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NBOME
Special Commission on Osteopathic Medical Licensure Assessment

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
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