From:  
BPL-BoardSupport  
To:  
MacIntosh, Weston (LARA)  
Subject:  
Date:  
Attachments:  
FW: Moonlighting Appeal to the State of Michigan  
Tuesday, June 14, 2022 6:58:01 AM  
Moonlighting Appeal Letter - N Amadi May 26 2022.docx  
From: Nwonukwuru Amadi <NAmadi-gme@authorityhealth.org>  
Sent: Monday, June 13, 2022 9:09 PM  
To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>  
Cc: Christopher Salazar-Fields <csalazar-fields-gme@authorityhealth.org>  
Subject: Re: Moonlighting Appeal to the State of Michigan  
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
3031 W. Grand Blvd  
Detroit, MI 48202  
June 13, 2022  
To the Michigan Board of Medicine,  
Good day,  
My name is Nwonukwuru Amadi, MD. I am a currently a first year Internal Medicine resident  
at Authority Health GME Consortium in Detroit, MI. I am writing to you to address a disparity  
that exist between Allopathic and Osteopathic medical trainees.  
In 2020, the ACGME GME MD-DO merger took place which according the ACGME website  
states the following:  
Benefits of Single GME  
The ACGME, Association of American Colleges of Osteopathic Medicine (AACOM), and  
American Osteopathic Association (AOA) are in the process of implementing a single GME  
accreditation system by the year 2020 in order to:  
Provide high-quality uniform graduate medical education accreditation that enhances  
opportunities for residents/fellows and provides transparency to the federal government,  
licensing boards, US and international credentialing committees, and most importantly the  
public.  
Increase collaboration among the medical education community to address the challenges  
facing graduate medical education for the benefit of all medical residents and fellows, and for  
the benefit of their patients.  
Reduce costs and increase efficiencies by eliminating duplicative accreditation costs and  
reporting.  
Eliminate need for programs to choose either an allopathic (MD) or osteopathic (DO)  
accreditation pathway, or face undue burden to be dually accredited by the ACGME and  
AOA.  
Provide consistency across all residency/fellowship programs in evaluation methods and  
accountability standards, using specialty-specific Milestones for assessing the competency of  
residents/fellows graduating from all US graduate medical education programs.  
Offer all US medical school graduates a uniform graduate medical education pathway,  
allowing them to seek admission into any residency and fellowship program.  
Preserve and protect osteopathic medical education in essential dimensions of the  
osteopathic tradition, including through AOA board certification, accreditation of colleges of  
osteopathic medicine, and osteopathic licensing examinations.  
Increase opportunities for osteopathic graduate medical education and recognition for all  
ACGME-accredited programs. Provide education in Osteopathic Principles and Practice to all  
allopathic (MD) and osteopathic (DO) medical school graduates; programs can receive  
designation for their osteopathic curricula through ACGME Osteopathic Recognition.  
(https://www.acgme.org/What-We-Do/Accreditation/Single-GME-Accreditation-  
System/Benefits-of-Single-GME)  
I believe the intentions of the merger was to bring consistency and equality to both the MD  
and DO GME programs. I myself am training currently in a program that was traditionally a  
DO program as an MD. However, as a resident physician when it comes to experience and  
financial opportunities such as Moonlighting, all residents are not equal as Michigan MD  
licensure requires 2 years of post graduate medical training, compared to Michigan DO  
licensure which only requires 1 year of post graduated training as stated in R 338.123 and R  
338.2423, which are listed below. This creates situations where residents who start at the same  
time, in the same residency program, receiving the same training and didactics, will be  
deemed competent to receive full licensure on identical metrics except the 2 initials following  
their name recognizing them as a Doctor of Medicine or Osteopathy. This creates a division of  
classism where MDs have less privileges and opportunities compared to their DO peers.  
Today, I am asking the Board of Medicine to consider revision to R 338.2423 to reflect the  
following:  
R 338.2423 (d) Have completed Provide proof verifying completion of a minimum of 2  
years 1 year of postgraduate clinical training in a program that satisfies the  
requirements of under R 338.2421(2), (3), (4), or (5). or (4).  
I believe this would bring equality and fairness to MD resident physicians wishing to obtain  
their full licensure after satisfying the same requirements that DO resident physicians are held  
to. Secondly, being able to see and recognize MD residents as equally competent to their DO  
peers after completing the same length of training, which is also consistent with the stated  
purpose of the 2020 ACGME MD-DO merger. I believe that are education are equivalent at  
the end of 1 year of post graduate training. I do believe that an MD would be able to fulfill the  
needs and duties that would be required by a moonlighting resident.  
Additionally, this would also make Michigan residents equal to their colleagues across sates  
lines. As of today, neighboring states of Illinois, Indiana, and Ohio also only require 1 year of  
post graduate training to be eligible to apply for full licensure, supporting documentation listed  
below. If our neighboring states have adapted to this policy, I do not see why the state of  
Michigan cannot as well  
For these reasons, I hope the Board of Medicine considers and passes this revision without  
delay.  
Best regards,  
Nwonukwuru Amadi, MD  
PGY-1 Internal Medicine Resident  
Authority Health GME  
(SUPPORTING DOCUMENTATION BELOW)  
STATE OF MICHIGAN  
R 338.123 Licensure by examination. (DO Licensure)  
Rule 23. An applicant for licensure by examination, in addition to satisfying the requirements of the  
code, shall satisfy all of the following requirements:  
(a) Submit the required fee and a completed application on a form provided by the department.  
(b) Possess a degree from a school of osteopathic medicine that satisfies the standards set forth in R  
338.121(1).  
(c) Have passed all parts of the Comprehensive Osteopathic Medical Licensing Examination  
(COMLEX) adopted under R 338.129.  
(d) Have completed a minimum of 1 year of postgraduate clinical training in a program that satisfies  
either of the following requirements:  
(i) A postgraduate training program that satisfies the requirements of R 338.121(2) at a training  
institution that satisfies the requirements of R 338.121(3).  
(ii) A postgraduate training program approved by the board in R 338.121(4).  
(e) Submit a certificate of completion of the postgraduate training required under subdivision (d) of  
this rule to the department no more than 15 days before the scheduled date of completion.  
R 338.2423 Medical doctor; license requirements; United States and Canadian graduates.  
Rule 123. An applicant for a medical license who graduated from a medical school located inside the  
United States, its territories, or the Dominion of Canada, in addition to satisfying the requirements of  
the code, shall satisfy all of the following requirements:  
(a) Submit the required fee and a completed application on a form provided by the department.  
(b) Possess a degree from a medical school that satisfies the standards set forth in R 338.2421(1).  
(c) Have passed all parts of the United States Medical Licensing Examination (USMLE) adopted under  
R 338.2431.  
(d) Have completed a minimum of 2 years of postgraduate clinical training in a program that satisfies  
the requirements of R 338.2421(2), (3), (4), or (5).  
(e) Submit a certificate of completion of the postgraduate training required under subdivision (d) of  
this rule to the department no more than 15 days prior to the scheduled date of completion.  
Other states  
STATE OF ILLINOIS  
Section 1285.70 Application for a License on the Basis of Examination  
a)  
Each applicant for a license to practice medicine in all of its branches on the basis of  
examination must submit to the Division:  
1)  
A fully completed application signed by the applicant, on which all questions have been  
answered and all programs of medical education attended by the applicant have been  
identified, including dates of attendance;  
2)  
Proof that the applicant is of good moral character. Proof shall be an indication on the  
application that the applicant has not engaged in any conduct or activities that would  
constitute grounds for discipline under Section 22 of the Act. Applications of individuals who  
answer affirmatively to any question on the personal history portion of the application or who  
have engaged in activities that would constitute grounds for discipline shall be forwarded to  
the Enforcement Division of the Division of Professional Regulation for further investigation  
and action by the Medical Licensing Board as provided in Section 9(B)(4) of the Act;  
3)  
An official transcript of a course of instruction in a college, university or other  
institution as required by Section 1285.20(a);  
4)  
5)  
Fee as required by Section 21 of the Act;  
An official transcript and diploma or an official transcript and certification of graduation  
from the medical education program granting the degree that shall be evidence that the  
applicant has met the minimum medical education requirements of the Act;  
6)  
Certification on forms provided by the Division that the core clerkship rotations were  
completed in accordance with Section 1285.20 and proof of current ECFMG certification as set  
forth in Section 1285.20(k) for those applicants who are applying under Section 11(A)(2)(a) of  
the Act;  
7)  
Proof of satisfactory completion of an approved program of clinical training in  
accordance with Section 1285.40;  
8) Proof of the successful completion of the examination set forth in Section 1285.60.  
Scores shall be submitted to the Division directly from the testing entity;  
9)  
A)  
B)  
A certification from the jurisdiction of original licensure and current licensure stating:  
The date of issuance of the license; and  
Whether the records of the licensing authority contain any record of disciplinary action  
taken or pending;  
10)  
Documentation of professional capacity, as set forth in Section 1285.95, for applicants  
who have not been engaged in the active practice of medicine or have not been enrolled in a  
medical program for 2 years prior to application; and  
11)  
Verification of fingerprint processing from the Illinois Department of State Police (ISP),  
an ISP live scan vendor whose equipment has been certified by ISP, or a fingerprint vendor  
agency licensed by the Division. Out-of-state residents unable to utilize the ISP electronic  
fingerprint process may submit to ISP one fingerprint card issued by ISP, accompanied by the  
fee specified by ISP. Fingerprints shall be taken within the 60 days prior to application.  
Section 1285.95 Professional Capacity Standards for Applicants Having Graduated More  
Than 2 Years Prior to Application  
Pursuant to Section 9(B)(4) of the Act, in determining professional capacity for individuals who  
have not been actively engaged in the practice of medicine or as a medical, osteopathic, or  
chiropractic student or who have not been engaged in a formal program of medical education  
during the 2 years immediately preceding application, the individual may be required to  
complete such additional testing, training, or remedial education as the Licensing Board may  
deem necessary to establish the applicant's present capacity to practice medicine with  
reasonable judgment, skill and safety. In determining professional capacity, the Board shall  
consider, but not be limited to, the following activities:  
a)  
Medical research that is human clinical research consistent with the requirements of  
the Federal Food and Drug Administration (21 CFR 50) (2001, no further amendments or  
additions included) and the Consumer Product Safety Commission (16 CFR 1028) (2001, no  
further amendments or additions included) or other equivalent medical research.  
b)  
Specialized training or education that is clinical training or clinical education such as, or  
equivalent to, the following:  
1)  
Clinical training that takes place in a residency training program in accordance with the  
requirements set forth in Section 1285.40 of this Part or the equivalent (e.g., residency  
training in another state or jurisdiction).  
2)  
3)  
Clinical medical practice in the National Health Service or its equivalent.  
Continuing medical education (CME) recognized by the Accreditation Council on  
Continuing Medical Education (ACCME), the American Osteopathic Association (AOA),  
American Chiropractic Association (ACA), or continuing medical education in accordance with  
Section 1285.110 of this Part.  
