Pathway for Class of 2022
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
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
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?
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
Recommendation of six months in residency training recommended prior to taking the Level 3