COMLEX-USA Level 3 Eligibility Pathways

Enhanced attestation for classes of 2020-2025

The first goal for the Special Commission on Osteopathic Medical Licensure Assessment was the review and endorsement of temporary pathways for the classes of 2020-2025 to take COMLEX-USA Level 3. For these graduates, eligibility will be based on an attestation of their fundamental clinical skills from Deans and Residency Program Directors as outlined below.

These temporary pathways have been endorsed by the Special Commission on Osteopathic Medical Licensure Assessment and approved by the NBOME Board of Directors.

Eligibility for the COMLEX-USA Level 3 can be earned by the following pathways:

Pathway 1: candidates who have taken and passed COMLEX-USA Level 2-PE (as for prior DO graduates) must do all of the following:

• Passing both COMLEX-USA Level 2-CE and Level 2-PE
• Graduation from an accredited college of osteopathic medicine (COM) with a DO degree as attested by the COM Dean
• Attestation by the Residency Program Director of an ACGME accredited program that you are in good academic and professional standing and meets the requirements to graduate from their COM
• Six months of GME completion prior to taking COMLEX-USA Level 3 (Recommendation ONLY)

Pathway 2: candidates who have never taken COMLEX-USA Level 2-PE must do all of the following:

• Passing COMLEX-USA Level 2-CE
• Attestation by COM Dean that you have graduated and have demonstrated the fundamental osteopathic clinical skills necessary for graduation
• Attestation by the Residency Program Director of an ACGME-accredited program that you are in good academic and professional standing
• Six months of GME completion prior to taking COMLEX-USA Level 3 (Recommendation ONLY)

Pathway 3: candidates who have unsuccessfully attempted (failed) COMLEX-USA Level 2-PE must do all of the following:

• Passing COMLEX-USA Level 2-CE
• Attestation by COM Dean that you have graduated and have demonstrated the fundamental osteopathic clinical skills necessary for graduation
• Attestation by the Program Director of an ACGME-accredited program that you are in good academic and professional standing
• Six months of GME completion prior to taking COMLEX-USA Level 3 (Required)

Frequently Asked Questions

1. Is there a change to the Program Director attestation?

No, the attestation from the Program Director of an ACGME accredited program is the same in all three pathways, namely, that the resident is in good professional and academic standing. The difference at the graduate level is the requirement of 6 months of GME for Pathway 3.

2. What about someone in the Classes of 2020 and 2021 who has failed the PE multiple times?

They would follow Pathway 3 above, provided they have not exceeded the maximum attempt limits for the examination.

3. I am a member of the Class of 2021 who never took the COMLEX-USA Level 2-PE. What do I need to do?

You will not need to do anything just now. Your Dean will complete the attestation for you at graduation provided you qualify. When you begin your residency, you will need to enter your Program Director information into the NBOME Portal. Your Program Director will then be able complete the required Program Director attestation for your eligibility to take COMLEX-USA Level 3. This has been required in the COMLEX-USA program since 2018, so Program Directors are quite accustomed to this straightforward and user-friendly process.

4. What about the Class of 2019 and previous classes?

These pathways are temporary and for the Classes of 2020 and 2021 only. As passing COMLEX-USA Level 2-PE was a graduation requirement per accreditation standards for the Class of 2019 and earlier, these pathways do not apply (as graduation is part of these pathways). Further review of special circumstances for candidates who were formerly in the Classes of 2019 and earlier, had failed COMLEX-USA Level 2-PE, and did not graduate is underway.

5. I have a previous failure on the COMLEX-USA Level 2-PE. Will this be erased from my transcript?

As COMLEX-USA is recognized by all U.S. state licensing boards for granting licenses, it is NBOME’s responsibility to provide comprehensive transcripts that include all exam history and results of COMLEX-USA examinations for state medical and osteopathic medical licensing boards. Therefore, we cannot remove examination results from official COMLEX-USA transcripts. We will annotate COMLEX-USA transcripts to note that the COMLEX-USA Level 2-PE was suspended on March 7, 2020 due to the pandemic, that temporary alternate pathways were provided, and that eligible candidates who complete the COMLEX-USA series of examinations via any of these pathways will be considered to have successfully completed the NBOME COMLEX-USA licensing examination program.

