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Foreign Physicians in Tennessee: Understanding Restricted Licenses

Practicing medicine and surgery is an essential and highly skilled profession, with competent physicians in high demand. If you are an international medical school graduate looking to practice medicine or surgery in Tennessee, there are specific requirements you must meet to obtain your license. Below is a detailed overview of the process.

The Base Requirements

          An application must be submitted to the Board of Medical Examiners (board). The application, for international medical school graduates, must include:

  1. Certificate from Medical School: the school’s curriculum must be approved as acceptable by the board.
  2. ECFMG Certification: a copy of a permanent Educational Commission for Foreign Medical Graduates is required.
  3. Proof of Good Moral Character: applicants must demonstrate sufficient evidence of good moral character.
  4. S. Citizenship or Legal Residency: the applicant must be a citizen of the United States or Canada or be legally authorized to live or work in the United States.

Additionally, the applicant must prove satisfactory completion a three-year post-graduate training program approved by the American Medical Association. Alongside these requirements, the applicant must successfully complete and pass the board examination.

Foreign Training Licenses

          Once all preliminary requirements are met, an international medical school graduate is eligible to receive a Foreign Training License. This restricted license allows the physician to practice medicine in Tennessee under specific conditions. The Board may issue this license if the applicant:

  1. Successfully completed the board exam;
  2. Demonstrates competency, as determined by the board;
  3. Completed a three-year post-graduate training program in the applicant’s licensing country; and
  4. Has otherwise practiced medicine for at least three years as a physician outside the United States.

The Foreign Training License is considered a restricted license and is valid only for a limited duration. Further, a physician practicing under this license must only provide medical services at a healthcare provider that has an accredited post-graduate training program in place. Therefore, the applicant must submit proof of an employment offer at a healthcare provider in Tennessee with a post-graduate training program approved by the Accreditation Council for Graduate Medical Education (ACGME).

Temporary Licenses

     Alternatively, an international medical school graduate can apply for a Temporary License of limited duration. The board may issue this license if the applicant:

  1. Successfully completed the board exam;
  2. Demonstrates competency, as determined by the board; and
  3. Completed a one-year post-graduate training program in the United States.

Unlike the Foreign Training License, the Temporary License is not restricted to working at a healthcare provider with an approved post-graduate training program. This offers more flexibility for the applicant in terms of employment.

Full and Unrestricted Licenses

After two years of active practice in Tennessee, a physician holding either a Foreign Training License or a Temporary License may be eligible for a Full and Unrestricted License. The board may grant this license if the physician has maintained good standing during their practice in the state.

Summary of Licensing Options for International Medical School Graduates

An international medical school graduate can pursue one of two paths to obtain a license to practice medicine or surgery in Tennessee:

  1. Foreign Training License: Available to applicants who have completed three years of post-graduate training in their licensing country and have practiced medicine for at least the last three years.
  2. Temporary License: Available to applicants who have completed one-year of post-graduate training in the United States.

Recent Changes to Licensing Requirements

As of January 1, 2025, the requirements for obtaining a Foreign Training License have been slightly modified. Previously, international medical school graduates could qualify for a Foreign Training License by either completing three years of post-graduate training or by practicing medicine for at least three of the last five years. However, under the updated regulations, both criteria must now be met: the applicant must have completed a three-year post-graduate training program and have practiced as a medical professional for at least the last three years.

Additionally, while the previous rules guaranteed that licensees with Foreign Training Licenses would receive a full and unrestricted license after two years of good standing, the new regulations give the board discretionary authority in granting the full license.

Conclusion

          Navigating the process of obtaining a medical license as an international medical school graduate in Tennessee requires careful attention to the specific requirements set forth by the board. Whether through a Foreign Training License or a Temporary License, these pathways offer flexibility with the possibility of obtaining a full, unrestricted license after two years of practice.

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It should be noted that I am not your lawyer (unless you have presently retained my services through a retainer agreement). This post is not intended as legal advice, it is purely educational and informational, and no attorney-client relationship shall result after reading it. Please consult your own attorney for legal advice. If you do not have one and would like to retain my legal services, please contact me using the contact information listed above.

