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Nurse Licensure Compact Update March 2025

(notes submitted by Mary O'Connor)

Act 68 of 2021 Nurse Licensure Compact was signed into law July 1, 2021 but is not fully implemented).  Multi-state licensure (MSL) for Pennsylvania’s nearly 300,000 licensed Registered Nurses and Licensed Practical Nurses is getting closer to full implementation and the following describes what is being done by the PA State Board of Nursing. 

Three areas need to be completed before there is full roll out of the Nurse Licensure Compact (NLC)in PA:

1. Temporary Regulations - SBN Board approved the Annex 

2. FBI clearances

3. Technology

1.  Temporary Regulations - SBN Board approved the Annex  (Excerpt from SBN Board Meeting, Dec. 2024.)

"Delays in implementation of the Compact is not related to the Board itself. One of the outstanding pieces to fully implementing the NLC is the ability to obtain the criminal background information.  The Department and Bureau have a good feeling about their ongoing discussions with the Federal Bureau of Investigation (FBI) about the approval of the criminal background check language recently passed by the Legislature.  Even with the Federal Bureau of Investigation approval, a second component of the background check issue is the need for a contract with a vendor to obtain and store the background check information.

The second piece to fully implementing the NLC is the technology. The Board and staff have been developing multistate license applications that are ready to roll out once there is full implementation. Technology interface between NCSBN, the Board's website, and the Department's websites and how they communicate with one another is also being developed.  

The third piece to fully implementing the NLC is regulations, noting the Legislature passed a law allowing for temporary regulations.  The Board adopted 16A-5148 Temporary Regulations for Nurse Licensure Compact at its Dec. 2024 meeting (refer to 121224-Nursing-Minutes-Final.pdf pp.24-28). Excerpts:

•  § 21.1104(a) Requirements for initial multistate licensure includes the Uniform Licensure Requirements.
• Paragraph (1) requires applicants to meet the requirements for licensure in either the Professional Nursing Law or Practical Nursing Law and the Board’s regulations.  Licensees who obtained a license under Act 41 would not qualify for a multistate license because they have not met the licensure requirements under the Practice Acts. 
• Paragraph (2) requires that applicants’ primary state of residence (PSOR) has to be in Pennsylvania. Documentation to prove PSOR is set out in Rule 9 402(3) of the NLC rules.
• Paragraphs (3) - (5) requires applicants to provide a fingerprint background check from the FBI, complete 3 hours of Child Abuse training, and possess a valid Social Security Number.
• Paragraph (6) requires that anyone who is a graduate of a foreign pre-license education program not taught in English or if the applicant’s native language is not in English must pass an English language proficiency exam.
• Paragraphs (7) and (8), applicants cannot be convicted of a felony offense related to the practice of nursing or have an encumbered license in another state. The Board decides whether a misdemeanor offense is related to the practice of nursing.
• Paragraph (10) disqualifies applicants from holding multistate licenses if they are enrolled in the Voluntary Recovery Program, Disciplinary Monitoring Unit, or Practice Educational Remediation Collaboration (PERC).
• § 21.1105. Subsection (a) the conversion process clarifies that upon full implementation all existing licenses will be converted to single state licenses; subsection (b) existing licensees will have to apply for a multistate license should they desire one.
• Paragraphs (c) and (d), existing Pennsylvania licenses who did not receive a license under 63 Pa.C.S. § 3111 (Act 41) would not be required to provide documentation evidencing their education, and where applicable, English language proficiency because that documentation was provided to the Board upon initial licensure.
• § 21.1104(c), existing Pennsylvania licensees who obtained a license under Act 41 will be required to submit the education documentation when applying for a multistate license because the alternate pathway to licensure in Act 41 is based upon a combination of equivalency in the state licensure laws and experience, not a review of applicants’ educational programs. As such, at the time a license was issued under Act 41, applicants were not required to submit evidence of completion of an approved nursing education program.
• § 21.1103(a)(3) -Because existing Pennsylvania licensees were not required to provide the FBI criminal background check when they obtained their Pennsylvania licenses, all applicants for multistate licenses must submit the background check.
• Subsection (e) reiterates the prohibition in the NLC against licensees holding multistate licenses while participating in an alternative program.
• § 21.1106 --changes to a primary state of residence; subsection (a) requires multistate licensees to document PSOR; subsection (b), if the multistate licensee moves to another party state, the PA multistate license is deactivated; subsection (c), if the move is to a non-party state, the PA license is converted to a single state license.  
• § 21.1107(a) anyone disciplined by the Board who has a multistate license in Pennsylvania would have the license automatically be converted to a single state license. Once the disciplinary order expires, the licensee is required to request conversion of the license back to a multistate license.

The fees for MSL were presented in the Annex at the Sept. 2024 Board Meeting minutes (refer to 091024-Minutes-Final.pdf):

• Renewal fees - the same for multistate and single state licenses at $76 for LPN and $122 for RN because staff is doing the same functions whether the licensee has a multistate or a single state license.
• Conversion fee from existing Pennsylvania license to a multistate license is $105.* 
• * Someone without an existing license would have to apply either for a license by endorsement, license by endorsement with exam, or a license by examination. Prices depend on whether the program is a PA-approved program, out-of-state 6 program, or foreign program because there is additional work needed to be completed. 

2. FBI & Act No. 79 of 2024 (“FBI-Approved Language to Implement Licensure Compacts” signed into law on July 17, 2024)

• BPOA - Pennsylvania Licensing System now showing FBI clearance https://www.pals.pa.gov/#!/page/default 

Effective January 13, 2025, all applicants for health care practitioner licenses must submit a full set of fingerprints to the Pennsylvania State Police for an FBI criminal history background check as a requirement for licensure. Individuals who are already licensed in Pennsylvania will not need to complete this background check to renew their current license. 
As the Department works to finalize the necessary steps to access official FBI background check results, the Bureau will temporarily continue to accept applicant-submitted FBI Identity History Summary Checks to permit applicants to complete their licensure requirements during this transitional period. FBI Identity History Summary Checks are available by clicking the link. 

3. Technology - work being done. "The Board and staff have been developing multistate license applications that are ready to roll out once there is full implementation. Technology interface between NCSBN, the Board's website, and the Department's websites and how they communicate with one another is also being developed." (refer to 121224-Nursing-Minutes-Final.pdf) 

Additional Notes:

The Commonwealth partially implemented the Nurse Licensure Compact starting Sept. 5, 2023, and registered nurses and licensed practical nurses from other states who hold multistate licenses through the Nurse Licensure Compact (NLC) can provide in-person and telehealth services to PA patients.

Health care facilities are required to have a mechanism in place to verify the licensure status of eligible MSL nurse. Facilities who want to verify the status of a nurse's MSL can go to www.nursys.com, the National Council of State Boards of Nursing's (NCSBN) central repository for licensing information, and click on "Quick Confirm." 

it will be incumbent upon employers and licensees to look at both the Pennsylvania website and the National Council of State Boards of Nursing (NCSBN) Nursys website to find people who have multistate  licenses in other states.  The Nursys eNotify program wherein employers register their nurses with NCSBN and receive updates regarding the status of their nurses’ licensure. 

 Click link to see the 43 NLC Jurisdictions and Status https://www.ncsbn.org/nurse-licensure-compact.htm