to map every patient's state to a licensed physician.
The Principle
Telehealth does not move care out of the state. The interstate licensure compact's own FAQ states that the location of medical practice is the state where the patient is located, and that physicians are bound by the laws of each state where they practice. A state board model policy adopted by Vermont, drawn from the Federation of State Medical Boards' 2022 telemedicine policy, says the same thing: a physician must be licensed, or appropriately authorized, by the medical board of the state where the patient is located.
What Individual States Say
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What the Interstate Medical Licensure Compact Does
The Interstate Medical Licensure Compact is a voluntary, expedited pathway to licensure. It reports 44 member states plus two territories. It is not a national license: physicians do not receive a compact license, each state still issues its own, and physicians remain subject to each state's laws. Eligibility generally requires a full license in a participating state with a tie to it, board certification and a clean disciplinary and controlled-substance history. It applies to physicians, and a member state may still be implementing it, so a license in every state is not guaranteed.
What a Telehealth Clinic Should Do
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Disclaimer
This article is general educational information, not legal advice. Telehealth rules differ by state and change often, so confirm specifics with health care regulatory counsel in each state where you treat patients.
MedGrid MSO provides management services to independently owned practices; it does not practise medicine and does not direct clinical decisions. Requirements vary by state and by service, and change over time — nothing on this page is legal or medical advice. Talk to us or your own counsel before making a structural decision for your clinic.