A Promise analysis of public licensure and regulatory data finds that while the core rule governing telehealth hasn't changed, a physician must be licensed in the state where the patient is physically located, not where the doctor happens to be sitting, the infrastructure states have built to satisfy that rule has scaled dramatically over the past decade, giving patients more ways than ever to verify who is actually authorized to treat them.
SCOTTSDALE, AZ — July 2026 — 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.
Why a telehealth doctor must be licensed in your state
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, per a June 26, 2026 announcement from 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: that the platform's consultation model requires a licensed clinician to review a patient's case before any prescription decision is made; that the assigned clinician is licensed or otherwise authorized to practice in the patient's own state, the standard set out in the FSMB's model telemedicine policy; and that 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 provider 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 provider, 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.
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 provider, who determines whether a prescription is appropriate; nothing is prescribed 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: max@mypromise.com
Location: Scottsdale, AZ