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Practicing without a U.S. residency

Since 2023, a growing number of states have passed laws that let an internationally trained physician reach a full medical license without repeating residency in the United States. The laws are real, and in about a dozen states you can apply today. They are also narrower than the headlines, written for experienced physicians rather than recent graduates, and a license earned this way still leaves board certification, portability, and immigration unsolved.

Guide · For international medical graduates ~16 min read Status as of October 1, 2026

What changed

The ordinary route to a U.S. medical license for an international medical graduate runs through ECFMG certification, the USMLE, and one to three years of ACGME-accredited residency, with the number of years set by each state1. Training completed abroad, however long and however good, has generally not counted toward that requirement.

Tennessee, in 2023, was the first state to open a route to full licensure this way, and others followed. As of its June 2026 chart, the Federation of State Medical Boards counts 24 states, plus Guam and the Northern Mariana Islands, that have enacted laws allowing qualifying internationally trained physicians to reach full licensure without accredited North American postgraduate training2. Seventeen more states have considered similar bills, and several of those failed.

An enacted law is not the same thing as an open door. We checked each state's statute and its medical board's own pages as of October 1, 2026. Twelve states are taking applications or have a board rule in force. Four have a law in force but no application we could confirm. Nine more laws, in eight states (Louisiana has one in each of the last two groups), are not yet usable: they are waiting on funding, rules, an operative date, or approved employers. The tables below sort them that way.

Read this first

None of this makes the pathways worthless. For the right physician, in the right state, with an employer who understands the limits, they are a real route into practice. But the people who need to hear the limits most are the ones these laws were not written for, and that is most of this site's readers.

Who these laws are written for

Read the statutes side by side and a consistent profile appears. With few exceptions, the laws are built for an already trained, already practicing physician:

  • A medical license in another country, current or recently held, in good standing.
  • Years of recent practice abroad. Common requirements are three, four, or five years, often within a recent window (Florida asks for practice during the entire four years before you apply; Minnesota, 60 months within the last 12 years).
  • Completed postgraduate training abroad in most states, judged "substantially similar" to U.S. residency by the board. Several states, including Arkansas, Illinois, Minnesota, North Carolina, and Oklahoma, accept years of practice instead.
  • ECFMG certification and USMLE. Steps 1 and 2 are almost always required, and most states require Step 3 up front or before the license converts. A few, including Kentucky, North Carolina, Georgia, and Louisiana's 2024 law, accept other examinations or leave the exam to the board.
  • A job offer before you apply. These are employer-sponsored licenses. Many states limit which employers qualify: hospitals, health centers, academic health systems, or employers in shortage areas.
  • Lawful permission to work, which the license does not supply.

The advisory commission convened by FSMB, ACGME, and Intealth recommends the same shape: formal postgraduate training abroad, at least three years of practice, a limit on time out of practice, supervised assessment before full licensure, and board discretion over that final step. It describes its nine recommendations as guidance for states that choose to legislate, "not intended as an endorsement" of the pathways themselves4.

If you are a U.S. citizen IMG

If you are an American who went abroad for medical school, often to the Caribbean, and did not match, this is the honest answer: these pathways were not written for you, and most of them exclude you in practice. Nearly all of them require a license to practice in another country and years of practice under it. A graduate who left medical school and came home to apply for residency does not have either.

Idaho goes further and excludes you by definition. Its law covers only physicians who were not legal residents of the United States or Canada "when they attended and matriculated from an international medical program"6.

What remains for a recent graduate is the ordinary route: another application cycle, a preliminary year, or the strategies on Going Unmatched. Some states also offer an assistant- or graduate-physician license, described below. It permits supervised practice, but it is a different product and is not a reliable path to full licensure. Becoming eligible for these pathways would mean years of licensed practice abroad first, and the statutes' recency windows make that a long and uncertain bet.

How the pathways work

Most states follow one of three shapes:

  • Provisional, then full. You practice for two to six years on a provisional or limited license tied to a sponsoring employer, usually under supervision, then convert or apply for a full license. This is the common model (Iowa, Kentucky, Minnesota, Wisconsin, and others).
  • Limited, then restricted, then full. You start with supervised practice at a sponsoring facility, move to independent practice confined to a shortage area, and only then become eligible for an unrestricted license. Illinois, Massachusetts, Virginia, Nebraska, and Texas use versions of this.
  • A full license with conditions. Florida's route grants a regular license on condition that you stay employed in Florida for two years. West Virginia grants a full license directly, but only after two years of U.S. fellowship training.

