Your Telehealth Doctor Must Be Licensed in the State You’re In, Not the State They’re In, Promise Analysis Finds
3,633 physician licenses were issued in a single month through the Interstate Medical Licensure Compact — American Medical Association, 2026.
SCOTTSDALE, Ariz., Aug. 20, 2026 /PRNewswire/ — Promise, a Scottsdale-based telehealth platform offering doctor-guided consultations for peptide therapy, weight management, and hormone care, today released an analysis of how physician licensure works across state lines in telehealth, and why the answer matters more to patients than most realize.
Drawing on data from the Federation of State Medical Boards (FSMB), the American Medical Association (AMA), and the Center for Connected Health Policy (CCHP), the analysis lays out the governing rule, the compact system built to scale it nationally, and what patients should verify before starting a telehealth visit.
The Interstate Medical Licensure Compact (IMLC), the primary mechanism states use to speed up multi-state physician licensing, issued 3,633 physician licenses in March 2026 alone, up from just three licenses in its first month of operation in April 2017, according to IMLCC data from 2026. It also found that more than 200,000 licenses have been issued through the compact since launch, and the compact now spans 44 states plus D.C. and Guam. The scale of that growth is, in itself, a signal of how much cross-state telehealth demand the licensure system has had to absorb.
The rule that hasn’t changed
Under longstanding guidance from the Federation of State Medical Boards, a physician must be licensed, or otherwise appropriately authorized, by the medical board of the state where the patient is physically located at the time telemedicine technologies are used, not the state where the physician’s practice is based. That guidance, formalized in FSMB’s model telemedicine policy, has anchored state medical board enforcement for years and remains the operative standard in 2026.
In practice, this means a patient logging into a telehealth visit from Arizona needs the assigned physician to hold authorization to practice in Arizona, regardless of where that physician’s medical group, headquarters, or primary license happens to be. The rule is easy to overlook because a telehealth visit doesn’t feel geographically specific; it’s a video call, an intake form, a follow-up message. However, the location of the patient (not the provider) is what determines which state’s medical board has jurisdiction over the encounter.
How compact licensure scaled to meet demand
Since the location-of-patient rule effectively requires physicians to hold authorization in every state where they see patients, states built the Interstate Medical Licensure Compact to make that multi-state process faster than applying to each state board individually.
According to an AMA article from 2026, nearly 11,000 physician applications for an IMLCC “Letter of Qualification”, the credential that initiates the compact licensing process, were completed between April 2025 and March 2026 alone. The compact’s geographic footprint has kept pace with that volume: According to an IMLCC press release from 2026, Alaska became the IMLC’s 44th member state, and 46th member-jurisdiction overall, counting D.C. and Guam, on June 26, 2026, per the Interstate Medical Licensure Compact Commission.
The IMLC is not the only mechanism states have built to scale cross-state telehealth access. The Center for Connected Health Policy, from October 2025, tracks 13 distinct interstate licensure compacts relevant to telehealth practice across professions, spanning medicine, nursing, and allied health fields. Separately, 18 states, plus the U.S. Virgin Islands and Puerto Rico, have established a telehealth-specific special registration or licensure process as an alternative route to full in-state licensure, according to CCHP’s Fall 2025 State Report on Telehealth Laws and Reimbursement Policies.
Taken together, these mechanisms mean a physician can now be authorized to see a patient in a given state through several different regulatory pathways, not just a traditional single-state license.
Why the patient’s location decides the license check
The practical effect of the FSMB’s location-of-patient standard is that licensure verification runs in the patient’s state, not the provider’s headquarters or the platform’s state of incorporation. A telehealth company’s physician network can span dozens of states, but what governs any single consultation is where the patient is physically located when that consultation happens.
That distinction reframes what patients should actually be researching. Confirming where a telehealth company is based, or how large its physician network is, doesn’t answer the licensure question. The relevant fact is narrower: whether the specific physician assigned to a given patient is licensed, or authorized through a compact or special-registration pathway, in that patient’s own state at the time of the visit. Since compact and special-registration pathways have expanded so quickly, from three IMLC licenses issued in an entire month in 2017 to 3,633 in one month in 2026, a “not licensed here” answer is now the exception in most compact-member states rather than the default barrier it once was.
