Temporary Licensure

In response to the COVID-19 public health emergency, states have taken measures to alleviate the occupational licensure policy burdens that impede state response efforts and which are counterintuitive to social distancing practices. The following information presents a collection of policy actions states have implemented to temporarily license practitioners.

COVID-19 has caused significant pressures on state healthcare workforces. States have therefore sought to allow previously unlicensed individuals the option to assist response efforts when they may have training and experience that is not currently recognized by the state through a license. These individuals have been identified in four primary groups, including:

- In-Training/Student Practitioners
- Out-of-State Practitioners (may include those trained/licensed in another country)
- Retired or Inactive Practitioners
- Volunteers

Click to view each state’s actions

Alabama

Out-of-state Practitioner Temporary License

- - State Board of Medical Examiners Emergency Rule – Allows for the licensure of out-of-state physicians, physician assistants and anesthesiologists.
  - 5th Supplement to State of Emergency – The Board of Pharmacy, Board of Nursing, the Medical Licensure Commission, and the State Board of Medical Examiners shall adopt emergency rules w/in 3 business days of this proclamation to allow expedited and/or temporary permits as long as they have active licenses in other states.

Retired or Inactive Practitioners

- - 5th Supplement to State of Emergency – Orders the Alabama State Board of Medical Examiners and the Medical Licensure Commission to adopt emergency rules that provide expedited reinstatement of medical licenses.

Alaska

Out-of-state Practitioner Temporary License

- - Senate Bill 421 – Authorizes the Commissioner of the Department of Commerce, Community, and Economic Development to grant licenses, for out-of-state practitioners.

Colorado

In-training/Student Practitioners

- - EO 2020 038 – Temporarily suspend the following State Board of Nursing (SBON) Rules in 3 CCR 716-1 to facilitate the completion of nursing and nurse aide students’ studies to make additional professionals available to the healthcare workforce as soon as possible:
  - EO 2020 063, (Extending EO 2020 038) – Extends EO 2020 038 and its provisions.

Connecticut

In-training/Student Practitioners

- - EO 7DD – Allows in-training practitioners to participate in intern, resident physician, or medical officer training, or resident physician assistant programs without a permit; also allows respiratory care therapist and technician students to practice during the emergency.

Out-of-state Practitioner Temporary License

- - EO 7DD – Allows the Commissioner of Public Health to suspend licensure requirements for certain out-of-state health care practitioners.
  - EO 7HHH – Takes several emergency actions in response to the COVID-19 outbreak and the governor’s civil preparedness and public health declarations, including: Authorization for continued temporary suspension of the requirements for licensure, certification, or registration of out-of-state providers.

Delaware

Out-of-state Practitioner Temporary License

Retired or Inactive Practitioners

- - Twelfth Modification: State of Emergency Declaration – Allows any individual who has at any time held an active license to practice medicine in the United States which is now inactive, expired or lapsed to provide healthcare services in Delaware as a volunteer.

VolunteerS

- - Twelfth Modification: State of Emergency Declaration – Allows any individual who has at any time held an active license to practice medicine in any United States jurisdiction, which is now inactive, expired or lapsed, may be activated to provide healthcare services on a volunteer basis in Delaware.

Florida

Out-of-state Practitioner Temporary License

- - Executive Order 20-52 – Allows licensed, out-of-state medical professionals, social workers and counselors to practice in Florida if free of charge and under the auspices of the American Red Cross or the Department of Public Health.
  - Executive Orders 20-114 and 20-166 – Extends Executive Order 20-52 which allows licensed, out-of-state medical professionals, social workers and counselors to practice in FL if free of charge and under the auspices of the American Red Cross or the Department of Public Health.

Georgia

In-training/Student Practitioners

- - EO 3.23.20.02 – Allows temporary licensing for graduate registered and practical nurses who have yet to take their respective licensing exams.

Out-of-state Practitioner Temporary License

- - EO 3142001 – Allows for pharmacist licenses for out-of-state practitioners.
  - EOs 04.08.20.02, 4.30.30.01. 5.28.20.01, and 6.29.20.01 – Extend the Public Health State of Emergency declared by EO 03.14.20.01 which allows temporary pharmacist licenses for out-of-state practitioners.

Retired or Inactive Practitioners

- - EO 3.23.20.02 – Allows certain medical professionals with expired licenses to practice.