One more structural point: Step 3 does not require a U.S. residency. An international graduate needs ECFMG certification to sit for it, and a year of U.S. training is recommended rather than required7. That is why these states can require it of physicians who never trained here, and why taking it early is good advice for anyone pursuing this route.

States taking applications

Each of these states shows a live application, a board rule in force, or an issued license on its own board's pages as of October 1, 2026. Terms are condensed; the statute and the board's current application control. "Steps" means USMLE Steps.

StateWhat you needWhere, and for how longTo a full license
Arkansas8
Act 971 (2025)
Active foreign license; practice throughout the 4 years before applying; ECFMG certificate and the ECFMG examination. No residency required.An employer serving a federally designated medically underserved population (an underserved area alone does not qualify). One-year provisional license, renewable; stay with the employer 3 years; appear before the board with your sponsor.Eligible after 2 years, subject to the board's review and approval.
Florida9
§458.311(8)(e) (2024)
Active foreign license; practice during the entire 4 years before applying; residency the board finds substantially similar to ACGME training; ECFMG certificate. The board lists Steps 1–3.A full-time offer from a Florida health care provider. You must stay employed in Florida for 2 consecutive years.No provisional stage: a regular license with a 2-year employment condition, granted at the board's discretion.
Illinois10
68 Ill. Adm. Code 1285.92–.93 (2025)
ECFMG certificate; Steps 1, 2 CK, and 3 up front; foreign license; 3 years of foreign postgraduate training, or practice in 2 of the last 5 years (older practice requires U.S. clinical experience).A sponsoring hospital, health center, or other approved entity. Two years on a limited license under a supervisor, then two years on a restricted license practicing independently in a shortage area.Full license after the restricted period, about 4 years in total. The first license was issued March 3, 2026.
Indiana11
HEA 1555 (2025; expires 2040)
ECFMG certificate; residency the board finds substantially similar; full-time practice 5 of the last 6 years; Steps 1–3 up front; immigration status.A facility in a state-designated underserved area, with a collaborative agreement. Limited license, renewable up to 6 years.The board may convert after 5 years and may require an independent evaluation.
Iowa12
Ch. 148J (2025)
Residency in your country of residence; 5 years of practice after it; good standing for 5 years; all Steps (by rule); ECFMG certificate or an approved English test.An Iowa health care facility. The provisional license is issued for up to a year at a time and tied to that facility.You may apply to convert after 3 consecutive years.
Kentucky13
SB 137 (2026)
Residency or similar training; at least 5 years of practice; good standing; ECFMG certificate or U.S. specialty board certification; an examination set by the board.A sponsor located in a federally designated medically underserved area. Open since July 15, 2026.Automatic after 3 years with the sponsor.
Minnesota14
§147.037 subd. 1b (2026)
60 months of practice abroad in the last 12 years; ECFMG certificate; Steps 1–2 (or COMLEX) within 3 attempts. No residency required.A collaborative agreement in a designated rural or underserved urban setting; pay at least equal to a resident's. A single 24-month license, not renewable.The board may grant one after 2 years with Step 3, a recommendation, and 20 hours of CME.
Nevada15
SB 124 (2025)
A foreign license (not Canadian); not open to graduates of U.S., Canadian, U.K., Australian, or New Zealand medical schools; residency, or practice within the last 5 years; all Steps up front. By rule, internal medicine, family medicine, or pediatrics only.A qualifying employer, such as a health center, public entity, or underserved group practice; supervised by a physician in the same specialty. Two-year license, renewable.The board may grant one after at least 2 years and 3,840 hours.
North Carolina16
G.S. 90-12.03 (rule eff. Aug. 2026)
Foreign license, current or within 5 years; 2 years of postgraduate training or 10 years of practice; at least 5 years of practice; competence shown by USMLE, a recognized foreign licensing exam, specialty certification, or a board-approved assessment.Full-time at a North Carolina hospital, or a rural practice with a physician on site. Practicing outside the qualifying site is a misdemeanor.The board shall grant one after 4 years with a clean record.
Tennessee17
Pub. Ch. 929 (2024; eff. 2025)
All Steps, in no more than two attempts each, and OET (by rule); 3 years of postgraduate training abroad and the last 3 years in practice abroad.An employer with an ACGME-accredited program. Three-year license, not renewable; it ends if the job ends.The board may grant one after 2 years. Changes January 31, 202718: a provisional training license with an on-site, board-certified supervisor, after which, barring board-determined disqualifications, the board shall grant a full license after 2 years and Step 3.
Texas19
HB 2038 (2025)
Foreign license; residency or similar training in that country; ECFMG certificate; Steps 1–2 within 3 attempts; the Texas jurisprudence exam; work authorization. Citizens of certain countries on federal national-security lists are excluded unless they are U.S. citizens or hold a U.S. work visa.First 2 years at a hospital or facility tied to an ACGME or AOA residency; a second 2-year license only in a rural, underserved, or shortage area.The board shall issue one once both provisional terms are done within 6 years and all Steps are passed. The board announced on February 25, 2026 that it was accepting applications.
Wisconsin20
2023 Act 214 (eff. Jan. 2025)
Residency or similar; 5 years of practice after it, including continuous practice in 1 of the last 5 years; ECFMG certificate; all Steps up front.A health center, hospital, surgery center, or approved facility; supervised by a physician in a similar specialty.Converts after 3 consecutive full-time years; by rule, you petition the board.

