Before expanding your telehealth practice to a new state, you need to understand four things: what license or registration is required, what prescribing authority you'll have, what informed-consent rules apply, and whether the compact simplifies any of it. Here's how to work through each.
Step 1: Determine the licensure pathway
Start by checking whether the target state is an IMLC member. If it is, and if you hold a Letter of Qualification (LOQ) from the compact, you can obtain a license through the expedited pathway rather than the full standard application. As of 2026, 43 states are IMLC members.
If the state is not an IMLC member, or if you don't hold an LOQ, you'll need to complete the standard license application. Lead times vary from 30 days (some compact states) to 6+ months (California, New York, Florida).
Step 2: Check prescribing authority
Even with a valid state license, prescribing authority via telehealth depends on: (1) your DEA registration, (2) state-specific Schedule II-IV rules, and (3) whether the state has a separate out-of-state controlled substance registration. Some states require a state-specific controlled substance registration separate from your DEA number.
Step 3: Review informed-consent requirements
Most states require some form of informed consent for telehealth. Requirements vary: verbal consent documented in the record, written consent signed by the patient, or a standardized consent form available from the state board. Some states require that the consent specifically acknowledge the telehealth modality.
Some states require written consent. Others accept verbal. A few specify the exact content of the consent form. Always check the current state board policy.
Step 4: Check out-of-state registration requirements
A small number of states have introduced out-of-state telehealth registration requirements separate from licensure (Colorado as of January 2026, for example). Check whether the target state has any such requirement before your first encounter.