The Tri-Regulator Collaborative Position Statement on Practice Location for Consumer Protection

As the organizations representing the state and territorial licensing boards in the United States that regulate the practice of medicine, pharmacy and nursing, the Federation of State Medical Boards (FSMB), National Association of Boards of Pharmacy (NABP), and National Council of State Boards of Nursing (NCSBN) affirm that in a consumer protection model, health care practice occurs where the recipient of health care services is located.

The public protection mandate through state licensure is based on a patient-centered model. Patients come first and have a right to know that their health care provider is qualified and practicing safely. Patients also have a right to easily obtain information about a health care provider, including the provider’s disciplinary record. Patients who have had perceived or actual harm should be able to contact the state licensing board where the health care practice occurred.

The increased use of telehealth modalities has highlighted the need to ensure consumer protection when care crosses geographic boundaries. Patients not residing in the location of the provider deserve the same quality of regulated practice regardless of where the provider is located. The Tri-Regulator Collaborative recognizes the importance of increased access to care and the efficient use of health resources. As practice occurs across geographic areas, licensing boards face the challenge of facilitating interstate practice while ensuring public protection. All three member organizations are actively involved in identifying and implementing licensure solutions to facilitate interstate access to quality health care while at the same time ensuring high standards of public protection.

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