Medicare telehealth flexibilities now run through December 31, 2027, with the in-person visit requirement for mental health telehealth waived through January 1, 2028. The federal payment side is settled. State-level credentialing is not. Practices serving patients across state lines still need a license in each state where the patient is physically located at the time of the visit, and the patchwork of compacts, reciprocity agreements, and state-specific telehealth rules has only partially closed the gap. For practices building a multi-state telehealth program, credentialing remains the bottleneck that determines how fast revenue can scale.
The patient-location rule
The default rule across all states and most payers is that the provider must hold a license in the state where the patient is physically located when the encounter occurs. A psychiatrist licensed only in New York cannot legally treat a patient in New Jersey, even if the patient is normally a New York resident traveling for the day. Documentation should capture the patient’s location at the start of every telehealth visit, not the patient’s home address or the address on the insurance card. This single workflow change reduces audit risk dramatically and is easy to add to the visit intake.
The Interstate Medical Licensure Compact
The Interstate Medical Licensure Compact provides an expedited pathway for physicians to obtain licenses in member states. As of 2026, more than 40 states participate. The Compact does not create a single multi-state license; it streamlines the application for a separate license in each member state. The advantage is processing time (often 30 to 60 days versus 4 to 9 months for a traditional application). The cost is the per-state license fee plus the Compact fee. For physicians serving patients in 5 or more states, the Compact is almost always worth the investment.
PSYPACT, NLC, and other compacts
Other professions have parallel compacts. PSYPACT (the Psychology Interjurisdictional Compact) lets licensed psychologists practice telepsychology across member states with a single Authority to Practice Interjurisdictional Telepsychology. The Nurse Licensure Compact (NLC) allows registered nurses and licensed practical nurses to hold one multistate license valid in all member states. The Counseling Compact, the Audiology and Speech-Language Pathology Compact, and the Physical Therapy Compact provide similar mechanisms in their respective fields. Practices employing multiple license types must build a credentialing matrix that tracks each provider’s eligibility in each state.
The CAQH and ProView coordination
Multi-state practices live and die by the consistency of their CAQH ProView profile. Every payer in every state pulls credentialing data from CAQH, and inconsistencies (different addresses, missing certifications, expired malpractice in one state but current elsewhere) trigger application delays and re-requests. The discipline is a single source of truth in CAQH, with quarterly attestation, and a state-by-state license tracker that feeds back into CAQH on each renewal cycle. Practices that try to maintain credentialing data in multiple places end up with conflicts that delay payer enrollment by months.
Payer credentialing, separate from state licensure
Holding a state license does not automatically mean a payer will pay claims. Each commercial payer requires separate credentialing in each state where the provider sees patients, and Medicare and Medicaid have their own enrollment processes (PECOS and state Medicaid systems). The full sequence for a new state is typically: state license, then DEA registration if controlled substances are prescribed, then Medicare PECOS enrollment, then state Medicaid enrollment, then commercial payer credentialing applications. Each step has its own timeline. Building all of them in parallel rather than sequentially shortens the time to first claim by months.
Re-credentialing on the multi-state schedule
Most state licenses, payer credentials, and Medicare enrollments require re-credentialing every 2 to 3 years, on different cycles. A provider with licenses in 8 states and credentials with 12 commercial payers per state is managing roughly 100 separate re-credentialing events on different schedules. Missing one means claims start denying without warning. The discipline is a calendar-based credentialing tracker with automated alerts 90, 60, and 30 days before each expiration, supported by a process for collecting and submitting renewal documentation on time.
How MHB helps multi-state practices
For practices building or maintaining multi-state telehealth credentialing, our team handles end-to-end insurance credentialing across states and payers, with CAQH attestation, compact applications, payer enrollments, and re-credentialing tracking. The work runs alongside the practice’s existing operations.
The bottom line
The federal telehealth rules are stable through 2027. State-level credentialing remains the rate limit on multi-state growth. Practices that treat credentialing as a discrete operational function (with compacts, calendars, CAQH discipline, and parallel payer applications) scale telehealth across state lines. Practices that handle credentialing as paperwork in someone’s spare time stay stuck in one or two states.