All information and references made to laws, rules, regulations, and advisory opinions were accurate based on the law as it existed at this time, but laws are constantly evolving. Please contact me to be sure that the law which will govern your business is current. Thank you.

FAQs on Florida’s Amendment to Senate Bill 7016; Creating A New Path to Licensure by Endorsement for Foreign Trained Physicians

Licensure by Endorsement for Foreign Trained Physicians

FAQs SHEET

At Jones Health Law we strive to be at the forefront of the latest information on healthcare laws that affect our clients, healthcare practitioners. We’ve received many calls and inquiries from physicians and attorneys worldwide regarding the amendment to Senate Bill 7016 which provides a new avenue of licensure for foreign physicians. We’ve decided to create this fact sheet to provide information on this trending topic based on questions we’ve received. We will update this sheet as we receive new information.

Last updated: 05/20/2025

Question: How does the new amendment to Senate Bill 7016 affect the path to licensure for foreign physicians?

Answer: The amendment to Senate Bill 7016 provides opportunities for foreign physicians to apply for licensure if they meet all of previously established requirements but have not completed a residency program in the United States.

 

Question: Is the USMLE still a requirement? Do physicians need to have a ECFMG certificate to be eligible?

Answer: Yes, the USMLE and ECFMG are still requirements under the amendment. The amendment only waives the requirement of having completed a residency but will require “substantially similar” post-graduate training. The Board of Medicine may approve a restricted license if an application is submitted without having completed one of these steps but it is up to the discretion of the Board. An incomplete application is subject to rejection.

 

Question: Is there a list of countries for eligible applicants?

Answer: No, there are no limits to where applicants may apply from.

 

Question: Is this license limited or restricted in any way? And is there is a cap to the amount that a physician can earn as compensation?

Answer: No, there is no limit or restriction to the license. There is also no cap to the amount that a physician can earn if becoming licensed under this pathway.

 

Question: Is there a specific application for foreign physicians interested in this pathway?

Answer: Yes. The Board of Medicine has updated the application as of 12/2024.

 

Question: Do sponsors have to pay for the visa and the medical license application for the applicants?

Answer: No, there are no rules on who must pay for the visa and application.

 

Question: If an applicant only passed the USMLE Step 1 and 2, is their certificate still valid?

Answer: The USMLE is valid indefinitely. However, the Board of Medicine has not considered whether an applicant that hasn’t completed Step 3 is in compliance with this requirement under the law. The Board would need to confirm validity based on the individual application and other eligibility requirements.

 

Question: Can applicants complete the required electronic fingerprinting in a foreign county?

Answer:  Yes, there are accepted ways to have fingerprints completed in a foreign county. We can provide our clients with approved fingerprinting sources and have a process for individuals with no social security number and who don’t reside in the U.S.

 

Question: What if I don’t meet all of the other requirements?

Answer: Once an application is submitted a regulatory specialist will review for completion. If the application fails to meet all eligibility requirements, the applicant (and attorney) will go before the Board of Medicine to plead their case. 

As previously stated, while the residency requirement is now waived, applicants must prove that their post-graduate training is “substantially similar” to that of a U.S. residency program. Currently, the Board of Medicine is discussing what an appropriate “substantially similar” post-graduate training would consist of. Foreign programs that are accredited by the Accreditation Council for Graduate Medical Education International (ACGME-I) will likely be accepted. All other applications who have not completed programs accredited by ACGME-I will be determined on a case-by-case basis. If you have any other questions, please read our other blog post, Florida’s “Live Healthy” Initiative Provides Foreign Trained Physicians a Path to Licensure for more information.

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It should be noted that I am not your lawyer (unless you have presently retained my services through a retainer agreement). This post is not intended as legal advice, it is purely educational and informational, and no attorney-client relationship shall result after reading it. Please consult your own attorney for legal advice. If you do not have one and would like to retain my legal services, please contact me using the contact information listed above.

All information and references made to laws, rules, regulations, and advisory opinions were accurate based on the law as it existed at this time, but laws are constantly evolving. Please contact me to be sure that the law which will govern your business is current. Thank you.