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NBOME
Special Commission on Osteopathic Medical Licensure Assessment

Pathway for Classes 2020 and 2021

The first goal for the Special Commission on Osteopathic Medical Licensure Assessment was the review and endorsement of temporary pathways for the Class of 2021 and 2020 to be eligible for the COMLEX-USA Level 3. For these graduates, eligibility to take COMLEX-USA Level 3 will be based on an attestation of their fundamental clinical skills from Deans and Residency Program Directors as outlined below. Phrases in italics are changes from current required attestations for examination eligibility.

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: for the Classes of 2020 and 2021 who have taken and passed COMLEX-USA Level 2-PE (as for prior DO graduates):

  • 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
  • 6 months of GME completion prior to taking COMLEX-USA Level 3 (Recommendation ONLY)

Pathway 2: for the Class of 2021, who have never taken COMLEX-USA Level 2-PE:

  • 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
  • 6 months of GME completion prior to taking COMLEX-USA Level 3 (Recommendation ONLY)
  • There is no requirement to travel to take COMLEX-USA Level 2-PE and there is no fee

Pathway 3: for the Classes of 2020 and 2021, who have unsuccessfully attempted (failed) COMLEX-USA Level 2-PE:

  • 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
  • 6 months of GME completion prior to taking COMLEX-USA Level 3 (Required)
  • There is no requirement to travel to take COMLEX-USA Level 2-PE and there is no fee
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.


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