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NBOME
Special Commission on Osteopathic Medical Licensure Assessment

Enhanced Attestation for the Class of 2022

UPDATED JUNE 29, 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 will release the Evidence of Clinical Skills Activities 2022 Inventory. Each COM will be asked to complete the Inventory with information about the activities they use 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.

Frequently Asked Questions
1. I am a member of the Class of 2022. Does this mean the NBOME will see how I performed on activities at my school?

No information will be collected regarding individual students’ performance on activities at each COM. The Inventory will only collect information about the activities themselves.

2. When will the Inventory be released?

The NBOME will conduct an introductory webinar for COM leadership on July 20. Following that session, the Inventory, along with a guide to assist in completing the Inventory, will be released to the Deans on July 30th.

3. I am a COM Dean or the contact person designated by a COM Dean to complete the Evidence of Clinical Skills Activities 2022 Inventory and I have questions about the process. How do I seek assistance?

We recommend reading the guide as a first step, but we recognize that additional questions will arise. In addition to the introductory webinar on July 20, the NBOME will host three informational webinars for COM Deans and designated contact persons throughout the process to answer questions about the Inventory.
COM Deans and contact persons can also email the NBOME for assistance using the email address included in the guide. The NBOME will compile and regularly update a FAQ list from questions received, making it available to all of the COMs as they work on the Inventory.

4. Is the Inventory the sole part of the enhanced attestation?

No, the enhanced attestation pathway is a two-part process. At graduation, Deans will still need to complete an online attestation for each graduating student, following the same process in the Dean’s NBOME Portal as for the classes of 2020 and 2021. The attestation declares that the student is in good academic and professional standing, meets the requirements to graduate from the COM, and has demonstrated the fundamental osteopathic clinical skills necessary for graduation.

5. How will the information provided on the Inventory be shared?

The information supplied on the Inventory will be used to support the attestation provided by the COM for the Class of 2022. Specific information for each COM will not be shared or published. Reports of de-identified data in the aggregate may be shared publicly and used to inform future osteopathic clinical skills education and assessment practices.

6. How does this fit into the eligibility pathway for Level 3?

Candidates for Level 3 will still need attestation from their residency program director that they are in good academic and professional standing. For more on eligibility for Level 3 for the Class of 2022, see here.

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 required 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. The requirements 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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