How many licenses have actually been issued? Almost no board publishes a count. Illinois announced its first license in March 202610. An advocacy organization that tracks these laws reported in June 2026 that licenses had been issued in six states (a count that includes Washington's clinical experience license, which is not a full-license pathway), including four in Illinois with 24 more applications under review21. Whatever the exact figures, these are pathways measured in dozens of physicians, not thousands.

In force, status unclear

The law is in effect, but we could not find a board application or other evidence that applications are being accepted. Ask the board directly before relying on any of these.

StateWhat the law saysWhy it is unclear
Idaho6Residency; 3 years of home-country practice after it and/or 500 hours of supervised U.S. clinical experience (the statute's wording is ambiguous); practice within 5 years; OET; Steps 1–2. A sponsor with a board-certified Idaho supervisor; 3-year provisional license, then eligible to apply for a full license with Step 3. Excludes anyone who was a U.S. or Canadian legal resident while in medical school.No board application page could be retrieved. In a May 2026 account, a physician who helped draft the law and mentors candidates said none of them were interested, "because they wouldn't be eligible to specialize and obtain board certification"22.
Louisiana (2024 law)23Foreign license; residency or at least 5 years of practice; U.S. or Canadian citizenship or the legal right to work in the U.S. The first 2 years must be at a hospital-owned facility; after that the limit lapses.The statute names no exam. A proposed board rule would add Steps 1–3, but we found no adoption, and the board's application page lists no such route. An advocacy group reports a first license21.
Oklahoma243 years of foreign postgraduate training, or practice abroad in 3 of the last 5 years. The employer must be within an academic health system or the OSU College of Osteopathic Medicine, with an ACGME program. Supervised by the department chair; the board may grant a full license after 3 years and all Steps.The board's FAQ said forms were "currently being developed," and we found no open application.
West Virginia25A completed foreign residency plus at least 2 years of non-accredited U.S. fellowship at an institution that sponsors an ACGME residency in a related field; all Steps within 10 years; ECFMG certificate; an employer's sponsorship letter. The board may grant a full license directly.No board application or guidance found. This route is for physicians already training in the U.S.; see Fellowship Without a U.S. Residency.

Enacted, not yet open

These laws are on the books but cannot be used yet. Do not move, resign a position, or sign a contract on the strength of one of these.

StateWhat is holding it upThe shape, once open
Georgia26Takes effect only if the legislature funds it by name. We found no such appropriation, and the board offers no application.A supervised provisional license at a rural practice, hospital, health center, or medical school; the board may grant a full license after 4 years, conditioned on 2 more years in an underserved area.
Louisiana (2026 rural license)27Effective August 1, 2026; no rules or application yet.Steps 1–3 and ECFMG; supervised practice of at least 2 years, limited to rural or underserved areas; eligible to apply for a full license after 5 years.
Massachusetts28Applications open only after a facility's assessment program is approved. We found no approved facility.A one-year limited license at the facility (renewable once), then, with Step 3, a restricted license for independent practice in a shortage area. You may apply for a full license after 2 restricted years. Board policy requires at least a year of practice in primary care or psychiatry.
Nebraska29Operative August 1, 2027.Three years provisional, then (with Step 3) three years transitional; eligible to apply for a full license after six years.
Oregon30Operative January 1, 2027; the board expects to take applications from January 4, 2027.A four-year supervised provisional license, then a clinical assessment. Unusually, provisional licensees are treated as fully licensed for credentialing and insurance billing.
Rhode Island31The board says regulations and an application are still being developed.Requires a foreign residency accredited by ACGME-International, a WFME-recognized body, or another board-approved accreditor; Steps 1–2 within 3 attempts; Step 3 and a facility assessment before full licensure. The resulting license authorizes independent practice in primary care, psychiatry, or another board-approved specialty.
Vermont32A report is due January 15, 2027; rulemaking begins July 2027; licenses no earlier than July 1, 2028.To be set by board rule.
Virginia33Proposed regulations are still in executive review and have not been published for comment.Two-year provisional license, then (with Step 3) a restricted license in an underserved area; eligible to apply for a full license after about 4 years.
Washington (2026 pilot)34Rulemaking expected to take 12 to 18 months.Only for physicians who held Washington's clinical experience license by July 1, 2026; leads to licensure to provide primary care.

