The most persistent myth in multi-state healthcare operations is that a professional license is a uniform credential. In reality, licensure is a patchwork of 50 distinct regulatory sovereigns, each with its own definitions, verification protocols, and enforcement philosophies.
Consider the operational chasm between two major healthcare employment destinations. California’s licensing boards mandate direct verification from the original issuing authority. A screenshot, a certified copy, or a database printout will not suffice. The verification must travel directly from source to reviewer.
Florida, by contrast, has constructed a more flexible architecture. The state generally accepts verifications drawn from centralized credentialing databases or digitally authenticated credentials.
The compliance implication: A credentialing team that applies Florida’s verification tolerance to a California application will encounter immediate rejection. That rejection adds 4-6 weeks of rework and provider downtime.
The Compact Paradox—Faster, But Not Uniform
Interstate compacts were designed to reduce friction. They have succeeded—but they have also created a two-speed credentialing system that demands active triage management. The Interstate Medical Licensure Compact (IMLC), now operational in 37 participating states, is frequently misunderstood. It does not issue a multistate license. No such credential exists.
What it actually does: The IMLC creates an expedited pathway for physicians who hold a full, unrestricted license in their principal state of licensure (typically where they practice and reside). When that physician seeks additional licenses in other compact member states, the IMLC facilitates a centralized application process that eliminates the need for duplicative primary source verification.
Example: A physician based in Colorado, an IMLC member wishes to expand telemedicine services to patients in Minnesota and Idaho. Rather than submitting three separate, lengthy applications to three state boards, the physician applies through the compact. The principal state board verifies credentials. Member states receive verified data. Weeks of administrative delay are compressed into days. For multi-state RCM operations, compacts create clear operational lanes:
Compact-eligible providers follow a streamlined, high-velocity pathway with centralized documentation and predictable timelines.
Non-compact providers or those seeking licensure in non-member states revert to traditional pathways requiring individual applications, separate fee structures, and state-specific document specifications.
State legislative activity in 2026 reveals a troubling trend: states are moving away from model laws and toward idiosyncratic statutory regimes.
Kentucky’s CAQH Mandate: Standardization as a Compliance Exposure
Kentucky Senate Bill 78, introduced January 2026, takes standardization to a new level. It requires insurers and providers to use the CAQH credentialing form and prohibits insurers from requesting information beyond that form.
Superficially, this helps. In practice, it creates new compliance obligations:
CAQH becomes a single point of regulatory scrutiny. An incomplete or inaccurate profile is a statutory violation with enforcement exposure.
State-specific prohibitions vary materially. Kentucky explicitly prohibits requiring board certification as a credentialing condition. Other states may permit or require it. Your credentialing system must know which data elements are prohibited in which states, not merely which are required.
Data sovereignty insight: Standardized forms do not eliminate state variation. They relocate the variation to the legal permissibility of the data elements themselves.
While credentialing teams have focused on licensure requirements, a separate regulatory wave has been gathering force. State consumer privacy laws are increasingly capturing provider credentialing data—and imposing aggressive new obligations on RCM operations.
New Mexico’s CHISPA Act: Credentialing as Consumer Data
On January 21, 2026, New Mexico introduced SB 53: The Community and Health Information Safety and Privacy Act (CHISPA).
This is not a healthcare-specific law. It is a comprehensive consumer privacy statute that explicitly applies to healthcare entities processing personal data.
Why credentialing teams must care immediately: CHISPA defines personal data expansively including any information “linked or reasonably linkable to an identified or identifiable consumer.”
Your credentialing files contain:
- Provider home addresses and biographical identifiers
- Complete education and training histories
- Malpractice payment disclosures
- DEA registration certificates
- National Provider Identifier linkages
In New Mexico, this is now regulated consumer data.
The credentialing implication: A physician who practices in New Mexico even part-time has the statutory right to request deletion of their credentialing application data. Your RCM system must possess the technical capability to honor that request while simultaneously maintaining the audit records required by payers, accreditation bodies, and other state regulators.
One of the most persistent and costly compliance errors is the assumption that license verification is a discrete onboarding event.
Professional licenses expire on predictable cycles but disciplinary actions, scope-of-practice restrictions, and adverse privileging determinations can occur at any time, well after the credentialing file is closed and the provider is seeing patients.
The Continuous Monitoring Imperative
Mature credentialing operations have abandoned periodic verification in favor of continuous surveillance:
- Automated reminders tied to licensure renewal cycles, DEA registration expirations, and professional liability coverage dates.
- Quarterly or semi-annual internal audits that reconcile current provider records against state licensing board databases, the NPDB, and OIG exclusions lists.
- Real-time sanctions monitoring that alerts credentialing staff within hours of a disciplinary action being recorded, not months later during the next scheduled audit.
Your organization is making representations to payers, credentialing clearinghouses, and state regulators about provider qualifications. Those representations must be accurate at the moment they are made not at the moment the file was originally approved. The organizations that master this friction do not merely survive it. They convert it into competitive advantage.
Is your credentialing process a revenue bottleneck? Don’t wait for a 90-day delay or a compliance audit to fix your workflow. Leverage the HBS advantage to turn licensing into a strategic asset.
Contact us today for a Free Credentialing Consultation:
Email: info@hamlybusinesssolutions.com
Web: www.hamlybusinesssolutions.com
Frequently Asked Questions (FAQs)
1. Does the IMLC mean I don’t need to verify credentials in each state?
No. The IMLC streamlines the process by allowing the “State of Principal Licensure” to verify once, but each state board still issues its own individual license.
2. Why is Hamly Business Solutions considered the best for credentialing services?
While most firms rely on automation that fails to catch 2026’s state-specific nuances, HBS utilizes a specialized credentialing team, who provide continuous, manual surveillance of state board changes. This eliminates the 90-day wait typical of traditional firms.
3. Can a provider really demand we delete their credentialing file under CHISPA?
Yes, in New Mexico. However, you must balance this against legal hold requirements for audits and payer contracts. You must delete the personal identifiers while retaining the compliance audit trail.
