How NLC Compact Changes Affect Employers
The Nurse Licensure Compact (NLC) now includes 41 member states, up from 25 in 2018. For healthcare employers, this expansion means a single nurse can practice across 41 states without separate license applications — but only if the employer understands compact eligibility rules, verification requirements, and the limitations that still apply. Nine states remain outside the compact, and they include some of the largest healthcare markets in the country.
What is the NLC and how has it expanded?
The NLC is an interstate agreement that allows registered nurses (RNs) and licensed practical/vocational nurses (LPN/LVNs) to hold one multistate license issued by their primary state of residence. That license grants practice authority in every other compact member state.
Expansion timeline:
| Year | Member States | Key Additions |
|---|---|---|
| 2018 | 25 | Enhanced NLC launched |
| 2020 | 34 | Pandemic accelerated adoption |
| 2022 | 37 | Several states fast-tracked legislation |
| 2024 | 39 | Continued steady growth |
| 2026 | 41 | Plus several states with pending legislation |
The original NLC launched in 2000. The enhanced NLC (eNLC) replaced it in 2018 with stricter uniform licensure requirements, including federal and state criminal background checks. All current compact states operate under the enhanced version.
According to the National Council of State Boards of Nursing (NCSBN), compact states now cover approximately 80% of the US population. That’s significant — but the 20% gap includes some critical markets.
For current membership status and pending states, see the NLC compact page on Nurse License Guide.
Which states are NOT in the compact?
The nine non-compact states as of early 2026 represent some of the largest nurse employers and patient populations in the country.
Notable non-compact states:
| State | Approximate RN Workforce | Significance |
|---|---|---|
| California | 300,000+ | Largest nursing workforce in the US |
| New York | 200,000+ | Major healthcare hub, NYC concentration |
| Illinois | 130,000+ | Chicago-area health systems |
| Oregon | 45,000+ | Pacific Northwest coverage gap |
| Alaska | 8,000+ | Remote care access challenges |
Why these states haven’t joined:
The reasons vary, but common objections include:
- Revenue concerns: State boards lose application fee income when out-of-state nurses don’t need individual licenses
- Regulatory control: Boards worry about oversight of nurses practicing under another state’s license
- Scope of practice differences: Some states have broader practice authority than the compact’s baseline requirements
- Political dynamics: Nursing unions in some states have opposed compact participation, citing concerns about wage impacts from increased labor mobility
California is the most consequential holdout. Its Board of Registered Nursing has studied compact membership multiple times, and legislation has been introduced but hasn’t advanced. Given that California employs more nurses than any other state, its absence from the compact creates a nationwide gap.
How does compact verification work?
Verifying a nurse’s compact privilege isn’t the same as verifying a traditional single-state license. Employers need to check both the multistate license status and the nurse’s primary state of residence.
NURSYS verification
NURSYS, operated by NCSBN, is the primary verification system for compact licenses. It provides:
- Real-time license status (active, inactive, suspended)
- Multistate privilege status (yes/no)
- Disciplinary action history
- Primary state of residence
Cost: $30 per verification for employers (free for nurses checking their own license).
What employers must verify
| Check | Why It Matters |
|---|---|
| Active multistate license | Confirms current practice authority |
| Primary state of residence | Must be a compact state; if nurse moves to non-compact state, multistate privilege ends |
| Discipline in any compact state | A disciplinary action in one state can trigger action across all compact states |
| License type | Compact applies to RN and LPN/LVN only — not APRNs |
The residence requirement trap
This is the most common employer compliance mistake with compact licenses. A nurse’s multistate privilege is tied to their primary state of residence. If a nurse with a Texas (compact state) multistate license moves to California (non-compact state), they lose their multistate privilege.
The nurse must then:
- Obtain a California single-state license
- Obtain individual licenses in any other state where they wish to practice
Employers with traveling or relocating nurses need to track residence changes. A nurse who moved six months ago might still be practicing under a multistate license that’s no longer valid.
What does the compact mean for staffing agencies?
Travel nursing and staffing agencies see the most direct financial impact from compact expansion. Every new compact state eliminates a licensing bottleneck.