Seventeen other states have seen bills recently, including Arizona, California, Maryland, Michigan, New Jersey, New York, Ohio, and Pennsylvania2. Many failed; some are still pending. A bill is not a license. Watch for enactment, then for the board's rules and application, which in several states above has taken more than a year.

Look-alikes that are not this

Several other licenses get described online as ways to "practice without residency." Each is a different product, and confusing them is costly.

  • Assistant, associate, and graduate physician licenses. Twelve states and Puerto Rico have one, under various names. They are designed largely for medical graduates who have not completed residency, require supervision or a collaborative agreement, and usually limit scope and setting. Whether any of them leads to full licensure depends on the state35. Treat it as supervised work, not as a back door to an unrestricted license.
  • Washington's clinical experience license. This is a supervised license that the medical commission describes as preparation "for residency or other advanced training"36. The 2026 pilot above is the only route from it to full licensure, and it is closed to newcomers.
  • Narrow limited licenses. California's Physicians from Mexico pilot is capped and time-limited, and New York issues limited permits for supervised hospital practice2. The Northern Mariana Islands' 2025 law authorizes a supervised, employer-tied limited license, and its proposed rule contains no path to full licensure37.
  • Faculty and "eminence" licenses. Nearly every jurisdiction has some route based on extraordinary ability or distinction, a faculty or research appointment, or board discretion2. The details vary by state; these licenses are typically tied to the appointing institution, and they depend on being recruited, not on applying. Check the specific state's terms.

What a license does not fix

Board certification

ABMS standards require ACGME-accredited training for initial certification, though member boards "may choose to recognize alternate pathways"3. For internal medicine, ABIM's special-consideration routes for internationally trained physicians require either at least three consecutive years on the full-time faculty of a U.S. or Canadian medical school or accredited training program (Pathway A), or an ACGME-accredited fellowship completed in the United States (Pilot Pathway E)38. A state pathway alone leads to neither. See Fellowship Without a U.S. Residency for how that route works and what it does not solve. Washington's 2026 law directs its medical commission to explore certification options with ABMS34. That is an acknowledgment of the gap, not a fix.

Hospital privileges, insurers, and payers

A statute can compel a board to license you. It cannot compel a hospital to grant you privileges, a malpractice carrier to insure you, or a commercial insurer to add you to its panel. Many of those decisions run through board certification4. Oregon is the rare law that addresses this directly, by treating its provisional licensees as fully licensed for credentialing and billing30. Before you accept a position, get written answers from the employer's credentials committee and its malpractice carrier.

Moving to another state

The Interstate Medical Licensure Compact requires accredited U.S. training and board certification, so it will not carry your license anywhere5. Any other state will apply its own rules, and outside a pathway those generally mean one to three years of accredited U.S. training1. A full license earned in one pathway state is a strong credential in that state and an uncertain one elsewhere.

Immigration

A state license does not authorize you to work. About half of these statutes, and some board rules, require work authorization before you start; where a law is silent, you still need it to work. For an H-1B, federal rules require a physician providing patient care to hold the license the state requires and to have passed the Federation Licensing Examination or an equivalent examination recognized by HHS39. The fee and policy picture for H-1B petitions has shifted repeatedly in 2025–2026; see the H-1B for physicians for the current state. ECFMG’s J-1 sponsorship covers clinical training and authorizes only that specific training activity, not practice under one of these licenses40, so the J-1 waiver programs described in the J-1 waiver guide generally do not apply. Have an immigration attorney map your status before you commit to a state.

