Why Does Payer Enrollment Still Take So Long After IMLC Licensure?
As of September 2026, the Interstate Medical Licensure Compact (IMLC) has issued more than 200,000 expedited physician licenses across 44 member states, with 51% of licenses processed within a single week. However, obtaining a state medical license through the IMLC does not establish payer enrollment, credentialing, or reimbursement in that state. Providers who obtain an IMLC license must still complete separate credentialing and enrollment with Medicare, Medicaid, and every commercial payer they intend to bill, a process that typically takes 90 to 180 days per payer.
- Licensure vs. enrollment: A state medical license authorizes a physician to practice medicine. Payer enrollment authorizes the physician to bill and receive reimbursement. These are two completely separate processes with separate timelines.
- IMLC growth in 2026: The IMLC processed 3,633 licenses in March 2026 alone. The compact now covers 44 states plus Washington D.C. and Guam, with Alaska joining in 2026.
- The bottleneck: Most providers who use the IMLC to expand into new states discover that payer enrollment, not licensure, is the timeline that controls when they can actually start generating revenue in that state.
What Changed with the IMLC in 2026
The IMLC released its September 2026 license volume data report showing continued record growth. According to the American Medical Association, nearly 11,000 applications for IMLC letters of qualification were completed in the 12-month period ending March 31, 2026. The top states issuing licenses under the compact were Texas (1,462), Illinois (1,013), Georgia (966), and Indiana (963). Alaska became the newest member state in 2026, bringing the total to 44 states plus D.C. and Guam.
For physicians expanding into new states for telehealth, locum tenens, or multi-site practice, the IMLC has removed what used to be the hardest part of multi-state expansion: the licensing process itself. What used to take months of individual state board applications now averages 19 days through the compact.
But the licensing breakthrough has exposed the bottleneck that was always there underneath it. In our experience helping providers expand into new states through credentialing and enrollment, the single most common issue we see is a provider who has an active license in a new state within two weeks but cannot bill a single payer in that state for another three to six months.
How Long Does Payer Enrollment Take After Getting an IMLC License?
The honest answer depends on the payer type, the state, and how complete your credentialing documentation is at the time of application. Here is what providers should realistically expect.
| Payer Type | Typical Timeline | Key Portal | Common Delay Cause |
|---|---|---|---|
| Medicare (PECOS) | 45 to 90 days | PECOS via I&A | Incorrect CMS-855 form selection |
| Medicaid (state portal) | 60 to 150+ days | Varies by state | State-specific requirements, OIG screening backlog |
| Commercial (e.g., UHC, BCBS, Aetna, Cigna) | 90 to 180 days | Payer portal + CAQH | Incomplete CAQH profile, expired attestation |
| Medicare Advantage | 90 to 180 days | Plan-specific | Directory accuracy requirements, closed networks |
The disparity is clear. An IMLC license can arrive in as few as 7 days. Payer enrollment in the same state takes a minimum of 45 days for Medicare and can stretch past 6 months for commercial plans. Every day between licensure and enrollment approval is a day the provider is legally authorized to practice but unable to bill.
Providers often come to us after they have obtained their IMLC license expecting to start billing immediately. The conversation Tim Daniels most frequently has with new clients expanding into multiple states is about sequencing: start your CAQH profile setup and payer enrollment applications at the same time as your IMLC application, not after.
What Steps Close the Multi-State Enrollment Gap?
The providers who minimize the revenue gap between licensure and billing are the ones who run both processes in parallel rather than in sequence. Here is the enrollment sequence that works.
- Start CAQH before or alongside the IMLC application. Your CAQH Provider Data Portal profile is the single data source most commercial payers pull from during credentialing. If it is incomplete, expired, or missing the new state’s information, every payer application in that state stalls.
- Apply for NPI enumeration with the new state address. If you are adding a new practice location in the target state, update your NPPES record to reflect that location. Medicare, Medicaid, and commercial payers cross-reference NPPES data during enrollment screening.
- Identify which CMS-855 form applies. Individual physicians enrolling in a new state use the CMS-855I. Groups use the CMS-855B. Submitting the wrong form requires starting over and adds 30 to 60 days to the timeline.
- Research state Medicaid enrollment requirements. Medicaid enrollment is state-administered. Every state has its own portal, screening process, and timeline. Some states, like Texas, are currently processing applications in 90 to 120 days due to OIG screening backlogs.
- Submit commercial payer applications in parallel. Do not wait for Medicare approval to start commercial credentialing. Most commercial payers operate on independent timelines and do not require active Medicare enrollment as a prerequisite.
- Track every application centrally. When enrolling with multiple payers across multiple states simultaneously, a single missed follow-up or document request can delay one payer by 60 days. Centralized tracking prevents applications from falling through gaps.