Hawaii

Out-of-state Practitioner Temporary License

- - EO 20-04 – Specifies which out-of-state professionals will be allowed to practice in Hawaii.

Retired or Inactive Practitioners

- - EO 20-05 – Allows occupational therapists, to the extent necessary to allow those previously licensed pursuant to chapter 457G, HRS, but who are no longer current and active, to practice in Hawai’i without a license; provided that they have never had their licenses revoked or suspended.

Idaho

In-training/Student Practitioners

Retired or Inactive Practitioners

- - State Board of Medicine Protocol 1 – Licensing for retired/inactive practitioners; waiver of all application fees related to medical licensure.
  - March 23rd Proclamation – Suspends several regulations to ease licensing for medical professionals, including retired practitioners.

Illinois

Out-of-state Practitioner Temporary License

Retired or Inactive Practitioners

- - IDFPR Proclamation – Restores physician and physician assistant licenses that expired less than 3 years ago; restores nurse and respiratory therapist licenses that expired less than 5 years ago; restored licenses require no fees or continuing education.
  - EO 2020-12 – Allows an individual to resume work as a certified nursing assistant if they have been inactive on the Health Care Worker Registry for no more than 5 years.
  - EO 2020-33, EO 2020-39, EO 2020-44, EO 2020-48 – Renews EO 2020-12; Allows an individual to work as a certified nursing assistant if they have been inactive on the Health Care Worker Registry if the individual has been in inactive status for a period of no more than 5 years.

Indiana

In-training/Student Practitioners

- - EO 2020-21 – Creates temporary licensure for recent pharmacy graduates.
  - EO 2020-33 – Renews provisions of EO 20-19 and EO 20-21; Creates temporary licensure for recent pharmacy graduates; waives the rule prohibiting the waiver of educational requirements for EMS licensure.

Out-of-state Practitioner Temporary License

- - EO 2020-05 – Allows licensed out-of-state medical professionals to practice in Indiana.
  - EO 2020-33 – Extends provisions of EO 20-19 and EO 20-21 allowing healthcare practitioners currently or previously licensed in another state to obtain a temporary license.

Retired or Inactive Practitioners

- - EO 2020-19 – Authorizes retired and inactive EMS professionals to practice if they been actively licensed within the past 5 years.
  - EO 2020-33 – Renews EO 2020-19; Allows any EMS professional to provide supplemental health care services without reinstatement or approval by the Indiana EMS Commission if they held a license within the last five years that has not been revoked, suspended or relinquished.

Iowa

In-training/Student Practitioners

- - 3/26 Proclamation of Disaster Emergency – Suspends regulatory provisions which limit the number of clinical hours that can be satisfied through simulation activities for nursing students.

Out-of-state Practitioner Temporary License

Retired or Inactive Practitioners

Kansas

In-training/Student Practitioners

- - EO 20-26 – Allows temporary licensure of students and military medical personnel in roles supporting COVID response or as “respiratory therapist extenders” under supervision.
  - EO 20-28 – Temporary aide authorization for persons with minimum training within a nursing facility; temporary authorization for non-licensed workers in long-term care facilities; allows temporary licensure of students. Extends EO 2020-01 through EO 2020-26.

Out-of-state Practitioner Temporary License

- - House Bill 2016a – Allows a healthcare professional licensed and in good standing in another state to practice such profession in the state of Kansas.

Retired or Inactive Practitioners

VolunteerS

- - HB 2016a – Allow a student who is enrolled in a program to become a licensed, registered or certified healthcare professional to volunteer for work within such facility in roles that are appropriate to such student’s education, training and experience.

Kentucky

Out-of-state Practitioner Temporary License

- - Board of Medical Licensure Notice – Medical and Osteopathic physicians not already licensed to practice in the Commonwealth of Kentucky may register to practice within Kentucky during the state of emergency

Retired or Inactive Practitioners

- - Board of Medical Licensure Notice – Medical and Osteopathic physicians not already licensed to practice in the Commonwealth of Kentucky may register through the board’s website
  - Executive Order 2020-265 – Suspends rule that prohibits employers that utilize the state retirement system from rehiring retired members, applies to law enforcement, EMS, firefighters, park rangers, and corrections officers

Louisiana

In-training/Student Practitioners

Out-of-state Practitioner Temporary License

- - Proclamation JBE 2020-29 – Suspends licensure requirements for licensed out-of-state medical professionals.
  - Proclamations JBE 2020-52, JBE 2020-59, JBE 2020-75, JBE 2020-84, JBE 2020-97, and JBE 2020-102 – Extend all prior proclamations and extends state of emergency.