If you fit: a sequence

If you are a physician with a foreign license, completed training, and years of recent practice, the pathways can work. The physicians who make them work tend to do things in this order:

  1. Settle your work authorization first, or at least know exactly how you will get it. A license you cannot use is not progress.
  2. Get ECFMG certification and Steps 1 and 2 done, then take Step 3 early. Most states require it at some point, several require it up front, and it widens your choice of states.
  3. Pick one or two states, not twenty. Match your record to the recency window, whether a foreign residency is required, which specialties are allowed (Nevada: internal medicine, family medicine, pediatrics), and which employers qualify.
  4. Find the employer before you apply. Most boards will not open a file without the offer and, often, a supervision or collaborative agreement. In Oklahoma, for example, only academic health systems qualify.
  5. Ask the hard questions in writing: whether the employer's credentials committee will grant privileges and its malpractice carrier will insure a provisional licensee without U.S. training. A yes from the board and a no from the hospital is a failed plan.
  6. Plan for the whole conversion period. Leaving the sponsor early can end the license in several states. Know whether your state's final step is "shall," "may," or "eligible to apply."
  7. Assume you will stay. Choose a state you would be content to practice in for the long term, because the license may not move with you.

References

  1. Federation of State Medical Boards. (2026, April). International medical graduates GME requirements: Board-by-board overview [Key issue chart]. https://www.fsmb.org/siteassets/advocacy/policies/img-gme-requirements-key-issue-chart.pdf “26 states + DC, GU, and MP may grant licenses to IMG applicants without completing accredited GME”; “14 states + PR, and VI do not accept credit towards accredited GME requirements for IMG applicants.” Most boards require one to three years of accredited GME of IMGs. ↩1 ↩2 ↩3
  2. Federation of State Medical Boards. (2026, June). States with enacted and proposed licensure pathways for internationally trained physicians: State-by-state overview [Key issue chart]. https://www.fsmb.org/siteassets/advocacy/policies/states-with-enacted-and-proposed-additional-img-licensure-pathways-key-issue-chart.pdf Counts 24 states plus Guam and the Northern Mariana Islands as having enacted pathways to full licensure without accredited North American postgraduate training; 17 more states with pending or recently proposed bills; California and New York with limited-licensure routes. FSMB describes the chart as informational and not authoritative. ↩1 ↩2 ↩3 ↩4
  3. American Board of Medical Specialties. (2016). Standards for initial certification (approved February 24, 2016; amended May 11, 2016). https://www.abms.org/board-certification/board-certification-standards/standards-for-initial-certification/ Training programs must be ACGME-accredited (standard ET-1); member boards “may choose to recognize alternate pathways” (ET-2). ↩1 ↩2
  4. Federation of State Medical Boards. (2025, February 4). Advisory Commission releases recommendations for states considering new licensing pathways for internationally trained physicians [News release]; Advisory Commission on Additional Licensing Models. (2025). Guidance document. https://www.fsmb.org/siteassets/communications/acalm-guidance.pdf Commission formed December 2023 by FSMB, ACGME and Intealth. Nine recommendations, which the release says “are not intended as an endorsement.” The guidance warns that “the ubiquity of specialty-board certification as a key factor in employment, hospital privileging, and insurance panel inclusion decisions is likely to impact the efficacy of non-traditional licensing pathways.” ↩1 ↩2 ↩3
  5. Interstate Medical Licensure Compact Commission. (n.d.). A faster pathway to physician licensure. Retrieved October 1, 2026. https://www.imlcc.com/a-faster-pathway-to-physician-licensure/ Eligibility includes having “successfully completed ACGME- or AOA-accredited graduate medical education” and holding “a current specialty certification or time-unlimited certification by an ABMS or AOABOS board.” ↩1 ↩2