4)  
Post-graduate education in basic or related medical sciences in any state or  
jurisdiction.  
c)  
Publication of original work in clinical medicine published in medical or scientific  
journals that are listed by the Cumulative Index Medicas (CIM).  
d)  
Clinical research or professional clinical medical practice in public health organizations  
(e.g., World Health Organization (WHO), Malaria Prevention programs, United Nations  
International Children's Emergency Fund (UNICEF) programs, both national and  
international).  
e)  
Having been engaged in clinical research or clinical medical practice at a veterans,  
military, or other medical institution operated by the federal government.  
f) Other professional or clinical medical activities or chiropractic activities, such as, or  
equivalent to, the following:  
1)  
Presentation of papers or participation on panels as a faculty member at a program  
approved or recognized by the American Medical Association (AMA) or its affiliates, the  
American Osteopathic Association (AOA) or its affiliates, the American Chiropractic Association  
(ACA) or its affiliates, or a recognized specialty society or equivalent recognized by the medical  
community; or  
2)  
Act.  
Experience obtained as a Visiting Professor in accordance with Section 18(A) of the  
g)  
Clinical medical practice obtained in violation of the Act shall not be considered by the  
Board in determining professional capacity for the purposes of this Section.  
h)  
Each applicant for temporary licensure, in accordance with this Section, shall submit a  
certificate of acceptance form signed by the program director of an approved residency  
training program, in accordance with Section 1285.40 of this Part, attesting that the applicant  
will be accepted for specialty/residency training, if, upon the evaluation of medical education  
and clinical skills by the Division, the applicant is found to be eligible for temporary licensure.  
i)  
In determining eligibility, the Board will consider any and all documentation of activities  
submitted by the applicant.  
(Source: Amended at 29 Ill. Reg. 18823, effective November 4, 2005)  
SOUTHERN ILLINOIS UNIVERSITY SCHOOL OF MEDICINE  
Moonlighting Policy  
I. Preamble  
The term “resident” is inclusive of all trainees at SIU School of Medicine, whether training in a  
residency or fellowship program. The goals of this policy are to outline:  
the allowable parameters for moonlighting  
the steps required to apply for moonlighting approval  
Residents will accept no responsibilities for professional activities outside the scope of the  
Residency Program (including, but not limited to "moonlighting") unless approved in writing by  
the employing hospital via the Office of Graduate Medical Education (OGME) and the Program  
Director, who shall have discretion as to whether or not such outside professional activities  
are permitted. Residents must not be required to engage in “moonlighting.”  
If a program chooses to allow moonlighting, there must be an internal policy established with  
the specific parameters for the program.  
Section I: External Moonlighting  
This is defined as voluntary, compensated, medically–related work performed outside the  
training program. With regard to those residency programs in which outside professional  
activities may be permitted, the following shall apply:  
a. The professional activities must be of educational value and must not interfere with the  
ability of the resident to achieve the goals and objectives of the educational program.  
b. The professional activities must have the approval of the Program Director. The Program  
Director must acknowledge this approval in writing, and a copy of that acknowledgement  
must be included in the resident’s file.  
c. The professional activities must have approval of the employing hospital.*  
d. The professional activities must not detract from the Residency Program or interfere in any  
way with the educational experience, performance or responsibilities of the resident. If such  
moonlighting activities are approved, the Program Director must monitor the resident for the  
effect of moonlighting activities upon performance. Adverse effects may lead to withdrawal of  
permission.  
e. All time spent moonlighting must be entered into New Innovations in a timely and accurate  
manner and counted toward the 80 hour weekly limit on work hours. Moonlighting on  
vacation does not need to be recorded, however the residents must ensure they are adequately  
rested and fit to provide the services required by their patients when returning to duty.  
f. PGY-1 residents are not permitted to moonlight.  
(https://www.siumed.edu/gme/policies/moonlighting-policy)  
UNIVERSITY OF ILLINOIS COLLEGE OF MEDICINE  
Graduate Medical Education Policies and Procedures  
Policy on Moonlighting  
PURPOSE: To assure an environment which balances learning and service, and protects  
patient safety and physician well-being.  
POLICY: Moonlighting is not a requirement. Moonlighting must not interfere with resident  
progress in the program.  
Moonlighting is after hours professional care activity that is not a part of a written curriculum  
and is independent of the residency program.  
It is the responsibility of the resident to assure that licensing and liability insurance are  
appropriate for work outside the residency program. Resident moonlighting hours must be  
approved in advance and reported to the program director and when combined with residency  
duty hours may not exceed 80 hours per week.  
PGY-1 Residents are not permitted to moonlight.  
(https://www.med.illinois.edu/depts_programs/gme/policies/moonlighting.php)  
STATE OF OHIO  
Section 4731.09 | Qualifications for license to practice medicine and surgery or osteopathic  
medicine and surgery.  
Ohio Revised Code/Title 47 Occupations-Professions/Chapter 4731 Physicians; Limited  
Practitioners  
Effective:  
October 9, 2021  
Latest Legislation:  
House Bill 263 - 133rd General Assembly  
(A) An applicant for a license to practice medicine and surgery or osteopathic medicine and  
surgery must meet all of the following requirements:  
(1) Be at least eighteen years of age;  
(2) Possess a high school diploma or a certificate of high school equivalence or have obtained  
the equivalent of such education as determined by the state medical board;  
(3) Have completed two years of undergraduate work in a college of arts and sciences or the  
equivalent of such education as determined by the board;  
(4) Meet one of the following medical education and graduate medical education  
requirements:  
(a) Hold a diploma from a medical school or osteopathic medical school that, at the time the  
diploma was issued, was a medical school accredited by the liaison committee on medical  
education or an osteopathic medical school accredited by the American osteopathic  
association and have successfully completed not less than twelve months of graduate medical  
education through the first-year level of graduate medical education or its equivalent as  
determined by the board;  
(b) Hold certification from the educational commission for foreign medical graduates and have  
successfully completed not less than twenty-four months of graduate medical education  
through the second-year level of graduate medical education or its equivalent as determined by  
the board;  
(c) Be a qualified graduate of a fifth pathway training program as recognized by the board  
under section 4731.091 of the Revised Code and have successfully completed, subsequent to  
completing fifth pathway training, not less than twelve months of graduate medical education  
or its equivalent as determined by the board.  
(5) Have successfully passed an examination prescribed in rules adopted by the board to  
determine competency to practice medicine and surgery or osteopathic medicine and  
surgery;  
(6) Comply with section 4731.08 of the Revised Code;  
(7) Meet the requirements of section 4731.142 of the Revised Code if eligibility for the license  
applied for is based in part on certification from the educational commission for foreign  
medical graduates and the undergraduate education requirements established by this section  
were fulfilled at an institution outside of the United States.  
(B) An applicant for a license to practice medicine and surgery or osteopathic medicine and  
surgery shall submit to the board an application in the form and manner prescribed by the  
board. The application must include all of the following:  
(1) Evidence satisfactory to the board to demonstrate that the applicant meets all of the  
requirements of division (A) of this section;  
(2) An attestation that the information submitted under this section is accurate and truthful;  
(3) Consent to the release of the applicant's information;  
(4) Any other information the board requires.  
(C) An applicant for a license to practice medicine and surgery or osteopathic medicine and  
surgery shall include with the application a fee of three hundred five dollars, no part of which  
may be returned. An application is not considered submitted until the board receives the fee.  
(D) The board may conduct an investigation related to the application materials received  
pursuant to this section and may contact any individual, agency, or organization for  
recommendations or other information about the applicant.  
(E) The board shall conclude any investigation of an applicant conducted under  
section 4731.22 of the Revised Code not later than ninety days after receipt of a complete  
application unless the applicant agrees in writing to an extension or the board determines that  
there is a substantial question of a violation of this chapter or the rules adopted under it and  
notifies the applicant in writing of the reasons for continuation of the investigation. If the  
board determines that the applicant is not in violation of this chapter or the rules adopted under  
it, the board shall issue a license not later than forty-five days after making that  
determination.  
THE STATE OF INDIANA  
Physician/Osteopathic Physician  
Application for licensure as a physician/osteopathic physician  
Application Instructions/Checklist - IMPORTANT!  
We ask that you please allow up to two weeks from the submission of an application for  
review by our staff. You will be notified via mail or email if there are any missing documents  
or issues with your application. You may also check the status of your application by  
clicking here. If you have not received a status update after two weeks, you may email us at  
pla3@pla.in.gov.  
General Information  
To be eligible for a Physician or Osteopathic Physician license, applicants must have received  
all of their medical school education from and graduated from a medical school recognized or  
approved by the Medical Licensing Board. Prior to submitting an application, please refer to  
the following links to verify that your medical school or training location is recognized or  
approved:  
Approved/Disapproved Foreign Medical Schools  
Approved Allopathic U.S./Canadian Medical Schools  
Approved Osteopathic U.S. Medical Schools  
Approved ACGME-accredited postgraduate training programs  
Approved AOA-accredited postgraduate training programs  
Approved Royal College of Physicians and Surgeons of Canada postgraduate training  
programs  
If you did not attend or graduate from a recognized or approved medical school or  
postgraduate training program, you may still an submit an application for licensure and request  
a waiver in writing. Waiver requests are reviewed on a case-by-case basis, and may require a  
personal appearance before the Medical Licensing Board. In determining whether to grant a  
waiver, the Medical Licensing Board will consider an applicant's training, experience, and  
credentials.  
General Questions about Licensure  
How Long Does it Take to Get a License?  
Questions Regarding Examinations  
Questions Regarding Criminal Background Checks  
Questions about Criminal Convictions  
Questions Regarding Recognized Medical Schools  
Questions about Translations of Documents  
Helpful Links  
General Questions about Licensure  
Q. How much training must I complete before I am eligible for licensure?  
A. U.S./Canadian graduates must complete 12 months of approved postgraduate training in the  
U.S. or Canada. An International Medical Graduate must complete 24 months of approved  
postgraduate training in the U.S. or Canada.  
Q. Should I report incomplete postgraduate training on the application?  
A. Yes. You are required to document all postgraduate training (internship, residency,  
fellowship) on the application, whether or not the program was completed or credit was  
granted. You must have each postgraduate training program verify your dates of training for  
each program.  
Q. What are the costs related to licensure?  
A. The fee for the application is $250. If you also require a controlled substances registration,  
that application fee is $60. All fees should be paid my cash, check or money order and  
submitted with your application. Checks and money orders should be made payable to the  
Indiana Professional Licensing Agency. We do not accept credit card payments.  
Q. When should I apply for licensure?  
A. Since a U.S./Canadian medical school graduate is not eligible for licensure until one year of  
training has been completed, you should not submit your application until after six months of  
training have been completed.  
Further, documentation relating to your application can be submitted at any time; you do not  
need to wait until your application has been submitted. The Board will retain documents for 6  
months.  
Q. Should I take Step 3 before I apply for licensure?  
A. You are not required to take and pass the USMLE Step 3/COMLEX Step 3 before you  
apply; however, a license will not be issued to any applicant until they have passed all three  
steps. In Indiana, you must pass all three steps of the USMLE within 10 years, with a  
maximum attempt of three times per step. For osteopathic physicians, all three steps must be  
passed within 7 years, with a maximum attempt of fives times per step.  
Applicants who fail to pass all the steps within the required timeframe or within the maximum  
number of attempts may stil apply for licensure and request a waiver. Waiver requests are  
reviewed on a case-by-case basis, and may require a personal appearance before the Medical  
Licensing Board. In determining whether to grant a waiver, the Medical Licensing Board will  
consider an applicant's training, experience, and credentials. Additional conditions, such as  
agreeing to work in an underserved area, may be required if a waiver is granted.  
Q. How long is my license valid?  
A. Upon issuance of your license, your license will remain valid through October 31 of each  
odd year.  
