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Connecticut Joins the Interstate Medical Licensure Compact and the Psychology Interjurisdictional Compact

Effective October 1, 2022, Connecticut adopted the Interstate Medical Licensure Compact (IMLC) and the Psychology Interjurisdictional Compact (PSYPACT). As of the date of this post, Connecticut joins 38 other states who have adopted the IMLC and 34 other states that have adopted the PSYPACT. Each of the IMLC and the PSYPACT provide an additional pathway for physicians and psychologists to obtain licensure in Connecticut. Providing medical or psychological services via telehealth generally requires the treating provider to obtain a license in the state in which the patient is located. These additional pathways to licensure in Connecticut are particularly important and useful for telehealth platforms as their providers may now become licensed in Connecticut more easily.

Interstate Medical Licensure Compact

The IMLC provides physicians a streamlined process through which they can obtain licensure in multiple states, including Connecticut, effective as of October 1, 2022.  It is important to note that the IMLC does not eliminate other methods of obtaining licensure in Connecticut and simply provides a process through which to obtain an Expedited License. Physicians seeking expedited licensure under the IMLC in Connecticut must submit their licensure application to the Connecticut Medical Examining Board. The Connecticut Medical Examining Board will evaluate whether the physician is eligible for expedited licensure under IMLC, and if so, will issue a letter of qualification to the Interstate Commission. Upon the Interstate Commission verifying that the physician is qualified for expedited licensure, the physician must complete the Interstate Commission registration process, after which time, the Connecticut Medical Examining Board will issue an expedited license to the physician.

Physicians licensed under IMLC must designate a state to serve as the physician’s principal licensure state. Such state must have adopted the IMLC and be:

  • The state of principal residence for the physician;
  • The state where at least 25% of the physician’s practice of medicine occurs; or  
  • The location of the physician's employer;

However, if no such state exists for a physician, a physician’s principal licensure state will be designated as the state of residence for purposes of federal income tax. As of the date of this post, the Connecticut Department of Public Health will issue licenses to out-of-state licensed physicians through the IMLC. However, Connecticut will not be acting as a state of principal license until additional legislation is passed.

Psychology Interjurisdictional Compact

The PSYPACT’s goal is to increase public access to professional psychology services and allow the practice of telepsychology across state lines. Psychologists authorized to practice telepsychology through PSYPACT are also authorized to provide temporary, face-to-face psychology services for up to 30 days to patients in other PSYPACT jurisdictions.

The Connecticut Board of Examiners of Psychologists (Psychology Board) will still maintain its authority over licensees. Further, when a Connecticut psychologist practices across state lines, the psychologist is subject to that state’s scope of practice. If the Psychology Board, another compact state, or any other authority to practice Interjurisdictional telepsychology in any receiving state restricts, suspends, or limits the psychologist’s license, that psychologist will no longer be eligible to practice telepsychology in any compact state. If the Psychology Board takes adverse action against the psychologist, the Psychology Board must report it to the PSYPACT Commission.

A psychologist can apply for authorization to practice telepsychology at Practicing Telepsychology Under PSYPACT or for temporary in-person practice authorization at Practicing Temporarily Under PSYPACT.

Conclusion

The ILMC and PSYPACT each provide physicians and psychologists the ability to offer telehealth services across state lines, which has become increasingly helpful over the last few years in the wake of the COVID-19 pandemic. Currently, several states across the United States are introducing or progressing toward enacting ILMC and PSYPACT. For instance, New York and Massachusetts have introduced both the ILMC and PSYPACT in legislation. As more and more states adopt the IMLC and the PSYPACT, patient access to telehealth services and the array of benefits derived from those services will increase.  

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Authors

Jean D. Krebs

Associate

Jean D. Krebs is an Associate at Mintz who focuses her practice on health care transactional, regulatory, and compliance matters. She represents clients across the health care industry, including hospitals, physician organizations, health care systems, and long-term and urgent care providers.

Cody Keetch

Associate

Cody Keetch is an Associate at Mintz who focuses his practice on health care transactions and advises health care organizations on regulatory, compliance, and governance matters. He also represents clients in the technology and life sciences industries.