  6. Idaho Code §§ 54-1803(12), 54-1812 (H.B. 542, 2024; effective January 1, 2025). https://legislature.idaho.gov/wp-content/uploads/sessioninfo/2024/legislation/H0542.pdf Defines an eligible “international physician” as one who “was not a legal resident of the United States or Canada when they attended and matriculated from an international medical program.” The definition lists both three years of home-country practice and 500 hours of supervised U.S. clinical experience; the operative section cross-references only the first, so how the board reads it should be confirmed directly. ↩1 ↩2
  7. United States Medical Licensing Examination. (n.d.). Eligibility [Bulletin of information]. Retrieved October 1, 2026. https://www.usmle.org/bulletin-information/eligibility Step 3 eligibility for international graduates requires ECFMG certification; a year of accredited U.S. graduate training is recommended, not required. ↩
  8. Arkansas Act 971 of 2025 (S.B. 601), amending Ark. Code Ann. § 17-95-403; Arkansas State Medical Board. (2026, April 15). Medical doctor licensure application packet. https://www.armedicalboard.org/Professionals/pdf/MD_AppPack.pdf The employer must serve a “medically underserved population” as defined in 42 U.S.C. § 254b; the board’s packet says practicing in a medically underserved area alone does not satisfy this. Full license after two years “after review and approval” of the board. ↩
  9. Fla. Stat. § 458.311(8)(e) (2025); Florida Board of Medicine. (2025). Pathways to licensure [Chart]. https://www.flsenate.gov/Laws/Statutes/2025/458.311 The board’s pathways chart (flboardofmedicine.gov/pdfs/MedPathways.pdf) lists USMLE Steps I, II and III and an active ECFMG certificate for this route. ↩
  10. Ill. Admin. Code tit. 68, §§ 1285.92–1285.93 (effective August 29, 2025), implementing 225 ILCS 60/15.5; Illinois Department of Financial and Professional Regulation. (2026, March 3). IDFPR issues first license under new pathway for internationally trained physicians [Press release]. https://ilga.gov/commission/jcar/admincode/068/068012850A00920R.html ↩1 ↩2
  11. Ind. Code § 25-22.5-5-7 (House Enrolled Act 1555, 2025; expires December 31, 2040); Indiana Professional Licensing Agency. (n.d.). Physician licensing information: International trained physician. https://www.in.gov/pla/professions/physicians-home/physicians-licensing-information/ ↩
  12. Iowa Code ch. 148J (effective January 1, 2025); Iowa Admin. Code r. 653-10.6 (effective May 21, 2025). https://www.legis.iowa.gov/docs/ico/chapter/148J.pdf The rule requires a passing score on all steps of the USMLE and issues the provisional license for up to one year at a time; after three consecutive years the licensee “may apply” to convert. ↩
  13. Ky. Rev. Stat. § 311.571(8)–(11) (S.B. 137, 2026); Kentucky Board of Medical Licensure. (2026). Provisional license. https://kbml.ky.gov/physician/Pages/Provisional-License.aspx Board page: “As of July 15, 2026, Kentucky now offers a Provisional License.” The license “shall automatically be converted into a regular license … after three (3) years with the employing sponsor.” ↩
  14. Minn. Stat. § 147.037, subd. 1b (2025 1st Spec. Sess. ch. 3, art. 3, § 5; effective January 1, 2026); Minnesota Board of Medical Practice. (2025, December). Internationally trained physician limited license: Instructions and requirements. https://www.revisor.mn.gov/statutes/cite/147.037 ↩
  15. Nev. Rev. Stat. § 630.2667 (S.B. 124, 2025; effective July 1, 2026); Nevada State Board of Medical Examiners, adopted regulation R112-25; Nevada State Board of Medical Examiners. (n.d.). Apply for licensure: Transitional limited physician. https://medboard.nv.gov/Licensees/Apply_for_Licensure/ Regulation R112-25 limits this license to internal medicine, family medicine and pediatrics and requires at least 3,840 hours before applying for an unrestricted license. ↩
  16. N.C. Gen. Stat. § 90-12.03 (S.L. 2025-37, pt. II); 21 N.C. Admin. Code 32B .1362 (effective August 1, 2026); North Carolina Medical Board. (2026). Internationally-trained physician employee (ITPE) license. https://www.ncmedboard.org/landing-page/Internationally-Trained-Physician-Employee-License ↩
  17. Tenn. Code Ann. § 63-6-207(g) (Pub. Ch. 929, 2024; effective January 1, 2025); Tenn. Comp. R. & Regs. 0880-02-.06 (rev. November 2025); Tennessee Board of Medical Examiners. (n.d.). Foreign training license (Public Chapter 929): Frequently asked questions. https://www.tn.gov/content/dam/tn/health/healthprofboards/medicalexaminers/FAQ_PC929.pdf The board rule requires all USMLE steps and the OET Medicine test; the license lasts three years, is not renewable, and expires if employment with the listed provider ends. ↩
