February 7, 2023

Volume XIII, Number 38


February 06, 2023

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Interstate License Compacts Arrive to Ohio for Physicians, Nurses, and Audiology/Speech-Language Pathologists

Health care practitioners are seemingly subject to a constantly growing laundry list of regulatory requirements. However, the Ohio General Assembly has reduced the administrative burden on certain professionals seeking licensure in multiple states through the enactment of interstate license compact legislation. At the same time, recent action by the Centers for Medicare and Medicaid Services provides increased reimbursement opportunities for specified practitioners who participate in interstate license compact as well.

Shortly after signing the state budget, Ohio Governor Mike DeWine signed a trio of bills resulting in Ohio becoming a member of interstate license compacts for physicians (Senate Bill 6), registered nurses and licensed practical nurses (Senate Bill 3), and audiology and speech-language pathology professionals (House Bill 252).

A licensure compact is an agreement among participating U.S. states and territories to work together to significantly streamline the licensing process for practitioners who want to practice in multiple jurisdictions. Eligible practitioners can qualify to practice in multiple states by completing just one application within the compact and thereby simultaneously receive separate licenses from each state in which they intend to practice. Licenses are still issued by individual states – just as they would be using the standard licensing process – however, because the application for licensure in these states is routed through the compact, the overall process of gaining a license is significantly streamlined.

A practitioner working under the authorization of a compact must meet both the licensure requirements outlined in their principal state of residence and those established by the compact laws adopted by the legislatures of the interstate compact states. Practitioners must hold an active, unrestricted license in their principal state of residence and not have a history of criminal convictions. Additionally, physicians are ineligible for licensure via compact if their medical license was ever subjected to discipline by a licensing agency in any state, federal, or foreign jurisdiction, other than any action related to nonpayment of fees.

The benefits of Ohio joining several other states in licensure compacts are significant, especially from a Medicare reimbursement perspective. Previously, Medicare administrative contractors (MACs) denied any enrollment application reporting an interstate license compact. Now, the Centers for Medicare and Medicaid Services (CMS) has reversed its prior position and concluded, interstate license compacts will be treated as valid, full licenses for the purposes of meeting Medicare license requirements. MACs will also re-open any previously denied enrollment applications reporting an interstate license compact and continue processing the applications. Importantly, the effective date of billing will be based on the receipt date of the original application.

Another benefit of interstate licensure compacts is improved access to care, particularly for patients in underserved or rural areas, in light of the ongoing COVID-19 pandemic. Interstate licensure compacts make it possible to extend the reach of practitioners, improve access to general providers and specialists, and leverage the use of new medical technologies, such as telemedicine.

Ohio joins more than 30 states already in the Interstate Medical Licensure Compact and the Nurse Licensure Compact, as well as 10 states already in the Audiology and Speech-Language Pathology Interstate Compact.

© 2023 Dinsmore & Shohl LLP. All rights reserved.National Law Review, Volume XI, Number 197

About this Author

Daniel S. Zinsmaster, Dinsmore Law Firm, Health Care Lawyer

Dan provides trusted counsel and advocacy to health care clients on a variety of matters, such as corporate compliance, provider credentialing, administrative proceedings and litigation.  He also advises clients on practice formation and acquisition, as well as contract review and preparation.  In recent years, Dan has helped health care companies and providers navigate through fraud and abuse investigations, antitrust reviews, and other white collar criminal matters.  He is a frequent author and lecturer on telehealth and telemedicine issues.


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LaTawnda focuses her practice on health care law. Her experience includes litigating complex cases in state courts, as well as all aspects of litigation for state regulatory boards from conception through trial, including pleadings, legal research, discovery, motions, and mediation. She develops client-specific litigation strategies when handling disputes concerning administrative law, public law, and Ohio’s sunshine law.