Locum Law | Arkansas IMLC Live, PA Compact at 30 & More (Nov 2026)

By Locumpedia Editorial

2026-11-04

Locum Law is Locumpedia’s monthly column on the rules that govern locum tenens: licensure, the compacts, telehealth, and Medicare. Every claim links to its source and we describe them rather than advise.

October was a compact month. Arkansas went live in the Interstate Medical Licensure Compact’s licensing system on October 12. On the physician assistant side, Pennsylvania signed on to the PA Licensure Compact on October 22, bringing the compact to 30 member states. The compact’s commission also started building the database required before privileges can be issued.

The one thing that didn’t arrive is the 2027 Medicare fee schedule. Here’s what changed, what’s still waiting, and what’s on the calendar.

What Changed in the Physician Compact?

Arkansas Went Live

Arkansas has been an IMLC member since 2025, but its board only now runs on the compact’s production system. The commission announced on October 26 that Arkansas “successfully launched as IMLCC’s newest Member-Board in production” as of Monday, October 12, 2026 (Interstate Medical Licensure Compact Commission, Arkansas go-live release).

The Commission Published Its Own Count

The commission’s 2026 annual report announcement, dated October 16, puts membership at “44 states, the District of Columbia and Guam,” representing 59 state physician licensure boards. It also reports that the compact has “issued more than 65,000 licenses and renewed more than 67,000 previously issued licenses,” figures the commission labels unaudited (annual report release).

New Mexico is preparing to go live. Its medical board expects to present proposed IMLC rules for hearing at its November 5-6 meeting, with an “anticipated launch of the Interstate Medical Licensure Compact in New Mexico, pending completion of the rulemaking process” in December 2026 or January 2027 (New Mexico Medical Board, IMLC update).

Which High-Volume States Are Still Outside the IMLC?

California, Virginia, and New York. Between them, they hold 666 of the locum tenens opportunities currently posted to Locumpedia in the ten states this column tracks, and none of the three is an IMLC member.

These are the ten states Locum Law tracks each month, not a national ranking. Counts are active, approved postings aggregated across competing agencies on Locumpedia as of November 1, 2026, using a 90-day freshness window in place since September 2026. They’re a snapshot of where agencies are posting opportunities right now and they move with posting and expiry cycles, so they aren’t a demand index. Compact membership is based on the Interstate Medical Licensure Compact Commission’s member-state map, which is current as of March 2026.

Pennsylvania now sits in both compacts: an IMLC member for physicians and, as of October 22, a PA Licensure Compact member for PAs. California is still the single largest source of locum tenens work posted to Locumpedia, and the IMLC’s expedited pathway isn’t an option there.

What Did Pennsylvania Just Join?

The PA Licensure Compact, the interstate agreement that will let a physician assistant licensed in one member state practice in another through a compact privilege.

Pennsylvania’s governor approved House Bill 1961 on October 22, 2026, as Act 76 of 2026. The bill authorizes “the Commonwealth of Pennsylvania to join the PA Licensure Compact,” and it passed both chambers without a dissenting vote: 50-0 in the Senate on October 20 and 203-0 when the House concurred on October 21 (Pennsylvania General Assembly, HB 1961 history).

The compact’s own count followed a week later: “As of October 29, 2026, there are 30 Compact Member States” (PA Licensure Compact, October newsletter).

Thirty states have signed on. None of them can issue a privilege yet.

When Can a PA Actually Use the Compact?

Not yet. The commission is still building the system that issues privileges, and it now has a contractor and a start date. It signed a data system contract with Focus LLC on September 25, and its chair wrote that “as of October 1, 2026, work has started on the database.” The same newsletter says the initial system “should be completed, as scheduled, in early 2027,” and lists the commission beginning to issue compact privileges as projected for early 2027.

The commission also cleared some groundwork at its September 18 meeting, approving its fiscal year 2027 budget, bylaw amendments, and two rules: Rule 5 on joint investigations and Rule 7 on state compliance.

What’s Still Only Proposed?

Georgia’s protocol ratio, for the third month running. Proposed Chapter 410-11 would raise the number of advanced practice registered nurses who can enter a nurse protocol agreement with one delegating physician from four to eight. We re-read the live rule on November 1 and it still says “Only four (4) advanced practice registered nurses may enter into a nurse protocol agreement with a delegating physician” (Georgia Rules and Regulations, Chapter 410-11).

Virginia’s PA prescription rule hasn’t moved. The action that would stop requiring a PA to name the patient-care-team physician or podiatrist on a controlled-substance prescription still shows “Governor’s office review in progress” at the final stage, with no effective date (Virginia Regulatory Town Hall, action 6294).

North Carolina holds a public hearing on its clinical pharmacist practitioner rule, 21 NCAC 32T .0101, on November 10 at 10 a.m. (North Carolina Medical Board, rule change tracker).

One small Virginia item did take effect: the Board of Medicine’s fast-track change to 18VAC85-20, its general practice-of-medicine chapter, reached effective status on October 22, 2026, as scheduled.

Where’s the 2027 Medicare Fee Schedule?

Still coming. As of November 1, the only CY2027 entry on CMS’s physician fee schedule regulation list was the July proposed rule. The final rule normally lands in November or December, and it’s the document that sets next year’s telehealth payment rules.

Until then, the statute does the talking. CMS’s proposed-rule fact sheet says the Consolidated Appropriations Act, 2026 Section 6209(c) requires “that in-person visit requirements for mental health visits not apply to any services furnished” through December 31, 2027, and that the same law “extended the authority for CMS to pay RHCs and FQHCs for non-behavioral health visits” by telecommunication through the same date (CMS, CY2027 PFS fact sheet).

Locum Law describes what state boards, compacts, courts, and federal agencies have published. It isn’t legal advice. Every item here was reviewed using its primary source on the date shown. Where a rule is proposed rather than enacted, we say so.