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Pennsylvania's NLC: From 2021 Law to 2025 Operational — How RNs and LPNs Convert in 2026

Pennsylvania signed the Nurse Licensure Compact in 2021, but full implementation did not arrive until July 7, 2025. Here is the conversion process, the IdentoGO fingerprint requirement, and the CE rules PA RNs and LPNs need to know in 2026.

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5 min read · by White Glove NLC

Pennsylvania nurses spent four years watching the Nurse Licensure Compact happen in other states. Governor Wolf signed Act 68 on July 1, 2021, making PA the 35th NLC state on paper — but a single FBI procedural objection over criminal-background-check language kept the law from going operational. Partial implementation arrived in September 2023 (PA recognized incoming multistate license holders but could not issue its own). Full implementation finally landed on July 7, 2025, after Governor Shapiro signed Act 79 of 2024 in July 2024 to fix the FBI language. If you are a PA RN or LPN converting to a multistate license in 2026, this is the pathway as it actually works now.

The Legislative History in One Paragraph

Three statutes did the work. Act 68 of 2021 enrolled Pennsylvania in the NLC but was held in abeyance because the FBI would not approve the bill's background-check language. Act 79 of 2024 (formerly HB 2200), signed July 17, 2024, rewrote that language to FBI specifications and authorized fingerprint-based national background checks for compact applicants. The State Board of Nursing then promulgated temporary regulations through the PA Bulletin in early 2025, and the Bureau of Professional and Occupational Affairs (BPOA) flipped the switch on July 7, 2025. PA is now a full participating state for both incoming compact privileges and outgoing multistate license issuance.

Who Qualifies to Convert

The State Board of Nursing requires every multistate applicant — whether converting an existing PA license or applying as a new graduate — to meet the NLC's Uniform Licensure Requirements. For a current PA RN or LPN, conversion eligibility comes down to:

  • Primary state of residence (PSOR) is Pennsylvania. You document this with a PA driver's license, voter registration, most recent federal tax return, military form, or a current W-2. The compact allows only one PSOR at a time.
  • Active, unencumbered PA license — no revocation, suspension, or probationary status.
  • Not currently in an Alternative to Discipline program (PA's PHMP or any equivalent in another state).
  • State and federal criminal background checks on file with the Board.

If you already hold a PA license in good standing, you do not need to resubmit your child-abuse-recognition training certificate or English-proficiency documentation — those carry over from your original licensure file. New graduates and licensure-by-endorsement applicants do still complete those steps.

The IdentoGO Fingerprint Step

The fingerprint requirement is what held PA's compact implementation up for three years, so the Board takes it seriously. The vendor is IdentoGO (operated by IDEMIA). You pre-register at uenroll.identogo.com using the service code the Board provides during your PALS application, then visit a PA IdentoGO location to be printed. Results route directly to the State Board of Nursing — do not request a copy be sent to you, as Board policy does not accept applicant-routed prints. Print appointments in metro Philadelphia and Pittsburgh fill quickly; book the appointment as soon as you have the service code, not after you finish the rest of the application. You also need a separate Pennsylvania state criminal history check through the PA State Police (PATCH system); this is a separate filing from the IdentoGO federal print and the Board needs both.

The Conversion Walkthrough on PALS

The Pennsylvania Licensing System (PALS) at pals.pa.gov is the only path — there is no paper conversion form. The flow is:

  • Log into your existing PALS account (the one you used to renew your single-state license).
  • Select your active RN or LPN license and choose "Apply for Multistate Designation."
  • Upload PSOR documentation, attest to the Uniform Licensure Requirements, and pay the $105 conversion fee.
  • Receive your IdentoGO service code; complete fingerprinting and the PATCH state check.
  • Wait for both background-check results to clear and the Board to issue the multistate designation. Your license number does not change — your record simply gains compact privileges.

For deeper details on PA application mechanics, our Pennsylvania nursing license guide walks through PALS account setup, document uploads, and Board response times.

Continuing Education — What 2026 Renewals Require

The compact does not change Pennsylvania's CE rules; it just makes them portable. RN renewals (biennial) require 30 contact hours, of which 2 hours must be Board-approved child abuse recognition and reporting. LPN renewals (also biennial) require the same 2-hour child abuse module — Pennsylvania mandates it for every renewing nurse regardless of license type. There is no general nursing-hours requirement for LPNs beyond the child abuse training.

The opioid CE rule applies separately and only to nurses with active DEA registration: under the federal MATE Act (effective for DEA registrations on or after June 27, 2023), DEA-registered practitioners must complete 8 hours of one-time training on treating and managing patients with opioid and other substance use disorders. This is a federal requirement, not a PA Board rule, but it is the most common CE gap we see on PA renewals.

Practical Notes for 2026

Three things to plan around if you are converting in 2026. First, the $105 conversion fee is in addition to your normal biennial renewal fee — converting mid-cycle does not extend your renewal date or refund unused renewal time. Second, if your PSOR is genuinely Pennsylvania but you have a non-PA driver's license (a common situation for nurses who recently moved here), update the license before applying or the PSOR documentation step will reject. Third, the Board is still working through a conversion backlog from the July 2025 launch; budget 4-6 weeks from clean fingerprint result to multistate designation rather than the 2-week target the Board publishes.

Sources: PA Department of State — Nurse Licensure Compact; NCSBN — Pennsylvania Enacts the NLC; PA Bulletin — Nurse Licensure Compact Temporary Regulations; 49 Pa. Code § 21.131 — Continuing Education; Pennsylvania Licensing System (PALS).

Pennsylvania's NLC story is a useful reminder that "the law passed" and "the license is available" are different events. Now that the operational machinery is in place, the conversion itself is straightforward — but the IdentoGO step is where 2026 files lose time. Schedule the print appointment the day your service code arrives.

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