6. I graduated in the Class of 2020 but am not in a residency program. How can I complete the pathway?

First, you would be classified into either Pathway 2 or 3, depending on your COMLEX-USA Level 2-PE status. Your dean would provide an attestation as noted in these pathways if you qualify. Then, if you are not in a residency program, you could seek eligibility for COMLEX-USA Level 3 though the NBOME’s Temporary Alternate Pathway for COMLEX-USA Level 3 Attestation (TAPA) program.

7. I am a COM Dean. How do I complete the attestation for the Classes of 2020 and 2021?

The dean’s attestation for graduation will be updated to include a two-step process. Step one: Dean must “check off” to indicate which candidates are graduating (this is consistent with past practice). Step two: Click the submit button a pop-up will appear to confirm the attestation with the following wording:

“You are acknowledging that each student submitted is in good academic and professional standing, meets the requirements to graduate from your COM and that they have demonstrated the fundamental osteopathic clinical skills necessary for graduation”.

Once agreed to, all checked candidates will convert to graduated status.

December 14, 2021

NBOME Extends Enhanced Attestation to Class of 2023

UPDATED DECEMBER 14, 2021

The NBOME Board of Directors has announced that it will extend its enhanced attestation guidelines for the Class of 2022 COMLEX-USA Level 3 eligibility to the Class of 2023.

Extending the enhanced attestation to the DO students in the Class of 2023 will have far-reaching benefits across the osteopathic profession; for example:

For the DO Student Class of 2023:

The enhanced attestation will allow these students to provide verification of their individual fundamental osteopathic clinical competences for eventual licensure eligibility in all 50 states—despite the inability to take the Level 2-PE due to its indefinite suspension.

For state licensing boards:

As these students will eventually seek licensure in their jurisdictions, state medical and osteopathic medical licensing boards will be confident in the verification that these individuals have proven competency in fundamental osteopathic clinical skills as attested by their osteopathic medical college.

For the osteopathic medical profession:

Extending the enhanced attestation provides additional opportunities for a thorough review of the results of the Evidence for Clinical Skills Activities Inventory, and to collaborate on optimal steps forward for a thoughtful—and more permanent—solution for assessing and verifying critical osteopathic clinical skills.

For the public:

The NBOME is committed to patient safety and protecting the health of the public through valid, reliable, and fair assessments of the fundamental osteopathic medical competencies, including clinical skills, that patients expect from osteopathic physicians and which research confirms are essential for safe and effective osteopathic medical care. Ensuring future DOs meet that standard, even as the profession and healthcare at large continue to evolve, is key to our mission.

This decision by the NBOME Board was informed by the Special Commission, which is expected to complete its work in spring 2022 and make recommendations to the NBOME Board of Directors at their June 2022 meeting. NBOME has continued to garner additional input from key stakeholder groups across the spectrum, including learners, the undergraduate and graduate medical education community, accreditors, the licensure community, and patient advocates/public members. Another period for stakeholder input and commentary on the Special Commission’s final recommendations prior to the NBOME Board decision is anticipated in May-June 2022.

August 16, 2021

Enhanced Attestation for the Class of 2022

UPDATED AUGUST 16, 2021

In light of the indefinite suspension of the COMLEX-USA Level 2-PE, the NBOME Board of Directors has approved an enhanced attestation pathway to COMLEX-USA Level 3 for the graduating DO Class of 2022.