  18. Tennessee Public Chapter 900 (S.B. 2366, 2026; signed May 5, 2026; effective January 31, 2027). https://publications.tnsosfiles.com/acts/114/pub/pc0900.pdf Replaces the foreign training license with a two-year provisional training license (extendable one year); the board “shall grant” a full license after two satisfactory years and passage of USMLE Steps 1, 2 and 3. ↩
  19. Tex. Occ. Code § 155.1015 (H.B. 2038, 2025); 22 Tex. Admin. Code § 161.53 (effective January 8, 2026); Texas Medical Board. (2026, February 25). Texas Medical Board DOCTOR Act update. https://www.tmb.texas.gov/about-us/newsroom/texas-medical-board-doctor-act-update For the full license, the rule requires passage of each part of the USMLE within three attempts and seven years, and completion of both provisional terms “within a period of six years, in total.” ↩
  20. Wis. Stat. §§ 448.04(1)(br), 448.05(2m) (2023 Wis. Act 214; effective January 1, 2025); Wis. Admin. Code ch. Med 27 (effective October 1, 2025); Wisconsin Department of Safety and Professional Services. (n.d.). Physician – provisional licensure. Retrieved October 2, 2026. https://dsps.wi.gov/a-z-professions-list/physician-mddo/provisional-licensure/ DSPS lists “Provisional Physician Licensure” as an application type on its LicensE portal and says that after three years the credential holder “can apply to convert the provisional license into a full license.” Rule text: docs.legis.wisconsin.gov/code/admin_code/med/27. ↩
  21. World Education Services. (2026, June 2). 27 states expand pathways for internationally trained physicians in 2026 [Blog post]. https://www.wes.org/resource-library/blog/welcoming-communities-in-action/27-states-expand-pathways-for-internationally-trained-physicians-in-2026/ Advocacy organization. WES counts 27 states and two territories (as of May 2026) against FSMB’s 24 plus two; the organizations use different criteria (WES’s list includes Colorado; FSMB’s does not). Reports licenses issued in Arkansas, Illinois, Louisiana, Tennessee, Washington and Wisconsin, including four provisional licenses in Illinois with 24 applicants under review. These are not board-published figures. ↩1 ↩2
  22. World Education Services. (2026, May 13). From legislation to practice: Lessons from Idaho’s internationally trained physician pathway [Blog post]. https://www.wes.org/resource-library/blog/welcoming-communities-in-action/from-legislation-to-practice-lessons-from-idahos-internationally-trained-physician-pathway/ ↩
  23. La. Rev. Stat. § 37:1275.2 (Act 646 of 2024, H.B. 972); Louisiana State Board of Medical Examiners. (2025, July 20). Notice of intent: Fully trained foreign physicians. Louisiana Register, 51(7). https://www.legis.la.gov/legis/Law.aspx?d=1391414 The statute names no examination. The board’s 2025 proposed rule would require USMLE Steps 1–3 and an employer-tied first two years; no notice of adoption had been posted as of October 1, 2026. ↩
  24. 59 Okla. Stat. § 493.2 (H.B. 2050, 2025; effective November 1, 2025); Oklahoma State Board of Medical Licensure and Supervision. (2025, September 16). Frequently asked questions: HB 2050. https://www.okmedicalboard.org/download/2449/FAQ-OK_HB_2050.pdf The statute limits qualifying employers to a facility “within an academic health system or the Oklahoma State University College of Osteopathic Medicine.” The FAQ said application forms were “currently being developed.” ↩
  25. W. Va. Code § 30-3-10(c) (H.B. 5458, 2026; effective June 7, 2026). https://code.wvlegislature.gov/30-3-10/ ↩
  26. Georgia Act 509 (S.B. 427, 2026; signed May 11, 2026), enacting O.C.G.A. § 43-34-34.1. https://www.legis.ga.gov/legislation/72469 The Act “shall become effective only if the Code section provided for in this Act is funded in an appropriations Act making specific reference to such Code section.” No such appropriation was found as of October 1, 2026. ↩
  27. La. Rev. Stat. § 37:1275.3 (Act 879 of 2026, H.B. 1160; effective August 1, 2026). https://legis.la.gov/Legis/ViewDocument.aspx?d=1481510 ↩
  28. Mass. Gen. Laws ch. 112, § 9 (as amended by St. 2024, c. 238); Massachusetts Board of Registration in Medicine. (2025). Board statement on recent law regarding new licensing pathway (updated October 22, 2025); Policy 25-03 (rev. February 26, 2026). https://www.mass.gov/info-details/board-statement-on-recent-law-regarding-new-licensing-pathway Board: limited license applications “will be available when participating healthcare facilities have established such programs.” Policy 25-03 requires at least one year of practice in primary care (including internal medicine) or psychiatry. ↩