(https://www.in.gov/pla/professions/medical-licensing-board-of-indiana/physicianosteopathic-  
physician/)  
============================================================================  
==========  
Dr. Nwonukwuru (Onu) Amadi, MD  
PGY-1 Internal Medicine  
Authority Health GME Consortium  
3031 W. Grand Blvd, Suite 600  
Detroit, MI 48201  
Phone: (313) 871-3751  
www.authorityhealth.org  
FOLLOW US AT:  
3031 W. Grand Blvd  
Detroit, MI 48202  
June 13, 2022  
To the Michigan Board of Medicine,  
Good day,  
My name is Nwonukwuru Amadi, MD. I am a currently a first year Internal Medicine resident at  
Authority Health GME Consortium in Detroit, MI. I am writing to you to address a disparity that exist  
between Allopathic and Osteopathic medical trainees.  
In 2020, the ACGME GME MD-DO merger took place which according the ACGME website states the  
following:  
Benefits of Single GME  
The ACGME, Association of American Colleges of Osteopathic Medicine (AACOM), and American  
Osteopathic Association (AOA) are in the process of implementing a single GME accreditation system by  
the year 2020 in order to:  
•
Provide high-quality uniform graduate medical education accreditation that enhances  
opportunities for residents/fellows and provides transparency to the federal government,  
licensing boards, US and international credentialing committees, and most importantly the  
public.  
•
Increase collaboration among the medical education community to address the challenges  
facing graduate medical education for the benefit of all medical residents and fellows, and for  
the benefit of their patients.  
•
•
•
Reduce costs and increase efficiencies by eliminating duplicative accreditation costs and  
reporting.  
Eliminate need for programs to choose either an allopathic (MD) or osteopathic (DO)  
accreditation pathway, or face undue burden to be dually accredited by the ACGME and AOA.  
Provide consistency across all residency/fellowship programs in evaluation methods and  
accountability standards, using specialty-specific Milestones for assessing the competency of  
residents/fellows graduating from all US graduate medical education programs.  
Offer all US medical school graduates a uniform graduate medical education pathway,  
allowing them to seek admission into any residency and fellowship program.  
Preserve and protect osteopathic medical education in essential dimensions of the osteopathic  
tradition, including through AOA board certification, accreditation of colleges of osteopathic  
medicine, and osteopathic licensing examinations.  
•
•
•
Increase opportunities for osteopathic graduate medical education and recognition for all  
ACGME-accredited programs. Provide education in Osteopathic Principles and Practice to all  
allopathic (MD) and osteopathic (DO) medical school graduates; programs can receive  
designation for their osteopathic curricula through ACGME Osteopathic Recognition.  
(https://www.acgme.org/What-We-Do/Accreditation/Single-GME-Accreditation-  
System/Benefits-of-Single-GME)  
I believe the intentions of the merger was to bring consistency and equality to both the MD and DO  
GME programs. I myself am training currently in a program that was traditionally a DO program as an  
MD. However, as a resident physician when it comes to experience and financial opportunities such as  
Moonlighting, all residents are not equal as Michigan MD licensure requires 2 years of post graduate  
medical training, compared to Michigan DO licensure which only requires 1 year of post graduated  
training as stated in R 338.123 and R 338.2423, which are listed below. This creates situations where  
residents who start at the same time, in the same residency program, receiving the same training and  
didactics, will be deemed competent to receive full licensure on identical metrics except the 2 initials  
following their name recognizing them as a Doctor of Medicine or Osteopathy. This creates a division of  
classism where MDs have less privileges and opportunities compared to their DO peers.  
Today, I am asking the Board of Medicine to consider revision to R 338.2423 to reflect the following:  
•
R 338.2423 (d) Have completed Provide proof verifying completion of a minimum of 2 years 1  
year of postgraduate clinical training in a program that satisfies the requirements of under R  
338.2421(2), (3), (4), or (5). or (4).  
I believe this would bring equality and fairness to MD resident physicians wishing to obtain their full  
licensure after satisfying the same requirements that DO resident physicians are held to. Secondly,  
being able to see and recognize MD residents as equally competent to their DO peers after completing  
the same length of training, which is also consistent with the stated purpose of the 2020 ACGME MD-DO  
merger. I believe that are education are equivalent at the end of 1 year of post graduate training. I do  
believe that an MD would be able to fulfill the needs and duties that would be required by a  
moonlighting resident.  
Additionally, this would also make Michigan residents equal to their colleagues across sates lines. As of  
today, neighboring states of Illinois, Indiana, and Ohio also only require 1 year of post graduate training  
to be eligible to apply for full licensure, supporting documentation listed below. If our neighboring  
states have adapted to this policy, I do not see why the state of Michigan cannot as well  
For these reasons, I hope the Board of Medicine considers and passes this revision without delay.  
Best regards,  
Nwonukwuru Amadi, MD  
PGY-1 Internal Medicine Resident  
Authority Health GME  
(SUPPORTING DOCUMENTATION BELOW)  
STATE OF MICHIGAN  
R 338.123 Licensure by examination. (DO Licensure)  
Rule 23. An applicant for licensure by examination, in addition to satisfying the requirements of the  
code, shall satisfy all of the following requirements:  
(a) Submit the required fee and a completed application on a form provided by the department.  
(b) Possess a degree from a school of osteopathic medicine that satisfies the standards set forth in R  
338.121(1).  
(c) Have passed all parts of the Comprehensive Osteopathic Medical Licensing Examination  
(COMLEX) adopted under R 338.129.  
(d) Have completed a minimum of 1 year of postgraduate clinical training in a program that satisfies  
either of the following requirements:  
(i) A postgraduate training program that satisfies the requirements of R 338.121(2) at a training  
institution that satisfies the requirements of R 338.121(3).  
(ii) A postgraduate training program approved by the board in R 338.121(4).  
(e) Submit a certificate of completion of the postgraduate training required under subdivision (d) of  
this rule to the department no more than 15 days before the scheduled date of completion.  
R 338.2423 Medical doctor; license requirements; United States and Canadian graduates.  
Rule 123. An applicant for a medical license who graduated from a medical school located inside the  
United States, its territories, or the Dominion of Canada, in addition to satisfying the requirements  
of the code, shall satisfy all of the following requirements:  
(a) Submit the required fee and a completed application on a form provided by the department.  
(b) Possess a degree from a medical school that satisfies the standards set forth in R 338.2421(1).  
(c) Have passed all parts of the United States Medical Licensing Examination (USMLE) adopted  
under R 338.2431.  
(d) Have completed a minimum of 2 years of postgraduate clinical training in a program that  
satisfies the requirements of R 338.2421(2), (3), (4), or (5).  
(e) Submit a certificate of completion of the postgraduate training required under subdivision (d) of  
this rule to the department no more than 15 days prior to the scheduled date of completion.  
Other states  
STATE OF ILLINOIS  
Section 1285.70 Application for a License on the Basis of Examination  
a)  
Each applicant for a license to practice medicine in all of its branches on the basis of examination  
must submit to the Division:  
1)  
A fully completed application signed by the applicant, on which all questions have been answered  
and all programs of medical education attended by the applicant have been identified, including dates of  
attendance;  
2)  
Proof that the applicant is of good moral character. Proof shall be an indication on the  
application that the applicant has not engaged in any conduct or activities that would constitute grounds  
for discipline under Section 22 of the Act. Applications of individuals who answer affirmatively to any  
question on the personal history portion of the application or who have engaged in activities that would  
constitute grounds for discipline shall be forwarded to the Enforcement Division of the Division of  
Professional Regulation for further investigation and action by the Medical Licensing Board as provided  
in Section 9(B)(4) of the Act;  
3)  
An official transcript of a course of instruction in a college, university or other institution as  
required by Section 1285.20(a);  
4)  
5)  
Fee as required by Section 21 of the Act;  
An official transcript and diploma or an official transcript and certification of graduation from the  
medical education program granting the degree that shall be evidence that the applicant has met the  
minimum medical education requirements of the Act;  
6)  
Certification on forms provided by the Division that the core clerkship rotations were completed  
in accordance with Section 1285.20 and proof of current ECFMG certification as set forth in Section  
1285.20(k) for those applicants who are applying under Section 11(A)(2)(a) of the Act;  
7)  
Proof of satisfactory completion of an approved program of clinical training in accordance with  
Section 1285.40;  
8)  
Proof of the successful completion of the examination set forth in Section 1285.60. Scores shall  
be submitted to the Division directly from the testing entity;  
9)  
A)  
B)  
A certification from the jurisdiction of original licensure and current licensure stating:  
The date of issuance of the license; and  
Whether the records of the licensing authority contain any record of disciplinary action taken or  
pending;  
10)  
Documentation of professional capacity, as set forth in Section 1285.95, for applicants who have  
not been engaged in the active practice of medicine or have not been enrolled in a medical program for  
2 years prior to application; and  
11)  
Verification of fingerprint processing from the Illinois Department of State Police (ISP), an ISP live  
scan vendor whose equipment has been certified by ISP, or a fingerprint vendor agency licensed by the  
Division. Out-of-state residents unable to utilize the ISP electronic fingerprint process may submit to ISP  
one fingerprint card issued by ISP, accompanied by the fee specified by ISP. Fingerprints shall be taken  
within the 60 days prior to application.  
Section 1285.95 Professional Capacity Standards for Applicants Having Graduated More Than 2 Years  
Prior to Application  
Pursuant to Section 9(B)(4) of the Act, in determining professional capacity for individuals who have not  
been actively engaged in the practice of medicine or as a medical, osteopathic, or chiropractic student  
or who have not been engaged in a formal program of medical education during the 2 years  
immediately preceding application, the individual may be required to complete such additional testing,  
training, or remedial education as the Licensing Board may deem necessary to establish the applicant's  
present capacity to practice medicine with reasonable judgment, skill and safety. In determining  
professional capacity, the Board shall consider, but not be limited to, the following activities:  
a)  
Medical research that is human clinical research consistent with the requirements of the Federal  
Food and Drug Administration (21 CFR 50) (2001, no further amendments or additions included) and the  
Consumer Product Safety Commission (16 CFR 1028) (2001, no further amendments or additions  
included) or other equivalent medical research.  
b)  
Specialized training or education that is clinical training or clinical education such as, or  
equivalent to, the following:  
1) Clinical training that takes place in a residency training program in accordance with the  
requirements set forth in Section 1285.40 of this Part or the equivalent (e.g., residency training in  
another state or jurisdiction).  
2)  
3)  
Clinical medical practice in the National Health Service or its equivalent.  
Continuing medical education (CME) recognized by the Accreditation Council on Continuing  
Medical Education (ACCME), the American Osteopathic Association (AOA), American Chiropractic  
Association (ACA), or continuing medical education in accordance with Section 1285.110 of this Part.  
4)  
c)  
Post-graduate education in basic or related medical sciences in any state or jurisdiction.  
Publication of original work in clinical medicine published in medical or scientific journals that are  
listed by the Cumulative Index Medicas (CIM).  
d) Clinical research or professional clinical medical practice in public health organizations (e.g.,  
World Health Organization (WHO), Malaria Prevention programs, United Nations International  
Children's Emergency Fund (UNICEF) programs, both national and international).  
e)  
Having been engaged in clinical research or clinical medical practice at a veterans, military, or  
other medical institution operated by the federal government.  
f) Other professional or clinical medical activities or chiropractic activities, such as, or equivalent to,  
the following:  
1)  
Presentation of papers or participation on panels as a faculty member at a program approved or  
recognized by the American Medical Association (AMA) or its affiliates, the American Osteopathic  
Association (AOA) or its affiliates, the American Chiropractic Association (ACA) or its affiliates, or a  
recognized specialty society or equivalent recognized by the medical community; or  
2)  
g)  
Experience obtained as a Visiting Professor in accordance with Section 18(A) of the Act.  