To accomplish this, the NBOME has released the Evidence of Clinical Skills Activities 2022 Inventory. The Inventory will provide information about the activities used to educate and assess students on their osteopathic clinical skills. We believe this Inventory will reassure our stakeholders (state medical and osteopathic medical boards, residency program directors, colleges of osteopathic medicine, students, and patients) that there is evidence used to inform this enhanced attestation. In addition, we anticipate the COMs’ information to be integral for future collaboration and continuous quality improvement innovations.

April 29, 2021

Pathway for Class of 2022

UPDATED APRIL 29, 2021

To address issues related to the indefinite suspension of the COMLEX-USA Level 2-PE, the NBOME Board of Directors approved new requirements for eligibility for COMLEX-USA Level 3 for the graduating DO Class of 2022. For the Class of 2022 only, candidates may earn eligibility for COMLEX-USA Level 3 through an enhanced attestation of fundamental osteopathic clinical skills by their College of Osteopathic Medicine (COM) Deans. Further details on these enhancements and the enhanced attestation of fundamental osteopathic clinical skills for the Class of 2022 will be announced by June 30, 2021.

This enhanced attestation by the COM Dean for the Class of 2022 amends the current attestation requirement for the COMLEX-USA Level 3 examination that the Dean attests to graduation. It is a temporary process to provide validation of assessment of fundamental osteopathic clinical skill competencies for members of the Class of 2022. This will likely include documentation of multi-source feedback from direct observation of fundamental osteopathic clinical skills, but will not require graduates in the Class of 2022 to take a national standardized examination at NBOME testing centers, nor will it include any candidate fees.

For the Classes of 2023 and beyond, the NBOME continues to explore the means to assess and/or verify fundamental osteopathic clinical skills via options that may include, but are not limited to: COM clinical skills program certification, COM-based clinical skills assessment, and virtual clinical skills assessment. In March, the NBOME Board approved pathways to provide access to the COMLEX-USA Level 3 examination for those graduates of the Classes of 2020 and 2021 who were unable to access the Level 2-PE examination due to the pandemic.

This decision by the NBOME Board of Directors was based on recommendations endorsed by the Special Commission on Osteopathic Medical Licensure Assessment. The Special Commission considered extensive input from stakeholder groups across osteopathic medical education (i.e. students, residents, UME and GME faculty, and leaders), licensure, practice, and the public.

Frequently Asked Questions

1. I am a member of the Class of 2022, what do I need to do now?

You don’t need to do anything at this time. Your Dean will complete the enhanced attestation for you at graduation provided you qualify.

2. Is the attestation for the Class of 2022 the same as for members of the Classes of 2020 and 2021?

No, taking into account ongoing stakeholder concerns, the pandemic emergency, and the need to provide an opportunity for students in this class to demonstrate fundamental competencies, the Special Commission on Osteopathic Medical Licensure Assessment recommended an attestation process that is targeted to specific fundamental osteopathic clinical skills for the Class of 2022. This enhanced attestation process has been approved by the NBOME Board of Directors.

3. I am in the Class of 2023. How does this enhanced attestation apply to me?

The enhanced attestation is a process for the Class of 2022 only, given the continued limitations of the COVID-19 pandemic. The NBOME is continuing to explore options to assess and/or verify fundamental osteopathic clinical skills for the Class of 2023 and future classes. Further updates for the Class of 2023 and beyond are expected by January 2022.

4. Is there a change to the Program Director attestation?

No, the attestation from the Program Director of an ACGME-accredited program remains a separate requirement for COMLEX-USA Level 3 eligibility. Therefore, eligibility requirements for the COMLEX-USA Level 3 examination for the Class of 2022 who have never taken COMLEX-USA Level 2-PE will be the following:

• Passing of COMLEX-USA Level 2-CE
• Graduation from an accredited college of osteopathic medicine (COM) as attested by the Dean
• Enhanced attestation completed by COM Dean (details by June 30, 2021)
• Attestation by a Program Director that the candidate is in good academic and professional standing
• Recommendation of six months in residency training recommended prior to taking the Level 3 examination