By Yoselyn Santos Gomez, MBA
PPS Consulting Group
Over the past two years, 24 states have enacted laws that allow internationally trained physicians to obtain a medical license without repeating residency in the United States, and 17 more have pending legislation. Social media is full of posts celebrating this as an open door for any foreign physician. It is not. I have spent 22 years in physician recruitment and licensing, and I want to explain what is behind these laws before a physician makes a decision based on a post.
How these laws work
Nearly all of them require two things: a current, unrestricted license in the country where the physician trained, and years of active practice under that license. Florida requires four full years immediately preceding the application. Indiana requires five of the last six. Virginia, North Carolina, Kentucky, Iowa and Wisconsin require five. Add to that ECFMG certification, USMLE (all three Steps in Florida), postgraduate training the Board accepts as equivalent and, in almost every state, a full-time job offer before applying.
In other words, these laws are designed for the physician who is still practicing in their home country and applies from there with a job offer in hand. They were not written for the physician who is already in the United States.
The Florida case
One important clarification, because there is confusion. Florida’s pathway is the licensure by examination route for internationally trained physicians, created in 2024. It is not the MOBILE license and it is not licensure by endorsement; those are for physicians who already hold a full, active license in another U.S. state.
And here is the problem for many physicians already living in Florida. The ACN license (Area of Critical Need) is a limited, temporary license. Years worked under an ACN do not satisfy the requirement of active practice under an unrestricted license that these laws demand. The physician who left their practice back home to come here, study for the Steps or work under an ACN has already broken the continuous practice period the law requires.
Texas is different
Texas did the opposite. Its law is designed for the internationally trained physician who already lives in the United States with legal immigration status and work authorization. It does not require active practice before applying, but it does require a current license in the home country, completed residency there, USMLE Steps 1 and 2, ECFMG certification and a job offer from a Texas hospital or health system. The Texas Medical Board has been accepting applications since January 2026.
For a physician already in the United States who meets those requirements, Texas is today the pathway that most clearly applies. Two warnings: a physician without USMLE does not qualify, and Texas will not issue this license to applicants without a visa from countries the federal government considers a national security risk, a list that includes Cuba.
What state laws do not solve
While the states pass these laws, the federal government is closing the other door. A state license does not resolve immigration status; that has to be sponsored by the employer. And today, bringing a physician from their home country on an H-1B visa costs the employer $100,000 under the new federal fee. As things stand, which employer is going to pay that?
The numbers confirm it. Of the 24 states with enacted laws, only six have issued licenses. The only one truly working is Washington, with about 50 licensed physicians, most of them in rural or underserved areas. Florida is not among the states that have issued licenses.
A pathway is not a job
The existence of a licensing pathway does not mean there are jobs for that type of license. As of today, based on our research, the only state we have been able to confirm is Washington. Not even in Texas have we found employers hiring or issuing letters of intent under this license. That does not mean they do not exist; it means that, so far, we have not found them.
We have seen this before with Florida’s ACN license. It was created in 1979, and years passed before it became known, before health plans built their credentialing process for it and before employers began hiring physicians under it. We do not know how fast or how slowly these new markets will develop, or how the political climate and upcoming elections may affect them. It is something to evaluate as time goes on.
Before making a decision
If you are an internationally trained physician evaluating any of these pathways, verify your eligibility against the actual requirements of each state before resigning from a job, relocating or leaving your practice back home. Every case is different, and the detail that seems minor is the one that decides whether you qualify.
PPS Consulting Group provides eligibility and multistate licensing consultations for internationally trained physicians and for the healthcare organizations evaluating whether to hire them.