Clinical medical practice obtained in violation of the Act shall not be considered by the Board in  
determining professional capacity for the purposes of this Section.  
h) Each applicant for temporary licensure, in accordance with this Section, shall submit a certificate  
of acceptance form signed by the program director of an approved residency training program, in  
accordance with Section 1285.40 of this Part, attesting that the applicant will be accepted for  
specialty/residency training, if, upon the evaluation of medical education and clinical skills by the  
Division, the applicant is found to be eligible for temporary licensure.  
i)  
In determining eligibility, the Board will consider any and all documentation of activities  
submitted by the applicant.  
(Source: Amended at 29 Ill. Reg. 18823, effective November 4, 2005)  
SOUTHERN ILLINOIS UNIVERSITY SCHOOL OF MEDICINE  
Moonlighting Policy  
I. Preamble  
The term “resident” is inclusive of all trainees at SIU School of Medicine, whether training in a residency  
or fellowship program. The goals of this policy are to outline:  
•
•
the allowable parameters for moonlighting  
the steps required to apply for moonlighting approval  
Residents will accept no responsibilities for professional activities outside the scope of the Residency  
Program (including, but not limited to "moonlighting") unless approved in writing by the employing  
hospital via the Office of Graduate Medical Education (OGME) and the Program Director, who shall have  
discretion as to whether or not such outside professional activities are permitted. Residents must not be  
required to engage in “moonlighting.”  
If a program chooses to allow moonlighting, there must be an internal policy established with the  
specific parameters for the program.  
Section I: External Moonlighting  
This is defined as voluntary, compensated, medically–related work performed outside the training  
program. With regard to those residency programs in which outside professional activities may be  
permitted, the following shall apply:  
a. The professional activities must be of educational value and must not interfere with the ability of the  
resident to achieve the goals and objectives of the educational program.  
b. The professional activities must have the approval of the Program Director. The Program Director  
must acknowledge this approval in writing, and a copy of that acknowledgement must be included in the  
resident’s file.  
c. The professional activities must have approval of the employing hospital.*  
d. The professional activities must not detract from the Residency Program or interfere in any way with  
the educational experience, performance or responsibilities of the resident. If such moonlighting  
activities are approved, the Program Director must monitor the resident for the effect of moonlighting  
activities upon performance. Adverse effects may lead to withdrawal of permission.  
e. All time spent moonlighting must be entered into New Innovations in a timely and accurate manner  
and counted toward the 80 hour weekly limit on work hours. Moonlighting on vacation does not need to  
be recorded, however the residents must ensure they are adequately rested and fit to provide the  
services required by their patients when returning to duty.  
f. PGY-1 residents are not permitted to moonlight.  
(https://www.siumed.edu/gme/policies/moonlighting-policy)  
UNIVERSITY OF ILLINOIS COLLEGE OF MEDICINE  
Graduate Medical Education Policies and Procedures  
Policy on Moonlighting  
PURPOSE: To assure an environment which balances learning and service, and protects patient safety  
and physician well-being.  
POLICY: Moonlighting is not a requirement. Moonlighting must not interfere with resident progress in  
the program.  
Moonlighting is after hours professional care activity that is not a part of a written curriculum and is  
independent of the residency program.  
It is the responsibility of the resident to assure that licensing and liability insurance are appropriate for  
work outside the residency program. Resident moonlighting hours must be approved in advance and  
reported to the program director and when combined with residency duty hours may not exceed 80  
hours per week.  
PGY-1 Residents are not permitted to moonlight.  
(https://www.med.illinois.edu/depts_programs/gme/policies/moonlighting.php)  
STATE OF OHIO  
Section 4731.09 | Qualifications for license to practice medicine and surgery or osteopathic medicine  
and surgery.  
Ohio Revised Code/Title 47 Occupations-Professions/Chapter 4731 Physicians; Limited Practitioners  
Effective:  
October 9, 2021  
Latest Legislation:  
House Bill 263 - 133rd General Assembly  
(A) An applicant for a license to practice medicine and surgery or osteopathic medicine and surgery must  
meet all of the following requirements:  
(1) Be at least eighteen years of age;  
(2) Possess a high school diploma or a certificate of high school equivalence or have obtained the  
equivalent of such education as determined by the state medical board;  
(3) Have completed two years of undergraduate work in a college of arts and sciences or the equivalent  
of such education as determined by the board;  
(4) Meet one of the following medical education and graduate medical education requirements:  
(a) Hold a diploma from a medical school or osteopathic medical school that, at the time the diploma  
was issued, was a medical school accredited by the liaison committee on medical education or an  
osteopathic medical school accredited by the American osteopathic association and have successfully  
completed not less than twelve months of graduate medical education through the first-year level of  
graduate medical education or its equivalent as determined by the board;  
(b) Hold certification from the educational commission for foreign medical graduates and have  
successfully completed not less than twenty-four months of graduate medical education through the  
second-year level of graduate medical education or its equivalent as determined by the board;  
(c) Be a qualified graduate of a fifth pathway training program as recognized by the board under  
section 4731.091 of the Revised Code and have successfully completed, subsequent to completing fifth  
pathway training, not less than twelve months of graduate medical education or its equivalent as  
determined by the board.  
(5) Have successfully passed an examination prescribed in rules adopted by the board to determine  
competency to practice medicine and surgery or osteopathic medicine and surgery;  
(6) Comply with section 4731.08 of the Revised Code;  
(7) Meet the requirements of section 4731.142 of the Revised Code if eligibility for the license applied  
for is based in part on certification from the educational commission for foreign medical graduates and  
the undergraduate education requirements established by this section were fulfilled at an institution  
outside of the United States.  
(B) An applicant for a license to practice medicine and surgery or osteopathic medicine and surgery shall  
submit to the board an application in the form and manner prescribed by the board. The application  
must include all of the following:  
(1) Evidence satisfactory to the board to demonstrate that the applicant meets all of the requirements  
of division (A) of this section;  
(2) An attestation that the information submitted under this section is accurate and truthful;  
(3) Consent to the release of the applicant's information;  
(4) Any other information the board requires.  
(C) An applicant for a license to practice medicine and surgery or osteopathic medicine and surgery shall  
include with the application a fee of three hundred five dollars, no part of which may be returned. An  
application is not considered submitted until the board receives the fee.  
(D) The board may conduct an investigation related to the application materials received pursuant to  
this section and may contact any individual, agency, or organization for recommendations or other  
information about the applicant.  
(E) The board shall conclude any investigation of an applicant conducted under section 4731.22 of the  
Revised Code not later than ninety days after receipt of a complete application unless the applicant  
agrees in writing to an extension or the board determines that there is a substantial question of a  
violation of this chapter or the rules adopted under it and notifies the applicant in writing of the reasons  
for continuation of the investigation. If the board determines that the applicant is not in violation of this  
chapter or the rules adopted under it, the board shall issue a license not later than forty-five days after  
making that determination.  
THE STATE OF INDIANA  
Physician/Osteopathic Physician  
Application for licensure as a physician/osteopathic physician  
Application Instructions/Checklist - IMPORTANT!  
We ask that you please allow up to two weeks from the submission of an application for review by our  
staff. You will be notified via mail or email if there are any missing documents or issues with your  
application. You may also check the status of your application by clicking here. If you have not received  
a status update after two weeks, you may email us at pla3@pla.in.gov.  
General Information  
To be eligible for a Physician or Osteopathic Physician license, applicants must have received all of their  
medical school education from and graduated from a medical school recognized or approved by the  
Medical Licensing Board. Prior to submitting an application, please refer to the following links to verify  
that your medical school or training location is recognized or approved:  
•
•
•
•
•
•
Approved/Disapproved Foreign Medical Schools  
Approved Allopathic U.S./Canadian Medical Schools  
Approved Osteopathic U.S. Medical Schools  
Approved ACGME-accredited postgraduate training programs  
Approved AOA-accredited postgraduate training programs  
Approved Royal College of Physicians and Surgeons of Canada postgraduate training programs  
If you did not attend or graduate from a recognized or approved medical school or postgraduate training  
program, you may still an submit an application for licensure and request a waiver in writing. Waiver  
requests are reviewed on a case-by-case basis, and may require a personal appearance before the  
Medical Licensing Board. In determining whether to grant a waiver, the Medical Licensing Board will  
consider an applicant's training, experience, and credentials.  
General Questions about Licensure  
How Long Does it Take to Get a License?  
Questions Regarding Examinations  
Questions Regarding Criminal Background Checks  
Questions about Criminal Convictions  
Questions Regarding Recognized Medical Schools  
Questions about Translations of Documents  
Helpful Links  
General Questions about Licensure  
Q. How much training must I complete before I am eligible for licensure?  
A. U.S./Canadian graduates must complete 12 months of approved postgraduate training in the U.S. or  
Canada. An International Medical Graduate must complete 24 months of approved postgraduate  
training in the U.S. or Canada.  
Q. Should I report incomplete postgraduate training on the application?  
A. Yes. You are required to document all postgraduate training (internship, residency, fellowship) on the  
application, whether or not the program was completed or credit was granted. You must have each  
postgraduate training program verify your dates of training for each program.  
Q. What are the costs related to licensure?  
A. The fee for the application is $250. If you also require a controlled substances registration, that  
application fee is $60. All fees should be paid my cash, check or money order and submitted with your  
application. Checks and money orders should be made payable to the Indiana Professional Licensing  
Agency. We do not accept credit card payments.  
Q. When should I apply for licensure?  
A. Since a U.S./Canadian medical school graduate is not eligible for licensure until one year of training  
has been completed, you should not submit your application until after six months of training have been  
completed.  
Further, documentation relating to your application can be submitted at any time; you do not need to  
wait until your application has been submitted. The Board will retain documents for 6 months.  
Q. Should I take Step 3 before I apply for licensure?  
A. You are not required to take and pass the USMLE Step 3/COMLEX Step 3 before you apply; however, a  
license will not be issued to any applicant until they have passed all three steps. In Indiana, you must  
pass all three steps of the USMLE within 10 years, with a maximum attempt of three times per step. For  
osteopathic physicians, all three steps must be passed within 7 years, with a maximum attempt of fives  
times per step.  
Applicants who fail to pass all the steps within the required timeframe or within the maximum number  
of attempts may stil apply for licensure and request a waiver. Waiver requests are reviewed on a case-  
by-case basis, and may require a personal appearance before the Medical Licensing Board. In  
determining whether to grant a waiver, the Medical Licensing Board will consider an applicant's training,  
experience, and credentials. Additional conditions, such as agreeing to work in an underserved area,  
may be required if a waiver is granted.  