Expanding into a new state? Our team manages payer enrollment across 40+ states in parallel with your IMLC licensure so you can start billing as soon as your license is active.
Common Multi-State Enrollment Mistakes
The speed of IMLC licensure creates a false sense of simplicity. Providers who assume that payer enrollment will be equally fast tend to make predictable mistakes.
Treating licensure as enrollment. A license to practice medicine and authorization to bill a payer are two different regulatory processes. Providers who start seeing patients in a new state before enrollment is complete risk furnishing services they cannot bill for.
Ignoring state-specific Medicaid rules. Medicaid enrollment varies dramatically by state. Some states require in-person site visits, fingerprint-based background checks, or separate Managed Care Organization (MCO) credentialing. A process that takes 60 days in one state can take 150 days in another.
Letting the CAQH attestation expire. Your CAQH profile must be attested within every 120-day window. If you are expanding into three new states and your CAQH attestation expires during the enrollment process, every commercial payer application in every state stalls simultaneously.
Sequencing instead of running in parallel. Providers who wait for their IMLC license to arrive before starting CAQH updates, Medicare enrollment, and commercial payer applications add 3 to 6 months of unnecessary delay. The parallel approach cuts the revenue gap significantly.
Assuming one payer enrollment covers all plans. Enrolling with UnitedHealthcare commercial does not automatically enroll you with UHC Medicare Advantage. Each product line often requires a separate application, and managed care credentialing is distinct from fee-for-service enrollment.
In-House vs. Outsourced Multi-State Enrollment
For a physician expanding into one additional state with two or three payers, in-house management may be feasible. For a group practice expanding into three or more states with Medicare, Medicaid, and multiple commercial payers in each, the enrollment volume quickly exceeds what most internal teams can track. Across the providers we work with at Contracting Providers, the ones who get billing-ready fastest in new states are the ones who use our team to run every enrollment application in parallel across all payers and all states while they focus on setting up the clinical operation.
The cost calculation is straightforward. A mid-volume provider generates $30,000 to $50,000 per month in collections. Every month of delayed enrollment in a new state represents that full amount in lost revenue. A three-month delay across three payers in one state can easily represent over $100,000 in revenue that was available but not accessible because the enrollment applications were not submitted early enough or managed closely enough.
Frequently Asked Questions
Does an IMLC license mean I can bill Medicare in the new state?
No. An IMLC license authorizes you to practice medicine in that state. To bill Medicare, you must separately enroll through PECOS using the appropriate CMS-855 form and receive approval from the Medicare Administrative Contractor for that jurisdiction. The two processes are completely independent.
How many states are in the IMLC as of 2026?
As of September 2026, 44 states plus Washington D.C. and Guam are members of the IMLC. Alaska joined in 2026. Massachusetts and New York have introduced compact legislation but are not yet operational. Hawaii and Vermont participate but cannot serve as states of principal licensure.
Can I start payer enrollment before my IMLC license is issued?
Yes, for most commercial payers. You can begin the CAQH profile update, gather documentation, and in many cases submit the payer application before the license is in hand. Medicare enrollment through PECOS requires an active, unrestricted license in the enrolling state, so the license must be issued before you submit the CMS-855.
How long does Medicaid enrollment take in a new state?
Medicaid enrollment timelines vary significantly by state. Florida and Arizona, where Contracting Providers has the deepest experience, typically process applications in 60 to 90 days. Texas is currently experiencing OIG screening delays that push timelines to 90 to 120 days or longer. Some states process clean applications in 30 business days.
Do I need separate credentialing for each MCO in the new state?
In most states, yes. Medicaid managed care enrollment requires separate credentialing with each Managed Care Organization operating in that state. This is a distinct process from state Medicaid fee-for-service enrollment and often runs on its own timeline. You typically must be enrolled in state Medicaid before an MCO will process your application.
What is the biggest mistake providers make when expanding to new states?
Running the IMLC licensure process and the payer enrollment process in sequence instead of in parallel. Providers who start enrollment applications at the same time as their IMLC application can be billing within weeks of receiving their license. Providers who wait can face a 3 to 6 month revenue gap after licensure.
Next Steps
If you are planning multi-state expansion, start with your CAQH profile. Confirm it is attested, complete, and includes the new state’s practice information. Then review our guide on PECOS and Medicare enrollment to understand the Medicare-specific process.
If you are expanding into multiple states and need enrollment managed across all payers in parallel, Contracting Providers handles the full enrollment lifecycle from CAQH setup through final payer approval in 40+ states.
Stop losing revenue to enrollment delays. Our team runs credentialing and payer enrollment in parallel across every state and every payer so your providers can start billing the week their license arrives.



