Locum Law | Alaska Joins IMLC, NC Eases PA Rules & More (September 2026)
By Locumpedia Editorial
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.
Alaska is joining the Interstate Medical Licensure Compact (IMLC) on September 20, 2026. You still won’t be able to use it: the state isn’t accepting applications yet. Three of the ten states with the most locum tenens opportunities posted right now aren’t in the compact at all. And the biggest scope change of the year for physician assistants already took effect on August 1, quietly, in North Carolina.
Here’s what changed, what’s still only proposed and what’s on the calendar.
What Takes Effect on September 20?
Alaska’s compact package. House Bill 110 became law without the Governor’s signature on June 22, 2026, as Chapter 28 of the 2026 Session Laws of Alaska. It’s an omnibus bill covering the Interstate Medical Licensure Compact, the PA Licensure Compact, the psychology compact, the social work compact and the EMS personnel compact, all sharing one effective date.
The state is direct about what that date does and doesn’t mean. Alaska’s Division of Corporations, Business and Professional Licensing says the laws “will not take effect until September 20, 2026,” and adds that the medical board and the division “are in the process of crafting implementation plans for the compacts and will update this webpage with more information once available” (compact page).
So Alaska is the compact’s 44th member state and can’t process a compact application. Both things are true at once.
A compact you can’t apply through is a statute, not a shortcut.
Worth noting what HB 110 didn’t include: nursing. Alaska’s Nurse Licensure Compact bill is separate legislation, SB 124, still sitting in Senate Labor and Commerce after a March 27, 2026 hearing (Alaska Legislature, bill detail).
Which High-Volume States Still Aren’t in the Compact?
California, New York and Virginia. Between them they account for 1,233 of the locum tenens opportunities posted to Locumpedia as of September 5, 2026. None of the three is an IMLC member.
That gap is worth sizing properly, because compact coverage gets discussed as though it’s nearly universal. It isn’t. It’s least universal exactly where the work is.
| State | Active locum opportunities on Locumpedia | IMLC member? |
|---|---|---|
| California | 729 | No |
| Texas | 396 | Yes |
| Florida | 380 | Yes |
| Pennsylvania | 303 | Yes |
| North Carolina | 296 | Yes |
| New York | 276 | No |
| Georgia | 269 | Yes |
| Indiana | 259 | Yes |
| Ohio | 248 | Yes |
| Virginia | 228 | No |
Counts are active, approved postings aggregated across competing agencies on Locumpedia as of September 5, 2026. They represent where agencies are actively placing rather than total national demand. Compact membership per the Interstate Medical Licensure Compact Commission, which reported 44 member states and 2 US territories as of July 31, 2026 (member count).
California is the single largest source of posted locum tenens opportunities on Locumpedia, by a margin of nearly two to one over Texas. A compact license does nothing for you there. New York has a bill, S1505, referred to the Senate Higher Education Committee and last moved on January 7, 2026 (New York Senate, bill S1505). Virginia has enacted the PA Licensure Compact and the Nurse Licensure Compact but not the physician compact, which its own compacts index makes plain by omission.
What Changed for Physician Assistants?
North Carolina Eases Supervision for Experienced PAs
Under 21 NCAC 32S .0227, approved effective August 1, 2026, a PA with 4,000 total clinical hours, including 1,000 in a specialty, can work in a team-based practice setting without physician supervision. It implements Session Law 2025-37 (North Carolina Medical Board, rule change tracker).
It’s a significant scope change for North Carolina PAs, and it landed with no press release.
The same rule package opened a licensure pathway for internationally trained physicians under 21 NCAC 32B .1362. A companion rule, 21 NCAC 32B .1403, created a route for resident-training-license holders in good standing to convert to a full physician license. Both took effect August 1, 2026.
Virginia Has a PA Rule at the Governor’s Desk
An amendment to 18VAC85-50-110(1) was at the Governor’s office as of August 7, 2026. It would, in the Board’s own words, “reduce requirements for consultation and collaboration with the patient care team physician or podiatrist” (Virginia Regulatory Town Hall, action 6295). It has no effective date yet.
The PA Licensure Compact Still Issues Nothing
It reached 29 enacted states when Michigan joined in July 2026, which sounds like more progress than it is. Its own August 28, 2026 newsletter says plainly: “No states are actively issuing privileges yet,” with a working database projected for early 2027 (PA Licensure Compact, August newsletter).
What Changed for Nurse Practitioners and CRNAs?
Two proposals, both still open questions.