Q. How long is my license valid?  
A. Upon issuance of your license, your license will remain valid through October 31 of each odd year.  
(https://www.in.gov/pla/professions/medical-licensing-board-of-indiana/physicianosteopathic-  
physician/)  
From:  
To:  
BPL-BoardSupport  
MacIntosh, Weston (LARA)  
Subject:  
Date:  
FW: Petition to Appeal the 2yr MD requirement for full licensure  
Thursday, June 16, 2022 8:28:25 AM  
-----Original Message-----  
From: Bernard Hardy <bhardy-gme@authorityhealth.org>  
Sent: Wednesday, June 15, 2022 11:24 PM  
To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>  
Subject: Petition to Appeal the 2yr MD requirement for full licensure  
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
Good evening,  
My name is Bernard Hardy II, MD and I am currently completing my intern year at the moment, and looking  
forward to the responsibilities of a 2nd-year senior resident. I would like the committee to consider the  
consequences of limiting the ability of its MD residents to moonlight. I see moonlighting as an opportunity to gain  
more experience by managing more patients, seeing different cases, and being placed in different hospital systems  
and environments -- becoming more involved with the patient population and more familiar with future colleagues.  
One thing that troubled me most during the most recent COVID resurgence, was how such an eager and  
knowledgeable group of rising healthcare professionals were limited in their ability to lend a hand! Residents are an  
under-utilized healthcare workforce that could certainly fill-in some of the gaps in healthcare delivery to the  
underserved; and the more we are utilized, the better we can become (and quicker!!) Limiting us only stifles our  
learning, cripples our ability to serve our communities, and overall decreases the quality of physician being  
produced and the quality of care being delivered (in my most humble opinion). These residency years are our  
formative years, and they would be better spent keeping busy and increasing exposure to our hospital systems and  
patient populations. And this is why I am calling for a reconsideration of the loss of an invaluable moonlighting  
year. Once all national board examinations have been passed, and 1 year of supervised patient management has been  
completed with satisfaction, continuing to hold back residents does everyone a disservice. This is especially odd  
since its DO residents are given such privileges, so the amount of time training doesn't seem to be the issue. It  
appears to be a mere matter of convention -- an inequity in experience and opportunity that I hope gets overturned.  
Thank you for your time and consideration.  
~Bernard L. Hardy II, MD  
Authority Health GME  
Internal Medicine Resident (PGY-1)  
From:  
To:  
BPL-BoardSupport  
MacIntosh, Weston (LARA)  
Subject:  
FW: Bureau of Professional Licensing Public Hearing June 17, 2022 - Comment on proposed changes to  
Administrative Rule Medicine (MOAHR #2021-044 LR)  
Date:  
Friday, June 17, 2022 4:37:59 PM  
Attachments:  
image006.png  
image007.png  
image008.png  
From: Stephanie Ottenwess <SOttenwess@OttenwessLaw.com>  
Sent: Friday, June 17, 2022 4:37 PM  
To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>  
Cc: BPLHelp <BPLHelp@michigan.gov>; Stephanie Ottenwess <SOttenwess@OttenwessLaw.com>  
Subject: Re: Bureau of Professional Licensing Public Hearing June 17, 2022 - Comment on proposed  
changes to Administrative Rule Medicine (MOAHR #2021-044 LR)  
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
Please consider the following comment-  
The proposed revisions to the Medicine General Rules include a revision to R 338.2431(3) by  
changing the three (3) attempt limitation to pass any part of the USMLE to four (4) attempts to  
follow the four (4) attempt policy that the Federation of State Medical Boards allows on the USMLE.  
The USMLE Composite Committee, the governing body of USMLE, set the limit at four (4) attempts  
to protect the integrity of the USMLE. Specifically, the Committee relied on information showing that  
individuals with no more than four (4) attempts to pass the USMLE Steps are more likely than those  
to require more than four (4) attempts to complete the examination sequence successfully, gain  
access to postgraduate training and ultimately receive a license to practice medicine in the United  
States.  
In addition, the Committee set the attempt limit at four (4) to more closely match the USMLE  
attempt limits imposed by the majority of state medical boards.  
The Michigan rule should follow the policy of the Federation of State Medical Boards for these same  
reasons. Allowing up to four (4) attempts would not compromise the purpose or integrity of the  
USMLE. The majority of states have recognized this fact. Moreover, if this change is not made, the  
practical impact is that individuals who are deemed qualified by the Federation of State Medical  
Boards to complete the examination sequence successfully and move on to postgraduate training  
would be precluded from obtaining a medical license in Michigan. Thus, MIchigan would lose out on  
physicians who are deemed qualified for licensure by the Federation and the majority of other  
states.  
Thank you  
Stephanie P. Ottenwess | Ottenwess Law, PLC  
Managing Partner  
3000 Town Center, Ste. 2500 | Southfield, MI 48075 | P 313.965.2121 | F 313.965.7680 | D  
313.788.7022  
sottenwess@ottenwesslaw.com | www.ottenwesslaw.com  
Sent from my iPhone  
On Jun 17, 2022, at 6:47 AM, BPL-BoardSupport <BPL-BoardSupport@michigan.gov>  
wrote:  
I’m sorry, but the Public Hearing is in person without an option for remote  
attendance. If you wish to make a comment, please submit it via email to this  
email address by 5:00 p.m. today to be considered.  
Thank you,  
Stephanie Wysack  
Departmental Technician  
Boards and Committees Section  
Bureau of Professional Licensing  
Michigan Department of Licensing and Regulatory Affairs  
Phone: 517-241-7500  
Email: BPL-BoardSupport@michigan.gov  
Confidentiality Notice: This State of Michigan message, including any attachments, is intended solely  
for the use of the named recipient(s) and may contain confidential and/or privileged information. Any  
unauthorized review, use, disclosure or distribution of any confidential and/or privileged information  
contained in this email is expressly prohibited. If you are not the intended recipient, please contact the  
sender by reply email and destroy any and all copies of the original message.  
From: Stephanie Ottenwess <SOttenwess@OttenwessLaw.com>  
Sent: Thursday, June 16, 2022 4:53 PM  
To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>; BPLHelp  
<BPLHelp@michigan.gov>  
Cc: Stephanie Ottenwess <SOttenwess@OttenwessLaw.com>  
Subject: Bureau of Professional Licensing Public Hearing June 17, 2022  
CAUTION: This is an External email. Please send suspicious emails to  
abuse@michigan.gov  
Hello –  
Is there a link to join by web or a phone number to call into the public hearing being  
held by the Dept of Licensing and Regulatory Affairs on June 17, 2022 at 9:00?  
Thank you!  
Stephanie p. OttenweSS | Ottenwess Law, PLC  
Managing Partner  
3000 Town Center, Suite 2500 | Southfield, MI 48075 | P 313.965.2121 | F  
313.965.7680 | D 313.788.7022  
sottenwess@ottenwesslaw.com | www.ottenwesslaw.com  
This electronic message and all contents contain information from the law firm of  
Ottenwess Law, PLC which may be privileged, confidential or otherwise protected from  
disclosure. The information is intended to be for the addressee only. If you are not the  
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prohibited. If you have received this electronic message in error, please notify us  
immediately and destroy the original message and all copies.  
From:  
To:  
Subject:  
Date:  
BPL-BoardSupport  
MacIntosh, Weston (LARA)  
FW: changes to MD PGY2s licensure  
Friday, June 17, 2022 1:36:00 PM  
Hi Wes,  
Does this go to you?  
Thank you,  
LeAnn Payne  
Departmental Technician  
Boards and Committees Section  
Bureau of Professional Licensing  
Michigan Department of Licensing and Regulatory Affairs  
Phone: 517-342-4808  
Email: BPL-BoardSupport@michigan.gov  
-----Original Message-----  
From: Felicia Randolph <feliciarandolph@mac.com>  
Sent: Friday, June 17, 2022 12:45 PM  
To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>  
Subject: changes to MD PGY2s licensure  
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
Dear Board Members,  
I write to provide support to the proposed changes that would allow MD residents full licensure and moonlighting  
capabilities equivalent to DO residents.  
Respectfully,  
Felicia Randolph, MD  
Associate Program Director  
Authorithy Health-IM  
Sent from my iPhone  
From:  
BPL-BoardSupport  
To:  
MacIntosh, Weston (LARA)  
Subject:  
Date:  
FW: Public Hearing Comments - Administrative Rules for Medicine - General Rules  
Monday, May 23, 2022 11:28:56 AM  
Attachments:  
Moonlighting Appeal Letter.docx  
image002.png  
This is the gentleman that spoke during public comment at the medicine meeting last week.  
Thank you,  
Stephanie Wysack  
Departmental Technician  
Boards and Committees Section  
Bureau of Professional Licensing  
Michigan Department of Licensing and Regulatory Affairs  
Phone: 517-282-9332  
Email: BPL-BoardSupport@michigan.gov  
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From: Christopher Salazar-Fields <csalazar-fields-gme@authorityhealth.org>  
Sent: Monday, May 23, 2022 11:18 AM  
To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>  
Cc: jappel@med.wayne.edu; 'Felicia Randolph' <feliciarandolph@mac.com>; BPLHelp  
<BPLHelp@michigan.gov>; Ernie Yoder <eyoder-gme@authorityhealth.org>  
Subject: Public Hearing Comments - Administrative Rules for Medicine - General Rules  
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
To the Michigan Board of Medicine,  
My name is Chris Salazar-Fields, MD and I am a first year internal medicine resident in the  
Authority Health GME Consortium. I am writing to you to address a disparity that exist  
between Allopathic and Osteopathic medical trainees.  
In 2020, the ACGME GME MD-DO merger took place which according the ACGME website  
states the following:  
Benefits of Single GME  
The ACGME, Association of American Colleges of Osteopathic Medicine (AACOM), and  
American Osteopathic Association (AOA) are in the process of implementing a single GME  
accreditation system by the year 2020 in order to:  
Provide high-quality uniform graduate medical education accreditation that enhances  
opportunities for residents/fellows and provides transparency to the federal government, licensing  
boards, US and international credentialing committees, and most importantly the public.  
Increase collaboration among the medical education community to address the challenges facing  
graduate medical education for the benefit of all medical residents and fellows, and for the benefit  
of their patients.  
Reduce costs and increase efficiencies by eliminating duplicative accreditation costs and reporting.  
Eliminate need for programs to choose either an allopathic (MD) or osteopathic (DO) accreditation  
pathway, or face undue burden to be dually accredited by the ACGME and AOA.  
Provide consistency across all residency/fellowship programs in evaluation methods and  
accountability standards, using specialty-specific Milestones for assessing the competency of  
residents/fellows graduating from all US graduate medical education programs.  
Offer all US medical school graduates a uniform graduate medical education pathway, allowing  
them to seek admission into any residency and fellowship program.  
Preserve and protect osteopathic medical education in essential dimensions of the osteopathic  
tradition, including through AOA board certification, accreditation of colleges of osteopathic  
medicine, and osteopathic licensing examinations.  
Increase opportunities for osteopathic graduate medical education and recognition for all  
ACGME-accredited programs. Provide education in Osteopathic Principles and Practice to all  
allopathic (MD) and osteopathic (DO) medical school graduates; programs can receive designation  
for their osteopathic curricula through ACGME Osteopathic Recognition.  
(https://www.acgme.org/What-We-Do/Accreditation/Single-GME-Accreditation-System/Benefits-  
of-Single-GME)  
I believe the intentions of the merger was to bring consistency and equality to both the MD and DO GME  
programs. I myself am training currently in a program that was traditionally a DO program as an MD.  