Retired or Inactive Practitioners

- - HB 363 – Enact R.S. 37:764.1 and 795(B)(1)(o), relative to retired volunteer dental hygienists; to authorize the licensure of retired dental hygienists who provide voluntary dental hygiene services; to provide for the procedures and requirements to obtain a retired volunteer dental hygienist license; to provide for a limitation of liability for retired volunteer dental hygienists and an exception to the limitation of liability; to provide for a return to active licensure status; to provide a renewal date; to provide for fees and costs; and to provide for related matters.

VolunteerS

- - HB 363 – Provides procedures and requirements to obtain a retired volunteer dental hygienist license, a limitation of liability for retired volunteer dental hygienists and an exception to the limitation of liability.

Maine

Out-of-state Practitioner Temporary License

- - Executive Order 16 – Allows for the emergency licensure of physicians, physicians assistants and nurses who are licensed in another state

Retired or Inactive Practitioners

- - Executive Order 16 – Allows physicians, physician assistants, and nurses to practice if they retired within the last 2 years
  - Executive Order 35 – Allows unlicensed individuals who were licensed in a health care profession and in good standing to reactivate their license upon request

Maryland

Out-of-state Practitioner Temporary License

- - Executive Order (March 5, 2020) – Allows any person who holds a valid, unexpired license as a health care practitioner that is issued by another state to, at a health care facility in Maryland, engage in the activities authorized under that license

Retired or Inactive Practitioners

- - Executive Order (3/16/2020) – Allows any inactive practitioner to engage in activities that would have been authorized under their inactive license without reinstating their license

Massachusetts

In-training/Student Practitioners

- - COVID-19 Order No 24 – Authorizes RN or LPN program graduates to practice and exempts them from prohibitions against unlicensed practice

Out-of-state Practitioner Temporary License

- - COVID-19 Order No 23 – Creates expedited licensure for physicians who are graduates of International Medical Schools and are currently practicing in the US under limited licenses
  - State Department of Public Health Order – Issues licenses to out-of-state health care providers who are licensed in good standing with another state

Retired or Inactive Practitioners

- - Commissioner of Public Health Order, Expanded Practice – Individuals who have been licensed to practice as a health care provider in Massachusetts within the last ten years and whose license has expired, lapsed or been retired but is not revoked, suspended, surrendered or subject to any non-disciplinary restriction shall have their licenses immediately renewed or reactivated upon request, notwithstanding the applicant’s completion of continuing education, or reactivation requirements, and shall remain valid until 90 days following the termination of the state of emergency

Michigan

In-training/Student Practitioners

Out-of-state Practitioner Temporary License

- - Executive Order 2020-30 – Provides out-of-state and healthcare students the ability to practice

VolunteerS

- - EO 2020-104 – As long as section 11 of the Emergency Management Act remains in effect, anyone establishing, volunteering, or working at a community testing location constitutes personnel of a disaster relief force, and with respect to the activities of COVID-19 testing are entitled to the same rights and immunities as provided by law for the employees of this state under MCL 30.41

Minnesota

Out-of-state Practitioner Temporary License

- - Emergency Executive Order 20-46 – Allows licensure for out-of-state healthcare professionals who would otherwise be required to obtain a license to practice in Minnesota
  - Emergency Executive Order 20-28 – Allows for telehealth services from in- and out-of-state practitioners

Mississippi

Out-of-state Practitioner Temporary License

- - State Board of Medical Licensure Proclamation – Authorizes Out-of-state physicians to provide telemedicine services without the necessity of securing a license to practice medicine in the state

Missouri

Out-of-state Practitioner Temporary License

- - Executive Order 20-04 – Allows out-of-state doctors to practice in Missouri without a special license

Retired or Inactive Practitioners

- - Executive Order 20-04 – Exempts retired physicians from applying for reinstatement

Montana

Out-of-state Practitioner Temporary License

- - Directive Implementing EOs 2-2020 and 3-2020 – Activates statutory provision allowing for licensure of out-of-state health professionals.
  - Directive implementing EOs 2 and 3 and easing licensing requirements for health care providers during the emergency – Allows licensing of out-of-state licensed health care professionals.

