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California Raising GME Requirements for Physician Licensure

By Debra Wood, RN, contributor

Obtaining a medical or osteopathic license in California could take a little longer, starting in 2020, when the state will require three years of graduate medical education from an approved program for full licensure. 

“These changes are intended to further support the Board’s mission of consumer protection,” said April Alameda, chief of licensing for the Medical Board of California, in a letter to GME program directors.

The Federation of State Medical Boards recommends that applicants for medical licensure should satisfactorily complete at least 36 months of progressive postgraduate medical training, or graduate medical education, according to Joe Knickrehm, director of communications and public affairs at the Federation of State Medical Boards.

However, California is the first state to enact the successful completion of 36 months GME requirement for medical doctors and osteopaths trained in the United States. Maine requires three years for medical doctors, and Nevada has a 36-month requirement for both MDs and DOs, but offers exceptions. For instance, MDs can be granted an unlimited license after finishing 24 months if they agree to complete the residency program and DOs can be granted a full license after two years of GME if they agree to practice in Nevada.

“Many states have the 12-month requirement,” Knickrehm said. He explained that the 12-months is the minimum requirement to obtain a license, but the medical school graduate would need to complete a residency in order to be specialty certified.

Residents must complete 24 consecutive months at the same residency program.

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GME requirement for licensure for current residents

If a second-year resident in California applies for full licensure before December 31, 2019, he or she will be able to obtain it and will not be subject to the new law. But if he or she waits until January 1, 2020, he or she will be required to apply for a training license and complete three years of residency.

Different rules for IMGs

Many states have different requirements for the initial licensure of international medical graduates (IMG). For instance, California formerly required two years for IMG. Now, both U.S. and foreign-trained graduates will have to complete the three years of GME.

Starting on January 1, 2020, the Medical Board of California will recognize “international medical schools as meeting the educational requirements” for a training license and full license, if the school is listed with the World Federation for Medical Education, the Foundation for Advancement of International Medical Education and Research World Directory of Medical Schools joint directory of the World Directory of Medical Schools.

Postgraduate training license

Before completing California’s 36-month GME requirement for licensure, medical doctors and osteopaths will need to apply for and receive a postgraduate training license. Applicants are eligible after graduating from medical school, completing the COMLEX levels one and two, and after receiving a confirmation of acceptance letter from an American Osteopathic Association- or an Accreditation Council for Graduate Medical Education-accredited California program. 

The graduate must apply for the training license within 180 days of enrolling in a residency program. Otherwise, the resident will have to stop practicing. It could take 60 days to process the training license application, so residents should not delay applying.

The training license is good for 39 months and cannot be renewed. Residents can be disciplined while holding a training license.

First year residents will be required to apply for the postgraduate training license after January 1, 2020, and before June 30, 2020. They will receive a training license pocket card.

After completing the GME, residents can obtain a full license within 90 days. The state will develop a special, streamlined application for people holding a postgraduate training license to apply for full licensure. Residents will need to provide an updated transcript for the COMPLEX level three score, a certificate of completion of the residency program, and pay fees.


California will now allow residents completing the 36-month requirement to moonlight, provided they obtain written permission from the director of the residency program. 

Read also: A Guide to Moonlighting for Physicians and Residents

GME Requirements by State

(as of 1-1-20)

US trained 
MD Months

US trained 
DO Months

Alabama 12 12
Alaska 24 24
Arizona 12 12
Arkansas 12 12
California 36 36
Colorado 12 12
Connecticut 24 24
Delaware 12 12
District of Columbia 12 12
Florida 12 12
Georgia 12 12
Hawaii 12 12
Idaho 12 12
Illinois 24 24
Indiana 12 12
Iowa 12 12
Kansas 12 12
Kentucky 24 24
Louisiana 12 12
Maine 36 12
Maryland 12 12
Massachusetts 24 24
Michigan 24 12
Minnesota 12 12
Mississippi 12 12
Missouri 12 12
Montana 24 24
Nebraska 12 12
Nevada 36* 36*
New Hampshire 24 24
New Jersey 24 24
New Mexico 24 12
New York 12 12
North Carolina 12 12
North Dakota 12 12
Ohio 12 12
Oklahoma 12 12
Oregon 12 12
Pennsylvania 24 12
Rhode Island 24 24
South Carolina 12 12
South Dakota ** **
Tennessee 12 12
Texas 12 12
Utah 24 24
Vermont 12 12 ***
Virginia 12 12
Washington 24 12
West Virginia 12 12
Wisconsin 24 24
Wyoming 24 24

Information courtesy of FSMB

* With exceptions at 24 months
** Successful completion of residency program
*** One year rotating internship or 3-year residency

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