However, as a resident physician when it comes to experience and financial opportunities such as  
Moonlighting, all residents are not equal as Michigan MD licensure requires 2 years of post graduate  
medical training, compared to Michigan DO licensure which only requires 1 year of post graduated training  
as stated in R 338.123 and R 338.2423, which are listed below. This creates situations where residents who  
start at the same time, in the same residency program, receiving the same training and didactics, will be  
deemed competent to receive full licensure on identical metrics except the 2 initials following their name  
recognizing them as a Doctor of Medicine or Osteopathy. This creates a division of classism where MDs  
have less privileges and opportunities compared to their DO peers.  
I am asking the Board of Medicine to consider revision to R 338.2423 to reflect the following:  
R 338.2423 (d) Have completed Provide proof verifying completion of a minimum of 2 years 1 year of  
postgraduate clinical training in a program that satisfies the requirements of under R 338.2421(2), (3), (4),  
or (5). or (4).  
I believe this would bring equality and fairness to MD resident physicians wishing to obtain their full  
licensure after satisfying the same requirements that DO resident physicians are held to, and recognize MD  
residents as equally competent to their DO peers after completing the same length of training, which is also  
consistent with the stated purpose of the 2020 ACGME MD-DO merger. Additionally, this would also make  
Michigan residents equal to their colleagues across sates lines as the states of Illinois, Indiana, and Ohio also  
only require 1 year of post graduate training to be eligible to apply for full licensure, supporting  
documentation listed below.  
For these reasons, I hope the Board of Medicine considers this revision.  
(SUPPORTING DOCUMENTATION BELOW)  
STATE OF MICHIGAN  
R 338.123 Licensure by examination. (DO Licensure)  
Rule 23. An applicant for licensure by examination, in addition to satisfying the requirements of the  
code, shall satisfy all of the following requirements:  
(a) Submit the required fee and a completed application on a form provided by the department.  
(b) Possess a degree from a school of osteopathic medicine that satisfies the standards set forth in R  
338.121(1).  
(c) Have passed all parts of the Comprehensive Osteopathic Medical Licensing Examination  
(COMLEX) adopted under R 338.129.  
(d) Have completed a minimum of 1 year of postgraduate clinical training in a program that satisfies  
either of the following requirements:  
(i) A postgraduate training program that satisfies the requirements of R 338.121(2) at a training  
institution that satisfies the requirements of R 338.121(3).  
(ii) A postgraduate training program approved by the board in R 338.121(4).  
(e) Submit a certificate of completion of the postgraduate training required under subdivision (d) of  
this rule to the department no more than 15 days before the scheduled date of completion.  
R 338.2423 Medical doctor; license requirements; United States and Canadian graduates.  
Rule 123. An applicant for a medical license who graduated from a medical school located inside the  
United States, its territories, or the Dominion of Canada, in addition to satisfying the requirements of  
the code, shall satisfy all of the following requirements:  
(a) Submit the required fee and a completed application on a form provided by the department.  
(b) Possess a degree from a medical school that satisfies the standards set forth in R 338.2421(1).  
(c) Have passed all parts of the United States Medical Licensing Examination (USMLE) adopted under  
R 338.2431.  
(d) Have completed a minimum of 2 years of postgraduate clinical training in a program that satisfies  
the requirements of R 338.2421(2), (3), (4), or (5).  
(e) Submit a certificate of completion of the postgraduate training required under subdivision (d) of  
this rule to the department no more than 15 days prior to the scheduled date of completion.  
STATE OF ILLINOIS  
Section 1285.70 Application for a License on the Basis of Examination  
a)  
Each applicant for a license to practice medicine in all of its branches on the basis of  
examination must submit to the Division:  
1)  
A fully completed application signed by the applicant, on which all questions have been  
answered and all programs of medical education attended by the applicant have been  
identified, including dates of attendance;  
2)  
Proof that the applicant is of good moral character. Proof shall be an indication on the  
application that the applicant has not engaged in any conduct or activities that would  
constitute grounds for discipline under Section 22 of the Act. Applications of individuals who  
answer affirmatively to any question on the personal history portion of the application or who  
have engaged in activities that would constitute grounds for discipline shall be forwarded to  
the Enforcement Division of the Division of Professional Regulation for further investigation  
and action by the Medical Licensing Board as provided in Section 9(B)(4) of the Act;  
3)  
An official transcript of a course of instruction in a college, university or other  
institution as required by Section 1285.20(a);  
4)  
5)  
Fee as required by Section 21 of the Act;  
An official transcript and diploma or an official transcript and certification of graduation  
from the medical education program granting the degree that shall be evidence that the  
applicant has met the minimum medical education requirements of the Act;  
6)  
Certification on forms provided by the Division that the core clerkship rotations were  
completed in accordance with Section 1285.20 and proof of current ECFMG certification as set  
forth in Section 1285.20(k) for those applicants who are applying under Section 11(A)(2)(a) of  
the Act;  
7)  
Proof of satisfactory completion of an approved program of clinical training in  
accordance with Section 1285.40;  
8) Proof of the successful completion of the examination set forth in Section 1285.60.  
Scores shall be submitted to the Division directly from the testing entity;  
9)  
A)  
B)  
A certification from the jurisdiction of original licensure and current licensure stating:  
The date of issuance of the license; and  
Whether the records of the licensing authority contain any record of disciplinary action  
taken or pending;  
10)  
Documentation of professional capacity, as set forth in Section 1285.95, for applicants  
who have not been engaged in the active practice of medicine or have not been enrolled in a  
medical program for 2 years prior to application; and  
11)  
Verification of fingerprint processing from the Illinois Department of State Police (ISP),  
an ISP live scan vendor whose equipment has been certified by ISP, or a fingerprint vendor  
agency licensed by the Division. Out-of-state residents unable to utilize the ISP electronic  
fingerprint process may submit to ISP one fingerprint card issued by ISP, accompanied by the  
fee specified by ISP. Fingerprints shall be taken within the 60 days prior to application.  
Section 1285.95 Professional Capacity Standards for Applicants Having Graduated More  
Than 2 Years Prior to Application  
Pursuant to Section 9(B)(4) of the Act, in determining professional capacity for individuals who  
have not been actively engaged in the practice of medicine or as a medical, osteopathic, or  
chiropractic student or who have not been engaged in a formal program of medical education  
during the 2 years immediately preceding application, the individual may be required to  
complete such additional testing, training, or remedial education as the Licensing Board may  
deem necessary to establish the applicant's present capacity to practice medicine with  
reasonable judgment, skill and safety. In determining professional capacity, the Board shall  
consider, but not be limited to, the following activities:  
a)  
Medical research that is human clinical research consistent with the requirements of  
the Federal Food and Drug Administration (21 CFR 50) (2001, no further amendments or  
additions included) and the Consumer Product Safety Commission (16 CFR 1028) (2001, no  
further amendments or additions included) or other equivalent medical research.  
b)  
Specialized training or education that is clinical training or clinical education such as, or  
equivalent to, the following:  
1)  
Clinical training that takes place in a residency training program in accordance with the  
requirements set forth in Section 1285.40 of this Part or the equivalent (e.g., residency  
training in another state or jurisdiction).  
2)  
3)  
Clinical medical practice in the National Health Service or its equivalent.  
Continuing medical education (CME) recognized by the Accreditation Council on  
Continuing Medical Education (ACCME), the American Osteopathic Association (AOA),  
American Chiropractic Association (ACA), or continuing medical education in accordance with  
Section 1285.110 of this Part.  
4)  
Post-graduate education in basic or related medical sciences in any state or  
jurisdiction.  
c)  
Publication of original work in clinical medicine published in medical or scientific  
journals that are listed by the Cumulative Index Medicas (CIM).  
d)  
Clinical research or professional clinical medical practice in public health organizations  
(e.g., World Health Organization (WHO), Malaria Prevention programs, United Nations  
International Children's Emergency Fund (UNICEF) programs, both national and  
international).  
e)  
Having been engaged in clinical research or clinical medical practice at a veterans,  
military, or other medical institution operated by the federal government.  
f) Other professional or clinical medical activities or chiropractic activities, such as, or  
equivalent to, the following:  
1)  
Presentation of papers or participation on panels as a faculty member at a program  
approved or recognized by the American Medical Association (AMA) or its affiliates, the  
American Osteopathic Association (AOA) or its affiliates, the American Chiropractic Association  
(ACA) or its affiliates, or a recognized specialty society or equivalent recognized by the medical  
community; or  
2)  
Act.  
Experience obtained as a Visiting Professor in accordance with Section 18(A) of the  
g)  
Clinical medical practice obtained in violation of the Act shall not be considered by the  
Board in determining professional capacity for the purposes of this Section.  
h)  
Each applicant for temporary licensure, in accordance with this Section, shall submit a  
certificate of acceptance form signed by the program director of an approved residency  
training program, in accordance with Section 1285.40 of this Part, attesting that the applicant  
will be accepted for specialty/residency training, if, upon the evaluation of medical education  
and clinical skills by the Division, the applicant is found to be eligible for temporary licensure.  
i)  
In determining eligibility, the Board will consider any and all documentation of activities  
submitted by the applicant.  
(Source: Amended at 29 Ill. Reg. 18823, effective November 4, 2005)  
SOUTHERN ILLINOIS UNIVERSITY SCHOOL OF MEDICINE  
Moonlighting Policy  
I. Preamble  
The term “resident” is inclusive of all trainees at SIU School of Medicine, whether training in a  
residency or fellowship program. The goals of this policy are to outline:  
the allowable parameters for moonlighting  
the steps required to apply for moonlighting approval  
Residents will accept no responsibilities for professional activities outside the scope of the  
Residency Program (including, but not limited to "moonlighting") unless approved in writing by  
the employing hospital via the Office of Graduate Medical Education (OGME) and the Program  
Director, who shall have discretion as to whether or not such outside professional activities  
are permitted. Residents must not be required to engage in “moonlighting.”  
If a program chooses to allow moonlighting, there must be an internal policy established with  
the specific parameters for the program.  
Section I: External Moonlighting  
This is defined as voluntary, compensated, medically–related work performed outside the  
training program. With regard to those residency programs in which outside professional  
activities may be permitted, the following shall apply:  
a. The professional activities must be of educational value and must not interfere with the  
ability of the resident to achieve the goals and objectives of the educational program.  
b. The professional activities must have the approval of the Program Director. The Program  
Director must acknowledge this approval in writing, and a copy of that acknowledgement  
must be included in the resident’s file.  
c. The professional activities must have approval of the employing hospital.*  
d. The professional activities must not detract from the Residency Program or interfere in any  
way with the educational experience, performance or responsibilities of the resident. If such  
moonlighting activities are approved, the Program Director must monitor the resident for the  
effect of moonlighting activities upon performance. Adverse effects may lead to withdrawal of  
permission.  
e. All time spent moonlighting must be entered into New Innovations in a timely and accurate  
manner and counted toward the 80 hour weekly limit on work hours. Moonlighting on  
vacation does not need to be recorded, however the residents must ensure they are adequately  
rested and fit to provide the services required by their patients when returning to duty.  
f. PGY-1 residents are not permitted to moonlight.  
(https://www.siumed.edu/gme/policies/moonlighting-policy)  
UNIVERSITY OF ILLINOIS COLLEGE OF MEDICINE  
Graduate Medical Education Policies and Procedures  
Policy on Moonlighting  
PURPOSE: To assure an environment which balances learning and service, and protects  
patient safety and physician well-being.  
POLICY: Moonlighting is not a requirement. Moonlighting must not interfere with resident  
progress in the program.  