Retired or Inactive Practitioners

- - Directive implementing EOs 2 and 3 and easing licensing requirements for health care providers during the emergency – Includes temporary reactivation of inactive, retired, and non-disciplinary terminated Montana health care licenses for those who have left the practice in the last 5 years without needing to meet requirements.

Nebraska

In-training/Student Practitioners

- - EO 20-10 – Provides for temporary licensure of recent graduates of medical training programs who pass a background check; exempts these applicants from submitting test scores.
  - EO 20-27 – Executive order suspends statutory provisions requiring advanced practice nursing, emergency medical services, medical radiology, medicine and surgery, mental health practice, nursing, nursing home administration, pharmacy, physical therapy, psychology, respiratory care, and surgical assisting personnel to complete an exam. A provisional credential is issued that is active until December 31st or completion of the exam. In person training for all of the professions and experience requirements for emergency medical personnel are waived until the end of the year.

Out-of-state Practitioner Temporary License

- - EO 20-10 – Allows licensed out-of-state physicians, nurses, pharmacists and other medical professionals to practice in Nebraska without further certification.
  - Executive Order 20-27 – Allows out-of-state medication aids to practice in Nebraska until 30 days after the state of emergency ends.

Retired or Inactive Practitioners

- - EO 20-10 – Temporary reinstatement of lapsed licenses.

Nevada

In-training/Student Practitioners

- - Declaration of Emergency Directive 011 – Activates statutory provision (NRS 114.110.2) suspending requirements for licensure for all skilled medical personnel, including physicians, PAs, nurses, and technicians; Students of medical professions may provide emergency treatment under supervision of a licensed practitioner; All medical personnel are permitted to practice outside the scope of their licenses as necessary

Out-of-state Practitioner Temporary License

- - Declaration of Emergency Directive 011 – Waives and exempts licensing requirements for licensed health care practitioners who are licensed in another state; Provides the Chief Medical Officer the authority to waive and exempt licensing requirements for health care practitioners trained in another country not currently licensed in the United States

Retired or Inactive Practitioners

- - Declaration of Emergency Directive 011 — Suspends requirements for licensure for formerly licensed retired professionals.

New Hampshire

Out-of-state Practitioner Temporary License

- - Executive Order 2020-04 #15 – Allows for licensed out-of-state medical providers to practice in New Hampshire under an emergency license

Retired or Inactive Practitioners

- - Emergency Order 46 – Emergency order allows the reactivation of medical personnel previously licensed in New Hampshire or another jurisdiction in the last three years on a temporary basis for the duration of the State of Emergency

New Jersey

Out-of-state Practitioner Temporary License

- - EO 112 – Authorizes the Division of Consumer Affairs to license any physician who is licensed in another country

Retired or Inactive Practitioners

- - EO 112 – Reactivation of any health care licenses for individuals retired within the last 5 years
  - EO 130 – Allows retired or inactive professionals to provide care. Allowances are temporary and apply for the duration of the state of emergency.

New Mexico

Out-of-state Practitioner Temporary License

- - Executive Order 2020-20 – Authorizes nursing professionals licensed in any province or territory of Canada to work in New Mexico health care facilities during declared public emergency
  - Executive Order 2020-020 – Orders the Department of Health and Department of Homeland Security and Emergency Management to credential out-of-state professionals who can render aid and necessary services

New York

In-training/Student Practitioners

- - Executive Order 202.10 – Allows students in programs to become licensed in New York State to practice as healthcare professionals and to volunteer at healthcare facilities for educational credit

Out-of-state Practitioner Temporary License

- - Executive Orders (list) – allowing nurses, physicians assistants, physicians, respiratory therapists, and midwives licensed in other states to practice in New York

North Carolina

In-training/Student Practitioners

- - EO 130 – Skilled but unlicensed volunteers and students at an appropriately advanced stage of professional study are authorized to provide care. Allowances are temporary and apply for the duration of the state of emergency.

Out-of-state Practitioner Temporary License

- - EO 116 – Waives licensure requirements for health care and behavioral health care personnel licensed in another state.
  - EO 130 – Executive order allows persons licensed in other states to provide medical care. It also allows retired or inactive professionals to provide care. Allowances are temporary and apply for the duration of the state of emergency.

