State Board of Medicine Proposes Regulations to Update Exam References

Last Updated: Sep 23, 2021

The State Board of Medicine has issued proposed regulations to update its existing regulations regarding examination requirements.

The proposed regulations can be accessed here. The proposal was also published in the Sept. 18, 2021 edition of the Pennsylvania Bulletin.

These proposals conform the Board's regulations to national standards and reflect the current licensure examination accepted by the Board -- the United States Medical Licensing Examination (USMLE) -- and clarify requirements as well as standards for examinations that are no longer administered but are still valid for licensure.

What do these proposed regulations do?

  1. Updates References to No Longer Administered Exams

    The Board’s existing regulations include references to the Federation Licensing Examination (FLEX) which was comprised of the FLEX I and Flex II. The FLEX has not been administered since 1993. The Flex, although no longer administered, is still valid for licensure purposes if it was the national exam which the applicant successfully passed. The current regulations also reference the Federation Exam which was the forerunner to the FLEX and has not been administered since 1984. This exam also remains valid for licensure if it was the national exam that the applicant successfully passed.

    The Board is proposing updates to its current provisions to ensure that the regulations appropriately reflect examination standards so that MDs who passed those examinations or combinations of the older examinations that are no longer administered may apply for licensure or participate in graduate medical training in Pennsylvania.

    The proposed regulations also delete provisions regarding failure of the FLEX. These provisions are no longer needed as the FLEX is no longer administered.


  2. Updates Information Concerning the USMLE

The existing regulations reference eligibility requirements for the various steps (Steps 1, 2, and 3) of the USMLE. The proposed regulations delete these references and instead just note that eligibility requirements are set by the Federation of State Medical Boards (FSMB) and the National Board of Medical Examiners (NBME). Eligibility requirements are set by these entities and are subject to change.

The proposed regulations also delete descriptions of the various steps of the USMLE. The proposed regulations define the USMLE as “the United States Medical Licensing Examination, a single, uniform examination for medical licensure consisting of three steps” but provide no details regarding the components of these three steps. The Board’s reasoning for this deletion is that the steps of the USLME are subject to change and are established through FSMB and NBME. For example, recently, in January 2021, the two component Step 2 (which formerly consisted of Step 2 Clinical Knowledge and Step 2 Clinical Skills) was modified by FSMB and NBME to permanently discontinue the Step 2 Clinical Skills component.

How can I submit comments?

Interested parties have 30-days from publication in the Pennsylvania Bulletin to submit comments to the Board. Comments must be submitted by Oct. 18, 2021, and may be submitted as follows:

By email to:

By mail to:
Board Counsel
State Board of Medicine
P.O. Box 69523
Harrisburg, Pennsylvania 17106-5923

Comments should reference the following:
State Board of Medicine: Rulemaking 16A-4948 (Examinations)

Where Can I Find Additional Information?
For a comprehensive list of regulatory items that PAMED is tracking, please visit PAMED's Regulatory Update.

For further information on legal topics, visit PAMED’s Legal Resource Center at PAMED's Legal Resource Center provides quality, timely legal advocacy and resources for member physicians who practice in Pennsylvania.

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