Moonlighting is after hours professional care activity that is not a part of a written curriculum  
and is independent of the residency program.  
It is the responsibility of the resident to assure that licensing and liability insurance are  
appropriate for work outside the residency program. Resident moonlighting hours must be  
approved in advance and reported to the program director and when combined with residency  
duty hours may not exceed 80 hours per week.  
PGY-1 Residents are not permitted to moonlight.  
(https://www.med.illinois.edu/depts_programs/gme/policies/moonlighting.php)  
STATE OF OHIO  
Section 4731.09 | Qualifications for license to practice medicine and surgery or osteopathic  
medicine and surgery.  
Ohio Revised Code/Title 47 Occupations-Professions/Chapter 4731 Physicians; Limited  
Practitioners  
Effective:  
October 9, 2021  
Latest Legislation:  
House Bill 263 - 133rd General Assembly  
(A) An applicant for a license to practice medicine and surgery or osteopathic medicine and  
surgery must meet all of the following requirements:  
(1) Be at least eighteen years of age;  
(2) Possess a high school diploma or a certificate of high school equivalence or have obtained  
the equivalent of such education as determined by the state medical board;  
(3) Have completed two years of undergraduate work in a college of arts and sciences or the  
equivalent of such education as determined by the board;  
(4) Meet one of the following medical education and graduate medical education  
requirements:  
(a) Hold a diploma from a medical school or osteopathic medical school that, at the time the  
diploma was issued, was a medical school accredited by the liaison committee on medical  
education or an osteopathic medical school accredited by the American osteopathic  
association and have successfully completed not less than twelve months of graduate medical  
education through the first-year level of graduate medical education or its equivalent as  
determined by the board;  
(b) Hold certification from the educational commission for foreign medical graduates and have  
successfully completed not less than twenty-four months of graduate medical education  
through the second-year level of graduate medical education or its equivalent as determined by  
the board;  
(c) Be a qualified graduate of a fifth pathway training program as recognized by the board  
under section 4731.091 of the Revised Code and have successfully completed, subsequent to  
completing fifth pathway training, not less than twelve months of graduate medical education  
or its equivalent as determined by the board.  
(5) Have successfully passed an examination prescribed in rules adopted by the board to  
determine competency to practice medicine and surgery or osteopathic medicine and surgery;  
(6) Comply with section 4731.08 of the Revised Code;  
(7) Meet the requirements of section 4731.142 of the Revised Code if eligibility for the license  
applied for is based in part on certification from the educational commission for foreign  
medical graduates and the undergraduate education requirements established by this section  
were fulfilled at an institution outside of the United States.  
(B) An applicant for a license to practice medicine and surgery or osteopathic medicine and  
surgery shall submit to the board an application in the form and manner prescribed by the  
board. The application must include all of the following:  
(1) Evidence satisfactory to the board to demonstrate that the applicant meets all of the  
requirements of division (A) of this section;  
(2) An attestation that the information submitted under this section is accurate and truthful;  
(3) Consent to the release of the applicant's information;  
(4) Any other information the board requires.  
(C) An applicant for a license to practice medicine and surgery or osteopathic medicine and  
surgery shall include with the application a fee of three hundred five dollars, no part of which  
may be returned. An application is not considered submitted until the board receives the fee.  
(D) The board may conduct an investigation related to the application materials received  
pursuant to this section and may contact any individual, agency, or organization for  
recommendations or other information about the applicant.  
(E) The board shall conclude any investigation of an applicant conducted under  
section 4731.22 of the Revised Code not later than ninety days after receipt of a complete  
application unless the applicant agrees in writing to an extension or the board determines that  
there is a substantial question of a violation of this chapter or the rules adopted under it and  
notifies the applicant in writing of the reasons for continuation of the investigation. If the  
board determines that the applicant is not in violation of this chapter or the rules adopted under  
it, the board shall issue a license not later than forty-five days after making that  
determination.  
THE STATE OF INDIANA  
Physician/Osteopathic Physician  
Application for licensure as a physician/osteopathic physician  
Application Instructions/Checklist - IMPORTANT!  
We ask that you please allow up to two weeks from the submission of an application for  
review by our staff. You will be notified via mail or email if there are any missing documents  
or issues with your application. You may also check the status of your application by  
clicking here. If you have not received a status update after two weeks, you may email us at  
pla3@pla.in.gov.  
General Information  
To be eligible for a Physician or Osteopathic Physician license, applicants must have received  
all of their medical school education from and graduated from a medical school recognized or  
approved by the Medical Licensing Board. Prior to submitting an application, please refer to  
the following links to verify that your medical school or training location is recognized or  
approved:  
Approved/Disapproved Foreign Medical Schools  
Approved Allopathic U.S./Canadian Medical Schools  
Approved Osteopathic U.S. Medical Schools  
Approved ACGME-accredited postgraduate training programs  
Approved AOA-accredited postgraduate training programs  
Approved Royal College of Physicians and Surgeons of Canada postgraduate training  
programs  
If you did not attend or graduate from a recognized or approved medical school or  
postgraduate training program, you may still an submit an application for licensure and request  
a waiver in writing. Waiver requests are reviewed on a case-by-case basis, and may require a  
personal appearance before the Medical Licensing Board. In determining whether to grant a  
waiver, the Medical Licensing Board will consider an applicant's training, experience, and  
credentials.  
General Questions about Licensure  
How Long Does it Take to Get a License?  
Questions Regarding Examinations  
Questions Regarding Criminal Background Checks  
Questions about Criminal Convictions  
Questions Regarding Recognized Medical Schools  
Questions about Translations of Documents  
Helpful Links  
General Questions about Licensure  
Q. How much training must I complete before I am eligible for licensure?  
A. U.S./Canadian graduates must complete 12 months of approved postgraduate training in the  
U.S. or Canada. An International Medical Graduate must complete 24 months of approved  
postgraduate training in the U.S. or Canada.  
Q. Should I report incomplete postgraduate training on the application?  
A. Yes. You are required to document all postgraduate training (internship, residency,  
fellowship) on the application, whether or not the program was completed or credit was  
granted. You must have each postgraduate training program verify your dates of training for  
each program.  
Q. What are the costs related to licensure?  
A. The fee for the application is $250. If you also require a controlled substances registration,  
that application fee is $60. All fees should be paid my cash, check or money order and  
submitted with your application. Checks and money orders should be made payable to the  
Indiana Professional Licensing Agency. We do not accept credit card payments.  
Q. When should I apply for licensure?  
A. Since a U.S./Canadian medical school graduate is not eligible for licensure until one year of  
training has been completed, you should not submit your application until after six months of  
training have been completed.  
Further, documentation relating to your application can be submitted at any time; you do not  
need to wait until your application has been submitted. The Board will retain documents for 6  
months.  
Q. Should I take Step 3 before I apply for licensure?  
A. You are not required to take and pass the USMLE Step 3/COMLEX Step 3 before you  
apply; however, a license will not be issued to any applicant until they have passed all three  
steps. In Indiana, you must pass all three steps of the USMLE within 10 years, with a  
maximum attempt of three times per step. For osteopathic physicians, all three steps must be  
passed within 7 years, with a maximum attempt of fives times per step.  
Applicants who fail to pass all the steps within the required timeframe or within the maximum  
number of attempts may stil apply for licensure and request a waiver. Waiver requests are  
reviewed on a case-by-case basis, and may require a personal appearance before the Medical  
Licensing Board. In determining whether to grant a waiver, the Medical Licensing Board will  
consider an applicant's training, experience, and credentials. Additional conditions, such as  
agreeing to work in an underserved area, may be required if a waiver is granted.  
Q. How long is my license valid?  
A. Upon issuance of your license, your license will remain valid through October 31 of each  
odd year.  
(https://www.in.gov/pla/professions/medical-licensing-board-of-indiana/physicianosteopathic-  
physician/)  
Best regards,  
Chris Salazar-Fields, MD  
Internal Medicine Resident  
Authority Health  
3031 W. Grand Blvd., Suite 600  
Detroit, MI 48201  
To the Michigan Board of Medicine,  
My name is Chris Salazar-Fields, MD and I am a first year internal medicine resident in the Authority  
Health GME Consortium. I am writing to you to address a disparity that exist between Allopathic and  
Osteopathic medical trainees.  
In 2020, the ACGME GME MD-DO merger took place which according the ACGME website states the  
following:  
Benefits of Single GME  
The ACGME, Association of American Colleges of Osteopathic Medicine (AACOM), and American  
Osteopathic Association (AOA) are in the process of implementing a single GME accreditation system by  
the year 2020 in order to:  
•
Provide high-quality uniform graduate medical education accreditation that enhances  
opportunities for residents/fellows and provides transparency to the federal government, licensing  
boards, US and international credentialing committees, and most importantly the public.  
Increase collaboration among the medical education community to address the challenges facing  
graduate medical education for the benefit of all medical residents and fellows, and for the benefit  
of their patients.  
•
•
•
Reduce costs and increase efficiencies by eliminating duplicative accreditation costs and reporting.  
Eliminate need for programs to choose either an allopathic (MD) or osteopathic (DO) accreditation  
pathway, or face undue burden to be dually accredited by the ACGME and AOA.  
Provide consistency across all residency/fellowship programs in evaluation methods and  
accountability standards, using specialty-specific Milestones for assessing the competency of  
residents/fellows graduating from all US graduate medical education programs.  
Offer all US medical school graduates a uniform graduate medical education pathway, allowing  
them to seek admission into any residency and fellowship program.  
•
•
•
Preserve and protect osteopathic medical education in essential dimensions of the osteopathic  
tradition, including through AOA board certification, accreditation of colleges of osteopathic  
medicine, and osteopathic licensing examinations.  
•
Increase opportunities for osteopathic graduate medical education and recognition for all ACGME-  
accredited programs. Provide education in Osteopathic Principles and Practice to all allopathic (MD)  
and osteopathic (DO) medical school graduates; programs can receive designation for their  
osteopathic curricula through ACGME Osteopathic Recognition.  
(https://www.acgme.org/What-We-Do/Accreditation/Single-GME-Accreditation-System/Benefits-of-  
Single-GME)  
I believe the intentions of the merger was to bring consistency and equality to both the MD and DO GME  
programs. I myself am training currently in a program that was traditionally a DO program as an MD.  
However, as a resident physician when it comes to experience and financial opportunities such as  
Moonlighting, all residents are not equal as Michigan MD licensure requires 2 years of post graduate  
medical training, compared to Michigan DO licensure which only requires 1 year of post graduated  
training as stated in R 338.123 and R 338.2423, which are listed below. This creates situations where  
residents who start at the same time, in the same residency program, receiving the same training and  
didactics, will be deemed competent to receive full licensure on identical metrics except the 2 initials  
following their name recognizing them as a Doctor of Medicine or Osteopathy. This creates a division of  
classism where MDs have less privileges and opportunities compared to their DO peers.  
I am asking the Board of Medicine to consider revision to R 338.2423 to reflect the following:  
R 338.2423 (d) Have completed Provide proof verifying completion of a minimum of 2 years 1 year of  
postgraduate clinical training in a program that satisfies the requirements of under R 338.2421(2),  
(3), (4), or (5). or (4).  