VolunteerS

- - EO 130 – Skilled but unlicensed volunteers and students at an appropriately advanced stage of professional study are authorized to provide care. Allowances are temporary and apply for the duration of the state of emergency.

North Dakota

Out-of-state Practitioner Temporary License

- - Executive Order 2020-05.01 – Allows licensed out-of-state providers to practice in North Dakota

Oklahoma

In-training/Student Practitioners

- - EO 2020-13 – Actions include reducing supervisory requirements or limitations placed on non-physicians, and to increase opportunities for students and recent graduates who are not yet fully licensed

Out-of-state Practitioner Temporary License

- - EO 2020-07 – Allows out-of-state licensed medical and allied health providers to practice in Oklahoma

Retired or Inactive Practitioners

- - EO 2020-07 – Allows nurses and nurse’s aides with lapsed licenses to renew without completing continuing education requirements
  - EO 2020-13 – Executive order directs Board of Medical Licensure and Supervision, State Board of Osteopathic Examiners, and Board of Nursing to promulgate rules necessary to increase the number of professionals able to practice. Actions include removing barriers for re-entry of inactive or retired practitioners.

Oregon

Out-of-state Practitioner Temporary License

Retired or Inactive Practitioners

- - Oregon Administrative Rule 847-010-0068 – Allows those with lapsed Oregon licenses to practice in Oregon under a temporary license; waives reactivation fees; removes restrictions on practice by emeritus licensees.

Pennsylvania

In-training/Student Practitioners

Out-of-state Practitioner Temporary License

Retired or Inactive Practitioners

- - PA Dept of State Waiver – Waives the regulations and costs of reactivating inactive and expired licenses for nursing home administrators, practical nurses (LPNs), psychologists, and social workers
  - PA Dept of State Waiver – Medical personnel licensed by the State Board of Medicine, Osteopathic Medicine, Nursing, and Pharmacy who are retired are allowed to practice during emergency

Rhode Island

Retired or Inactive Practitioners

- - EO 20-37 – Suspends statutes related to public retirement such that RI Dept. of Health may permit specific state retirees to temporarily return to work in order to combat the pandemic

South Carolina

In-training/Student Practitioners

- - Commissioners of Pilotage Emergency Rule 136-100 – Provides for issuance of temporary ship pilot’s licenses to current pilotage apprentices
  - Board of Dentistry Emergency Rule 39-19 – Allows dental school graduates to gain limited licensure, without an examination, in order to enroll in their residency experiences as scheduled

Out-of-state Practitioner Temporary License

- - EO 2020-08 – Authorizes the state Medical Board to provide and expedite licensure for out-of-state physicians, physician assistants, and respiratory care practitioners

Retired or Inactive Practitioners

- - Commissioners of Pilotage Emergency Rule 136-100 – Provides for issuance of temporary ship pilot’s licenses to current pilotage apprentices and waives 70-year age limitation for recertification of retirees

South Dakota

In-training/Student Practitioners

- - EO 2020-16 – Waives practical experience requirements for pharmacist & pharmacy tech licensure; Suspends pharmacy tech certification exam requirement; Allows pharmacists to administer immunizations without active CPR certification
  - EO 2020-25 – Suspends examination requirements for new licensees in a wide range of healthcare-related professions

Tennessee

In-training/Student Practitioners

Out-of-state Practitioner Temporary License

- - EO 14 – Allows health care professionals licensed in another state, and who would otherwise be subject to licensing requirements, to practice in Tennessee

Texas

In-training/Student Practitioners

Out-of-state Practitioner Temporary License

Retired or Inactive Practitioners

VolunteerS

- - Press Release: Governor Abbott Suspends Regulations To Increase EMS, First Responder Workforce – Allows individuals who are qualified though not formally licensed to provide critical emergency response services, suspends certain skills testing requirements so that both in-state and out-of-state EMS personnel who are qualified but unable to take the skills test may provide services, and suspends regulations to allow first responder organizations to delay submission on their renewal application and completion requirements for licensure.
  - Waiver of Certified Nurse Aide Requirements – Suspends four-month limitation on employment of uncertified individuals as nurse aides in long-term care facilities.

