Rapid Response Executive Orders for Internationally Trained Medical Professionals
WHO ARE INTERNATIONALLY TRAINED MEDICAL PROFESSIONALS?
Internationally trained medical professionals are individuals who receive their education, medical training, and experience in another country before coming to the U.S.
Across the U.S., communities face healthcare worker shortages that have been exacerbated by the ongoing COVID-19 pandemic. Governors in six states have responded by issuing executive orders that would utilize internationally trained medical professionals to expand the workforce available to healthcare providers to assist communities impacted by COVID-19.
EXECUTIVE ORDERS
The Executive Orders (EOs) issued during the COVID-19 pandemic have varied from state to state and included: suspending licensing requirements for medical professionals; reducing the length of time that graduates of a foreign medical school need to complete a postgraduate training program; and expediting licensing applications; granting limited licenses for physicians, respiratory therapists, and nurses who are licensed and in good standing in another country.
New York: Allows IMGs without a license to provide patient care in hospitals if they have completed at least one year of graduate medical education.
Michigan: Allows IMGs who are licensed and in good standing in another country, have a least five years of practice, and at least one year of practice in the last five to obtain a temporary license.
Colorado: Allows qualified IMGs to obtain a temporary license to practice under the direct supervision of a Colorado licensed physician.
Massachusetts: International Medical Graduates (IMGs) who had completed at least two years of postgraduate medical training are eligible for licensure.
Nevada: Authorized the state’s Chief Medical Officer to approve waivers of state licensing requirements for various healthcare positions, including internationally trained professionals.
New Jersey: Authorized temporary licenses for IMGs that could prove good standing, at least five years of practice, and practice experience within the last five years.
EXECUTIVE ORDER CONSIDERATIONS
Following are best practices and recommendations for implementing a limited term license by executive order.
IMPLEMENTATION
Engagement with potential employers: States and advocates must engage in robust dialogue and education with potential employers so that they understand the option and parameters of employing internationally trained medical professionals.
Clear and accessible information for potential licensees: States should provide detailed information about: who qualifies for temporary licensure; documentation required to apply; exactly how and where individuals should apply, especially if applications will be processed through a different department or portal than standard licenses.
Interagency coordination: Where applicable, cross coordination between agencies to facilitate the design of the limited term license, raise public awareness, and coordinate with potential employers to raise awareness of this new program.
ORDER LANGUAGE
Time since medical school and recent experience: This potentially leaves out individuals who came to the U.S. as refugees and were displaced for several years.
Good standing in a country where a degree was obtained: The definition of good standing can vary from country to country. It can mean someone who was in good standing before leaving or someone who has continued to maintain an active license—including paying fees—in their licensing country. This term should be defined in the order.
Immunity: States that do not include immunity language in their executive order leave questions about who must assume responsibility for obtaining malpractice insurance. This can be addressed with the appropriate regulatory agency.
LIMITED TERM LICENSE OPTIONS BY PROFESSION
Following are examples of how internationally trained medical professionals and international medical graduates (IMGs) can be incorporated into state responses to the COVID-19 pandemic.
ALLIED HEALTH & UNLICENSED POSITIONS
Paramedics, EMTs, Respiratory Therapy students, and IMGs who have specialized in Emergency Medicine would be allowed to assist healthcare facilities while working under a licensed practitioner.
Lab Technicians who assist in receiving, labeling, and analyzing COVID-19 tests would be permitted to help clean and sanitize equipment and record data.
Allow individuals working at a healthcare facility or testing site who are not licensed to assist with throat/swab specimens at COVID-19 testing sites under the supervision of a licensed individual.
Allow internationally trained social work candidates to practice under the supervision of a Licensed Social Worker or a Licensed Clinical Social Worker.
Permit Telemetry Technicians to serve in the capacity of an EKG technician.
Suspend licensing requirements for healthcare workers who would otherwise be subject to licensing requirements to provide localized treatment to patients in a temporary residence.
Allow IMGs to serve as Phlebotomists or an Outreach Specialist without attending a course to seek and take blood donations.
Allow internationally trained Pharmacists to serve as Qualified Medication Administration Personnel.
Temporarily suspend the certification/state registration for pharmacy technicians to assist in filling and dispensing medications.
Permit internationally trained Pharmacists who are FPGEC certified to fill these roles as well as graduates of pharmacy tech programs who do not yet have their PTCB certification.
Permit international medical professionals to work as Medical Assistants. Many states do not require a license to serve as an MA, but national certification is often encouraged.
LIMITED SCOPE PHYSICIANS
Allow IMGs and U.S. medical school graduates who have not completed a medical residency in the U.S. to obtain a temporary license to practice as a limited scope physician under a collaborative agreement with a licensed Medical Doctor (MD), Physician Assistant (PA), or Nurse Practitioner (NP).
The collaborating MD, PA, NP, and the medical entity would be responsible, at all times, for the oversight of the limited scope physician.
Limited scope licensees would be allowed to count their services as U.S. clinical experience on graduate medical education applications as if the student had secured a placement under a clinical affiliation agreement, without entering into any such clinical affiliation agreement.
LIMITED LICENSE REGISTERED NURSE (RN)
Internationally trained nurses seeking RN-licensure would be eligible for a temporary license if they have:
Successfully completed a credential review from CGFNS, NACES, or AICE that validates their nursing education completed outside of the U.S.
Passed the TOEFL/IELTS exam if required by the Board of Nursing.
Applied for RN-licensure with the Board of Nursing.
Obtained a valid and unexpired authorization to sit for the NCLEX board exam.
Allow RN candidates to perform Registered Nurse duties under the supervision of a licensed Nurse Practitioner or a Registered Nurse.
Allow RN candidates to perform duties at the LPN level under the supervision of a licensed RN or LPN.
Grant RN candidates a temporary Certified Nurse Aide license.
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