Before compact (or in non-compact states):
| Step | Time | Cost |
|---|---|---|
| Identify assignment | Week 1 | - |
| Apply for state license | Week 1-2 | $100-$300 |
| Background check processing | Week 2-6 | $30-$100 |
| License issued | Week 6-16 | - |
| Nurse starts assignment | Week 6-16+ | Revenue begins |
| Total delay | 6-16 weeks | $130-$400 |
With compact license:
| Step | Time | Cost |
|---|---|---|
| Identify assignment | Week 1 | - |
| Verify compact privilege | Day 1 | $30 |
| Nurse starts assignment | Week 1-2 | Revenue begins |
| Total delay | 1-2 weeks | $30 |
The time savings dwarf the cost savings. Getting a nurse on assignment 4-14 weeks sooner translates to tens of thousands in billing revenue per placement.
For a staffing agency placing 500 nurses per year across compact states, the compact eliminates an estimated $50,000-$200,000 in annual licensing costs and weeks of administrative processing per placement. That’s a conservative estimate based on average application fees and staff processing time.
How does the compact affect health systems?
Hospitals and health systems benefit from the compact differently than staffing agencies.
Permanent workforce
For health systems with a stable workforce primarily in one state, the compact’s direct impact is modest. Nurses employed full-time at a single facility don’t typically need multi-state licenses.
However, the compact does:
- Expand the hiring pool — nurses in neighboring compact states can accept positions without licensing delays
- Support float and per diem staffing — PRN nurses living across state lines can pick up shifts
- Enable telehealth expansion — nurses can provide telehealth to patients in other compact states
Disaster and surge capacity
The compact proved its value during COVID-19. Health systems in hard-hit areas could rapidly deploy nurses from compact states without waiting for emergency license waivers.
Without the compact, deploying out-of-state nurses during a surge requires either:
- Emergency executive orders waiving licensing (uncertain timeline, limited duration)
- Pre-positioned licenses in states where surge capacity might be needed (expensive, speculative)
Multi-facility systems
Health systems operating hospitals across multiple states see major benefits. A system with facilities in Georgia, Tennessee, Virginia, and North Carolina (all compact states) can deploy nursing staff across facilities without separate licenses for each state.
What doesn’t the compact cover?
Employers who assume “compact = done” for multi-state compliance will run into problems. Key limitations:
APRNs are excluded. Nurse practitioners, certified nurse midwives, clinical nurse specialists, and CRNAs need individual state licenses everywhere they practice. The APRN Compact exists but has only a handful of member states as of 2026. This is the single biggest gap for telehealth employers.
State practice rules still apply. Having a compact license lets you practice in another state, but you must follow that state’s scope of practice laws, not your home state’s. A nurse whose home state allows independent practice for certain procedures might face restrictions in a state with more conservative scope laws.
Discipline is shared. A disciplinary action in one compact state triggers notification to all other compact states and the nurse’s home state. This is by design, but it means employers need to monitor discipline status across all compact states, not just the state of employment.
The compact doesn’t cover every nursing role. Some states require additional certifications or registrations beyond the RN license for specific roles (school nursing, correctional nursing, certain telehealth roles). These requirements apply regardless of compact status.
What should employers do now?
Audit your current licensing approach. Identify which of your nursing staff hold multistate licenses versus single-state licenses. For nurses in compact states with single-state licenses, encourage them to convert to multistate — it costs nothing extra in most states.
Update your credential verification process. Ensure your system distinguishes between single-state and multistate licenses, tracks primary state of residence, and monitors compact privilege status through NURSYS.
Plan around non-compact states. If you operate in California, New York, Illinois, or other non-compact states, you still need full licensing infrastructure for those states. Don’t dismantle your per-state licensing process — just optimize it for compact states where you can.
Watch pending legislation. Several states have compact legislation in various stages. When a state joins the compact, there’s typically a 6-12 month implementation period before compact privileges become active. Getting ahead of these timelines lets you plan workforce deployment in advance.
Budget accordingly. The compact reduces but doesn’t eliminate multi-state licensing costs. APRNs still need per-state licenses, non-compact states still require full applications, and verification systems still cost money to operate.
For structured data on compact membership and state licensing requirements, explore our healthcare licensing guides and the License Guide API for programmatic access to licensing data across all 50 states.