Utah

Out-of-state Practitioner Temporary License

- - Emergency Declaration – Declared state of emergency suspends provisions under Utah Telehealth Act restricting practice of telehealth, including requirement that a telehealth provider be in compliance with applicable laws & rule regarding the provider’s licensed practice

Retired or Inactive Practitioners

- - Division of Occupational and Professional Licensing Waivers– Expedited licensure for professionals with expired or lapsed licenses while in good standing; volunteer licenses for formerly licensed medical professionals

Vermont

In-training/Student Practitioners

- - House Bill 742 – Provides temporary licensure for new graduates of health care and mental health professionals

Out-of-state Practitioner Temporary License

- - House Bill 742 – Provides expedited licensure for licensed out-of-state health care and mental health professionals

Retired or Inactive Practitioners

- - House Bill 742 — Provides expedited, temporary licensure for retired health care and mental health professionals

Virginia

In-training/Student Practitioners

Out-of-state Practitioner Temporary License

- - Executive Order 57 (amended) – Allows out-of-state licensed medical and mental health professionals to practice during the emergency; allows telehealth across state lines is allowed if a prior doctor-patient relationship exists.
  - Board of Pharmacy Waivers (Revised May 4) – Allows licensed out-of-state pharmacists and pharmacy technicians to practice in Virginia.

Retired or Inactive Practitioners

- - Department of Health Professions Waiver – Waives fees and continuing education requirements for unencumbered licenses of those who retired within the last 4 years.
    - Authorized under Executive Order 51
  - Board of Nursing Fee and Continuing Education Waiver – Board of Nursing waives fees and CE requirements for renewal or reinstatement of an RN, LPN, or NP license that expired within the past four years.

Washington

In-training/Student Practitioners

Out-of-state Practitioner Temporary License

- - Department of Health Announcement – Emergency Proclamation activates the Emergency Volunteer Health Practitioner Act, allowing out-of-state healthcare practitioners the ability to volunteer services in the state

Retired or Inactive Practitioners

- - Proclamation 20-32 – Waives restrictions on practice by retired active medical, nursing, and mental health licensees
  - Dept. of Health Emergency Rule 20-10-014 – Waives nursing continuing education requirements for active retired licensees

VolunteerS

- - Proclamation 20-32 – Waives barriers to practice by healthcare provider volunteers

West Virginia

In-training/Student Practitioners

- - EO 11-20 – Eases requirements for issuance of temporary permits for medical students to practice respiratory care.
  - EO 31-20 – Suspends requirement for clinical exams for initial dentist and dental hygienist licensees; provides for issuance of provisional licenses to 2020 graduates of dental education programs.

Out-of-state Practitioner Temporary License

Retired or Inactive Practitioners

- - EO 10-20 – Allows retired physicians to return to practice sans re-certifying.

Wisconsin

In-training/Student Practitioners

- - Emergency Order 21
    - EMT Licensure Provisions: Waives requirement that EMS training be completed within 2 years before applying for license; Waives CPR training requirement for EMT license renewal; Allows EMT training permits to be renewed (normally prohibited)
    - Nurse Aide Training Provisions: Allows nurses with less than 2 years of experience to serve as nurse aide instructors; Suspends requirement that nurse aide instructors complete an approved training course; Suspends 120-hour training minimum for nurse aides (16 hours still required); Suspends some nurse aide supervision requirements

Out-of-state Practitioner Temporary License

- - Emergency Order 16 – Allows licensed out-of-state medical doctors to practice in Wisconsin
  - Act 185 (2020) – Codifies licensure for out-of-state medical professionals

Retired or Inactive Practitioners

MODIFICATION OF LICENSING REQUIREMENTS

TEMPORARY LICENSURE

TELEHEALTH

SCOPE OF PRACTICE

INTERSTATE COMPACTS

All Actions

The executive orders, administrative orders and legislation included in this web resource represent a sample of the actions states have enacted in response to COVID-19. Therefore, this resource is not intended to be represented as an exhaustive list of state actions, but rather used to review the variances in strategies states have implemented through occupational licensing policy to effectuate response efforts. The descriptions of the policy actions have been summarized to include relevant detail but should be viewed in full for their entire context. CSG will continue to update the list of policy actions throughout the duration of the state public health emergency response and recovery efforts.