  29. Nebraska L.B. 1212 (2026; approved April 14, 2026; operative August 1, 2027). https://nebraskalegislature.gov/FloorDocs/109/PDF/Slip/LB1212.pdf ↩
  30. Oregon S.B. 476 (2025), sections 4–9 operative January 1, 2027; Oregon Medical Board. (2026). Internationally trained physicians. https://www.oregon.gov/omb/topics-of-interest/pages/internationally-trained-physicians.aspx Board timeline: rulemaking initiated July 2026; applications expected from January 4, 2027, subject to change. Provisional licensees are “considered a fully licensed physician … for all purposes, including … credentialing and insurance billing.” ↩1 ↩2
  31. R.I. Gen. Laws § 5-37-16 (P.L. 2025, chs. 95–96; effective June 23, 2025); Rhode Island Department of Health, Board of Medical Licensure and Discipline. (2026, March). 2025 annual report. https://webserver.rilegislature.gov/Statutes/TITLE5/5-37/5-37-16.htm Annual report: the board “is developing regulations and an application process for these Limited International Physician registrations, which are anticipated to be considered in 2026.” ↩
  32. Vermont Act 172 (S.142, 2026; signed June 18, 2026). https://legislature.vermont.gov/Documents/2026/Docs/ACTS/ACT172/ACT172%20As%20Enacted.pdf ↩
  33. Va. Code Ann. § 54.1-2933.1 (2024 Va. Acts ch. 464; effective July 1, 2024); Virginia Regulatory Town Hall. (2026). Action 6636: Licensure of foreign physicians through provisional and restricted licenses. https://www.townhall.virginia.gov/L/viewaction.cfm?actionid=6636 As of October 1, 2026, the proposed regulations were in Governor’s-office review and had not yet been published for public comment. ↩
  34. Washington Laws of 2026, ch. 154 (S.S.B. 5185; effective June 11, 2026); Washington Medical Commission. (2026). Clinical experience graduate program. https://wmc.wa.gov/licensing/clinical-experience-graduate-program Open only to holders of a clinical experience license issued on or before July 1, 2026; leads to licensure “to provide primary care.” Commission estimate for rulemaking: 12 to 18 months. ↩1 ↩2
  35. Federation of State Medical Boards. (2026, June). States with enacted and proposed assistant physician legislation [Key issue chart]. https://www.fsmb.org/siteassets/advocacy/policies/associate-physician-legislation-by-state-key-issue-chart.pdf Twelve states and Puerto Rico have created an assistant-physician or similar license category: AL, AZ, AR, FL, ID, KS, LA, MD, MO, TN, TX, UT. Whether any of them leads to full licensure varies by state. ↩
  36. Washington Medical Commission. (n.d.). International medical graduates clinical experience license. Retrieved October 1, 2026. https://wmc.wa.gov/licensing/applications-and-forms/international-medical-graduates-clinical-experience-license ↩
  37. Commonwealth of the Northern Mariana Islands Public Law 23-33 (2025); Health Care Professions Licensing Board. (2025, April 15). Notice of proposed amendments to the limited licensure for foreign medical graduates. Commonwealth Register, 47(4). https://cnmilaw.gov/docs/public_laws/23/pl23-33.pdf ↩
  38. American Board of Internal Medicine. (n.d.). Candidates for special consideration. Retrieved October 1, 2026. https://www.abim.org/certification/policies/candidates-for-special-consideration/ ↩
  39. 8 C.F.R. § 214.2(h)(4)(viii). Petition for alien physician. https://www.ecfr.gov/current/title-8/chapter-I/subchapter-B/part-214/section-214.2 A physician coming to provide direct patient care must hold the license the state requires and must have “passed the Federation Licensing Examination (or an equivalent examination as determined by the Secretary of Health and Human Services)” unless a U.S. graduate or exempt. ↩
  40. Educational Commission for Foreign Medical Graduates (Intealth). (2025). Exchange Visitor Sponsorship Program: General information for applicants. https://www.ecfmg.org/evsp/applying-general.html “Intealth J-1 visa sponsorship authorizes a specific training activity, location, and associated financial compensation. Federal regulations do not permit any additional activity or compensation outside of the defined parameters of the approved program.” ↩

Statutes, rules, and board practice in this area change frequently; status is as of October 1, 2026. This page is educational and program-neutral. It is not legal, immigration, or licensure advice.