Section 1285.92  International Medical Graduate Physician Limited License

a)         "International medical graduate" is defined under Section 2 of the Act as a medical graduate:

1)         who has been trained in a country other than the United States;

2)         whose education has been certified by the Educational Commission for Foreign Medical Graduates;

3)         who has passed Step 1, Step 2 Clinical Knowledge, and Step 3 of the United States Medical Licensing Examination;

4)         who maintains an unencumbered license from another country; and

5)         who is not licensed to practice medicine in any state or territory of the United States.  [225 ILCS 60/2]

b)         An international medical graduate shall be eligible to apply for a limited license to practice medicine in the State of Illinois.  Upon determination of fitness, the Division will issue a two-year limited license to an international medical graduate in accordance with Section 15.5 of the Act to an applicant who satisfies all of the following criteria:

1)         Submits a fully completed application on forms provided by the Division which includes the payment of a $100 fee;

2)         Provides an official transcript and diploma or official transcript and certification of graduation from the medical education program granting the degree and proof of Educational Commission for Foreign Medical Graduates (ECFMG) certification; provided, however, that the Division will waive the official transcript and diploma/certification of graduation requirement if the applicant demonstrates, to the Division's satisfaction, that the applicant is unable to obtain the required documentation from a non-cooperating country or educational institution;

3)         Provides proof of successful completion of the United States Medical Licensing Examination (USMLE) Steps 1, 2, and 3.  Examination scores shall be submitted directly to the Division from the testing entity;

4)         Provides proof of current, unencumbered physician licensure in another country as verified by ECFMG's international credential verification services, currently named EPIC;

5)         Submits evidence the applicant has at least three years of post-graduate training in another country verified by ECFMG or submits evidence that the applicant has been engaged in the active practice of medicine in the country where the applicant is licensed for at least two of the last five years. If the active practice of medicine predates the two years immediately preceding the date of application, the applicant must show evidence of a United States clinical experience, including one of the following:

A)        A Clinical Rotation. A structured rotation in a specific medical department, often within a hospital or university setting to gain practical experience in patient care.

B)        An Observership. An opportunity to shadow a United States licensed physician without a prior disciplinary history and observe the physician's daily routines and patient care, providing valuable insights into US medical practice.

C)        An Externship. A hands-on experience where the individual is actively involved in patient care under the guidance of a physician preceptor.

D)        Electives. An opportunity to complete clinical rotations in specific areas of medicine, often chosen by the individual to align with their career interests.

E)        Holds an active Illinois physician assistant or advanced practice registered nurse license without prior disciplinary action.

6)         Has entered into an agreement with a sponsoring entity which must be one of the following:  a hospital, a Federally Qualified Health Center, a State-operated mental health facility or developmental center or a correctional center operated by the Department of Corrections, a community health center as defined in 77 Ill. Adm. Code 591.20, a multispecialty medical practice or clinic with two or more active physicians who hold unrestricted licenses to practice in the State of Illinois and which participates in graduate medical education, or another facility approved by the Division that provides an annual supervisor assessment and summative evaluation designed to develop, assess, and evaluate the individual's nonclinical and clinical skills and familiarity with standards appropriate for medical practice in the State of Illinois; and

7)         Submits to and passes the background check required of physician license applicants under Sections 1285.70 and 1285.80.

c)         Upon the issuance of the limited license, an individual may only practice:

1)         Within the sponsoring entity; and

2)         Under the supervision and control of the sponsoring entity who designates a supervisor who possesses a full and unrestricted Illinois license to practice medicine in all of its branches that has never been disciplined in the State of Illinois. The supervisor must be either board certified or actively participating in their maintenance of certification in the specialty or completed a residency or fellowship in a similar specialty to the one the applicant is pursuing.

d)         An applicant for limited license must maintain a practice agreement, made available to the Department upon Department request, between the applicant and the sponsoring entity that provides an annual supervisor assessment and summative evaluation.

e)         The sponsoring entity must ensure that the supervisor has sufficient support and dedicated time to effectively carry out educational, administrative, and professional responsibilities. The supervising physician shall maintain the final responsibility for the care of the patient and the performance of the limited license holder. All procedures and tasks performed by the limited license holder shall be within the current scope of practice of the supervising physician. It is the responsibility of the supervising physician to direct and review the practice of the limited license holder to ensure that appropriate directions are given and understood and that appropriate treatment is being rendered. Failure of the supervising physician to properly supervise a limited license holder may result in discipline under Section 1285.240.

f)         Should either party terminate the practice agreement, it shall be the responsibility of both the limited license holder and the sponsoring entity to notify the Division immediately and submit a written explanation to the Division indicating why the practice agreement was terminated.  A limited license holder may only practice within the sponsoring entity and under the supervision of a licensed physician in accordance with Section 1285.92(c).

g)         A limited license issued under this Section is valid for two years and may be renewed every two years if the applicant meets the requirements of Section 1285.120, with the exception of the continuing medical education requirement for the first renewal.

h)         A limited license holder shall be entitled to perform only those actions that are within the scope of practice of the supervising physician, as may be prescribed by and incidental to the limited license holder's practice agreement with the sponsoring entity while under supervision.  A limited license holder shall not be entitled to otherwise engage in the practice of medicine in this State unless fully licensed in this State.

i)          All persons licensed under this Section are subject to the jurisdiction of the Division to the same extent as all other licensees under the Medical Practice Act of 1987.

(Source:  Added at 49 Ill. Reg. 11270, effective August 29, 2025)