On January 14, 2025, the IDFPR promulgated rules to implement SB 1298. The rules define IMGs as: Medical graduates trained outside the U.S. whose education has “been certified by the ECFMG;” having passed all steps of the USMLE; having an unencumbered license from another country; and not licensed to practice medicine in the U.S. IMGs are eligible to apply for a limited license to practice medicine in the state, and the IDFPR, upon its determination of fitness, may issue the license, which is valid for two years. Applicants must: Submit an application, plus $100 fee; provide an official transcript and diploma; provide their ECFMG certificate (waivable if the applicant hails from a “non-cooperating country”); have practiced in at least three of the last 10 years, and if the applicant has not practiced within the last three years, they must show evidence of U.S. clinical experience; submit to a background check; and enter into an agreement with a sponsoring entity, defined as a hospital, critical access teaching hospital, FQHC, state facility, CHC, or another facility approved by the IDFPR; that “provides an assessment and evaluation program designed to develop, assess, and evaluate the physician’s nonclinical and clinical skills and familiarity with standards appropriate for medical practice.” Limited licensees may only practice within the sponsoring entity and under the supervision of a “faculty supervisor” that is a fully licensed physician, and must file a practice agreement between themselves and the sponsoring entity with the IDFPR. The sponsoring entity maintains professional responsibility for the licensee, the licensee must notify the IDFPR if the practice agreement is terminated. The limited license may be renewed every two years, in accordance with Ill. Admin. Code tit. 68 § 1285.120, with an exception to the CME requirements in the initial licensure period. After at least two years of practice under the limited license, licensees may apply for a restricted license, which entitles licensees to practice independently in health professional shortage areas (HPSAs) as defined by the IDFPR. Applicants for the restricted license must: Successfully complete the two-year supervised work experience at the sponsoring entity, including the assessment and evaluation program; show proof of “anticipated” employment in an HPSA; and pay a $230 fee. After at least two years of restricted practice (at least four years total), the licensee is eligible to apply for a full, unrestricted medical license. IDFPR Rules (see § 1285.345)