However, coverage still isn’t universal; with 44 states plus D.C. and Guam participating in the IMLC as of Alaska’s June 2026 addition, a handful of states remain outside the compact. This means a physician’s ability to rely on expedited compact licensure still depends on exactly which state the patient is in, as opposed to a traditional single-state license or one of the 18 states’ telehealth-specific registration alternatives tracked by CCHP. That state-by-state variation is precisely why the verification question belongs to the patient’s location and can’t be answered in the abstract, even as the overall system has scaled to make cross-state authorization faster to obtain.
Given how much licensure infrastructure now sits behind a routine telehealth visit, the analysis recommends that patients treat licensure verification as a standard part of starting care, not an afterthought. Three checks are most relevant: whether the platform’s consultation model requires a licensed physician to review a patient’s case before any prescription decision is made. According to the Federation of State Medical Boards (FSMB)’s policy statement in April 2022, the assigned physician is licensed or otherwise authorized to practice in the patient’s own state, and the platform can explain, in plain terms, how it satisfies state-by-state licensure requirements rather than treating the question as a formality buried in terms of service.
Consultation-first models are built around this structure by design. On Promise, every treatment begins with an online consultation, and a licensed physician determines whether a prescription is appropriate for that specific patient; nothing is issued without provider review. Patients can start a consultation for programs including sermorelin, semaglutide, and tirzepatide; from there, it is the reviewing physician, working within the licensure framework described above, who determines next steps for that patient’s care.
Methodology
Promise synthesized publicly available data from the Federation of State Medical Boards’ 2022 model telemedicine policy (“The Appropriate Use of Telemedicine Technologies in the Practice of Medicine”), American Medical Association reporting on Interstate Medical Licensure Compact Commission data published in 2026, and the Center for Connected Health Policy’s Fall 2025 State Telehealth Laws and Reimbursement Policies Report. No proprietary survey was conducted. All figures are drawn from named third-party sources and reflect information publicly available as of July 2026.
Frequently Asked Questions
Does my telehealth doctor need to be licensed in the state I’m physically in, or the state they’re in?
A telehealth physician must be licensed, or otherwise appropriately authorized, in the state where the patient is physically located at the time of the visit, not the state where the physician is based. This standard comes from the Federation of State Medical Boards’ model telemedicine policy and governs how state medical boards oversee telehealth encounters.
Why does my location matter more than the doctor’s?
A patient’s location determines which state medical board has jurisdiction over a given telehealth encounter, since licensure and oversight are tied to where care is delivered, not where the physician’s practice is headquartered. A single physician network can include doctors authorized across dozens of states, but each individual consultation is governed by the state the patient is in at that moment.
What should I actually check before a telehealth visit?
Patients starting telehealth care should confirm that a licensed physician reviews their case before any prescription decision is made, that the assigned physician is authorized to practice in the patient’s own state, and that the platform can clearly describe how it handles state-by-state licensure rather than leaving the question unaddressed.
What happens if a telehealth doctor isn’t licensed in a patient’s state?
A telehealth physician who lacks licensure or authorization in the patient’s state is generally not permitted to diagnose, treat, or prescribe for that patient under that state’s medical board rules, regardless of the physician’s standing elsewhere. Reputable telehealth platforms address this by matching patients to physicians already licensed, or authorized through a compact or special-registration pathway, in the patient’s own state before a consultation is scheduled, which is why confirming that match in advance, rather than assuming it, is part of informed telehealth use.
Does a compact license change how care is delivered during a telehealth visit?
Compact licensure changes how quickly a physician becomes authorized to practice in a given state, not how care is delivered once that authorization is in place. A physician who obtains a license through the Interstate Medical Licensure Compact is held to the same standards and falls under the same state medical board jurisdiction as a physician who obtained a traditional single-state license. For patients, the practical difference is upstream, faster physician authorization in more states, rather than in the structure of the consultation itself.
About Promise
Promise is a Scottsdale, Arizona-based telehealth platform, founded in 2026, offering doctor-guided care for peptide therapy, weight management, and hormone health. Every Promise treatment starts with an online consultation with a licensed physician, who determines whether a prescription is appropriate; nothing is sold without provider review. Current programs include sermorelin, semaglutide, and tirzepatide. More information is available at mypromise.com.
Media Contact
Source: Promise
Contact: Max Power
Email: [email protected]
Location: Scottsdale, AZ
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