Georgia Would Double the APRN Protocol Ratio
Proposed Chapter 410-11 would allow “eight (8) advanced practice registered nurses or the combined equivalent of eight (8) advanced practice registered nurses or physician assistants” to enter a nurse protocol agreement with one physician, up from four. It would also stop recognizing the Psychiatric/Mental Health CNS as an APRN role. The hearing was held August 13, 2026 (Georgia Secretary of State, Chapter 410-11 notice).
It hasn’t taken effect. As of September 5 the live rule on Georgia’s regulations portal still reads “Only four (4) advanced practice registered nurses may enter into a nurse protocol agreement with a delegating physician at any one time,” the Psychiatric/Mental Health CNS is still a recognized role and the old association name is still in the text (Georgia Rules and Regulations, Chapter 410-11). Four is still the number.
California Would Remove an NP Certification Route
The Board of Registered Nursing proposed removing the NP certification equivalency route known as Method 3, along with narrowing patient-notice requirements, including the mandatory verbal notice that an NP is not a physician. The notice is dated July 2, 2026 and the comment period closed August 25, 2026 (California Board of Registered Nursing, proposed NP rule). No adoption notice yet.
What’s Happening With Medicare Telehealth?
Two provisions in CMS’s proposed rule carry the same expiration: December 31, 2027. CMS proposes “conforming regulatory changes to implement the Consolidated Appropriations Act, 2026 Section 6209(c) to require that in-person visit requirements for mental health visits not apply to any services furnished through December 31, 2027.” The same statute, CMS writes, “extended the authority for CMS to pay RHCs and FQHCs for non-behavioral health visits furnished via telecommunication technology through December 31, 2027" (CMS, CY2027 PFS fact sheet).
The proposed rule was published July 16, 2026 and runs from 91 FR 43842 to 44557. Its Section II.C covers payment for Medicare telehealth services. It sets its own deadline: “To be assured consideration, comments must be received at one of the addresses provided below, by September 14, 2026" (Federal Register, CY2027 PFS proposed rule).
The comment period on the CY2027 fee schedule closes September 14, 2026, nine days out.
One thing we’re deliberately not saying: CMS’s fact sheet doesn’t restate an expiration for the broader geographic and originating-site waivers, so we aren’t putting a date on those.
What’s on the Calendar
- Sept 14, 2026
- CY2027 Medicare PFS comment period closes.
- Sept 20, 2026
- Alaska’s compacts take effect. Applications are not yet open.
- Sept 23, 2026
- Virginia’s opioid and buprenorphine prescribing rule (18VAC85-21) takes effect.
- Oct 22, 2026
- Virginia’s CE-requirement reference-cleanup rule (18VAC85-20) takes effect.
- Oct 29, 2026
- New Mexico IMLC rules comment deadline, 3:00pm MDT.
- Nov 5-6, 2026
- New Mexico Medical Board IMLC rules hearing.
New Mexico is the next compact state to watch. Senate Bill 1 was signed February 5, 2026. The board expects to go live in December 2026 or January 2027, once rulemaking finishes (New Mexico Medical Board, IMLC page).
Key Takeaways
- Alaska joins the IMLC on September 20, 2026 and won’t be accepting compact applications on that date.
- California, New York and Virginia are not IMLC members. They hold 1,233 of the locum tenens opportunities posted to Locumpedia as of September 5, 2026.
- North Carolina PAs with 4,000 clinical hours can practice in team-based settings without physician supervision as of August 1, 2026.
- The PA Licensure Compact has 29 states and issues nothing, with a database projected for early 2027.
- Two Medicare telehealth provisions expire December 31, 2027: the mental-health in-person waiver and RHC/FQHC non-behavioral telehealth. Comments close September 14, 2026.
Frequently Asked Questions
Can a physician use the Interstate Medical Licensure Compact in Alaska on September 20, 2026?
No. Alaska’s compact laws take effect September 20, 2026, but the state medical board is still crafting implementation plans and is not yet issuing or accepting Interstate Medical Licensure Compact applications.
Which high-volume states are not in the Interstate Medical Licensure Compact?
California, New York and Virginia. Together they hold 1,233 of the locum tenens opportunities posted to Locumpedia as of September 5, 2026. None of the three is an IMLC member.
Can a physician assistant get a compact privilege yet?
No. The PA Licensure Compact reached 29 enacted states in July 2026 but is not issuing privileges. A working database is projected for early 2027.
Locum Law describes what state boards, compacts and federal agencies have published. It isn’t legal advice. Every rule here was read at its primary source on the date shown. Where a rule is proposed rather than enacted, we say so.