I believe this would bring equality and fairness to MD resident physicians wishing to obtain their full  
licensure after satisfying the same requirements that DO resident physicians are held to, and recognize  
MD residents as equally competent to their DO peers after completing the same length of training, which  
is also consistent with the stated purpose of the 2020 ACGME MD-DO merger. Additionally, this would  
also make Michigan residents equal to their colleagues across sates lines as the states of Illinois, Indiana,  
and Ohio also only require 1 year of post graduate training to be eligible to apply for full licensure,  
supporting documentation listed below.  
For these reasons, I hope the Board of Medicine considers this revision.  
(SUPPORTING DOCUMENTATION BELOW)  
STATE OF MICHIGAN  
R 338.123 Licensure by examination. (DO Licensure)  
Rule 23. An applicant for licensure by examination, in addition to satisfying the requirements of the  
code, shall satisfy all of the following requirements:  
(a) Submit the required fee and a completed application on a form provided by the department.  
(b) Possess a degree from a school of osteopathic medicine that satisfies the standards set forth in R  
338.121(1).  
(c) Have passed all parts of the Comprehensive Osteopathic Medical Licensing Examination  
(COMLEX) adopted under R 338.129.  
(d) Have completed a minimum of 1 year of postgraduate clinical training in a program that satisfies  
either of the following requirements:  
(i) A postgraduate training program that satisfies the requirements of R 338.121(2) at a training  
institution that satisfies the requirements of R 338.121(3).  
(ii) A postgraduate training program approved by the board in R 338.121(4).  
(e) Submit a certificate of completion of the postgraduate training required under subdivision (d) of  
this rule to the department no more than 15 days before the scheduled date of completion.  
R 338.2423 Medical doctor; license requirements; United States and Canadian graduates.  
Rule 123. An applicant for a medical license who graduated from a medical school located inside the  
United States, its territories, or the Dominion of Canada, in addition to satisfying the requirements  
of the code, shall satisfy all of the following requirements:  
(a) Submit the required fee and a completed application on a form provided by the department.  
(b) Possess a degree from a medical school that satisfies the standards set forth in R 338.2421(1).  
(c) Have passed all parts of the United States Medical Licensing Examination (USMLE) adopted  
under R 338.2431.  
(d) Have completed a minimum of 2 years of postgraduate clinical training in a program that  
satisfies the requirements of R 338.2421(2), (3), (4), or (5).  
(e) Submit a certificate of completion of the postgraduate training required under subdivision (d) of  
this rule to the department no more than 15 days prior to the scheduled date of completion.  
STATE OF ILLINOIS  
Section 1285.70 Application for a License on the Basis of Examination  
a)  
Each applicant for a license to practice medicine in all of its branches on the basis of examination  
must submit to the Division:  
1) A fully completed application signed by the applicant, on which all questions have been answered  
and all programs of medical education attended by the applicant have been identified, including dates of  
attendance;  
2)  
Proof that the applicant is of good moral character. Proof shall be an indication on the  
application that the applicant has not engaged in any conduct or activities that would constitute grounds  
for discipline under Section 22 of the Act. Applications of individuals who answer affirmatively to any  
question on the personal history portion of the application or who have engaged in activities that would  
constitute grounds for discipline shall be forwarded to the Enforcement Division of the Division of  
Professional Regulation for further investigation and action by the Medical Licensing Board as provided  
in Section 9(B)(4) of the Act;  
3)  
An official transcript of a course of instruction in a college, university or other institution as  
required by Section 1285.20(a);  
4)  
5)  
Fee as required by Section 21 of the Act;  
An official transcript and diploma or an official transcript and certification of graduation from the  
medical education program granting the degree that shall be evidence that the applicant has met the  
minimum medical education requirements of the Act;  
6)  
Certification on forms provided by the Division that the core clerkship rotations were completed  
in accordance with Section 1285.20 and proof of current ECFMG certification as set forth in Section  
1285.20(k) for those applicants who are applying under Section 11(A)(2)(a) of the Act;  
7)  
Proof of satisfactory completion of an approved program of clinical training in accordance with  
Section 1285.40;  
8)  
Proof of the successful completion of the examination set forth in Section 1285.60. Scores shall  
be submitted to the Division directly from the testing entity;  
9)  
A)  
A certification from the jurisdiction of original licensure and current licensure stating:  
The date of issuance of the license; and  
B)  
Whether the records of the licensing authority contain any record of disciplinary action taken or  
pending;  
10)  
Documentation of professional capacity, as set forth in Section 1285.95, for applicants who have  
not been engaged in the active practice of medicine or have not been enrolled in a medical program for  
2 years prior to application; and  
11)  
Verification of fingerprint processing from the Illinois Department of State Police (ISP), an ISP live  
scan vendor whose equipment has been certified by ISP, or a fingerprint vendor agency licensed by the  
Division. Out-of-state residents unable to utilize the ISP electronic fingerprint process may submit to ISP  
one fingerprint card issued by ISP, accompanied by the fee specified by ISP. Fingerprints shall be taken  
within the 60 days prior to application.  
Section 1285.95 Professional Capacity Standards for Applicants Having Graduated More Than 2 Years  
Prior to Application  
Pursuant to Section 9(B)(4) of the Act, in determining professional capacity for individuals who have not  
been actively engaged in the practice of medicine or as a medical, osteopathic, or chiropractic student  
or who have not been engaged in a formal program of medical education during the 2 years  
immediately preceding application, the individual may be required to complete such additional testing,  
training, or remedial education as the Licensing Board may deem necessary to establish the applicant's  
present capacity to practice medicine with reasonable judgment, skill and safety. In determining  
professional capacity, the Board shall consider, but not be limited to, the following activities:  
a)  
Medical research that is human clinical research consistent with the requirements of the Federal  
Food and Drug Administration (21 CFR 50) (2001, no further amendments or additions included) and the  
Consumer Product Safety Commission (16 CFR 1028) (2001, no further amendments or additions  
included) or other equivalent medical research.  
b)  
Specialized training or education that is clinical training or clinical education such as, or  
equivalent to, the following:  
1) Clinical training that takes place in a residency training program in accordance with the  
requirements set forth in Section 1285.40 of this Part or the equivalent (e.g., residency training in  
another state or jurisdiction).  
2)  
3)  
Clinical medical practice in the National Health Service or its equivalent.  
Continuing medical education (CME) recognized by the Accreditation Council on Continuing  
Medical Education (ACCME), the American Osteopathic Association (AOA), American Chiropractic  
Association (ACA), or continuing medical education in accordance with Section 1285.110 of this Part.  
4)  
c)  
Post-graduate education in basic or related medical sciences in any state or jurisdiction.  
Publication of original work in clinical medicine published in medical or scientific journals that are  
listed by the Cumulative Index Medicas (CIM).  
d) Clinical research or professional clinical medical practice in public health organizations (e.g.,  
World Health Organization (WHO), Malaria Prevention programs, United Nations International  
Children's Emergency Fund (UNICEF) programs, both national and international).  
e)  
Having been engaged in clinical research or clinical medical practice at a veterans, military, or  
other medical institution operated by the federal government.  
f) Other professional or clinical medical activities or chiropractic activities, such as, or equivalent to,  
the following:  
1)  
Presentation of papers or participation on panels as a faculty member at a program approved or  
recognized by the American Medical Association (AMA) or its affiliates, the American Osteopathic  
Association (AOA) or its affiliates, the American Chiropractic Association (ACA) or its affiliates, or a  
recognized specialty society or equivalent recognized by the medical community; or  
2)  
Experience obtained as a Visiting Professor in accordance with Section 18(A) of the Act.  
g)  
Clinical medical practice obtained in violation of the Act shall not be considered by the Board in  
determining professional capacity for the purposes of this Section.  
h) Each applicant for temporary licensure, in accordance with this Section, shall submit a certificate  
of acceptance form signed by the program director of an approved residency training program, in  
accordance with Section 1285.40 of this Part, attesting that the applicant will be accepted for  
specialty/residency training, if, upon the evaluation of medical education and clinical skills by the  
Division, the applicant is found to be eligible for temporary licensure.  
i)  
In determining eligibility, the Board will consider any and all documentation of activities  
submitted by the applicant.  
(Source: Amended at 29 Ill. Reg. 18823, effective November 4, 2005)  
SOUTHERN ILLINOIS UNIVERSITY SCHOOL OF MEDICINE  
Moonlighting Policy  
I. Preamble  
The term “resident” is inclusive of all trainees at SIU School of Medicine, whether training in a residency  
or fellowship program. The goals of this policy are to outline:  
•
•
the allowable parameters for moonlighting  
the steps required to apply for moonlighting approval  
Residents will accept no responsibilities for professional activities outside the scope of the Residency  
Program (including, but not limited to "moonlighting") unless approved in writing by the employing  
hospital via the Office of Graduate Medical Education (OGME) and the Program Director, who shall have  
discretion as to whether or not such outside professional activities are permitted. Residents must not be  
required to engage in “moonlighting.”  
If a program chooses to allow moonlighting, there must be an internal policy established with the  
specific parameters for the program.  
Section I: External Moonlighting  
This is defined as voluntary, compensated, medically–related work performed outside the training  
program. With regard to those residency programs in which outside professional activities may be  
permitted, the following shall apply:  
a. The professional activities must be of educational value and must not interfere with the ability of the  
resident to achieve the goals and objectives of the educational program.  
b. The professional activities must have the approval of the Program Director. The Program Director  
must acknowledge this approval in writing, and a copy of that acknowledgement must be included in the  
resident’s file.  
c. The professional activities must have approval of the employing hospital.*  
d. The professional activities must not detract from the Residency Program or interfere in any way with  
the educational experience, performance or responsibilities of the resident. If such moonlighting  
activities are approved, the Program Director must monitor the resident for the effect of moonlighting  
activities upon performance. Adverse effects may lead to withdrawal of permission.  
e. All time spent moonlighting must be entered into New Innovations in a timely and accurate manner  
and counted toward the 80 hour weekly limit on work hours. Moonlighting on vacation does not need to  
be recorded, however the residents must ensure they are adequately rested and fit to provide the  
services required by their patients when returning to duty.  
f. PGY-1 residents are not permitted to moonlight.  
(https://www.siumed.edu/gme/policies/moonlighting-policy)  
UNIVERSITY OF ILLINOIS COLLEGE OF MEDICINE  
Graduate Medical Education Policies and Procedures  
Policy on Moonlighting  
PURPOSE: To assure an environment which balances learning and service, and protects patient safety  
and physician well-being.  
POLICY: Moonlighting is not a requirement. Moonlighting must not interfere with resident progress in  
the program.  
Moonlighting is after hours professional care activity that is not a part of a written curriculum and is  
independent of the residency program.  
It is the responsibility of the resident to assure that licensing and liability insurance are appropriate for  
work outside the residency program. Resident moonlighting hours must be approved in advance and  
reported to the program director and when combined with residency duty hours may not exceed 80  
hours per week.  
PGY-1 Residents are not permitted to moonlight.  
(https://www.med.illinois.edu/depts_programs/gme/policies/moonlighting.php)  
STATE OF OHIO  
Section 4731.09 | Qualifications for license to practice medicine and surgery or osteopathic medicine  
and surgery.  
Ohio Revised Code/Title 47 Occupations-Professions/Chapter 4731 Physicians; Limited Practitioners  
Effective:  
October 9, 2021  
Latest Legislation:  
House Bill 263 - 133rd General Assembly  
(A) An applicant for a license to practice medicine and surgery or osteopathic medicine and surgery must  
meet all of the following requirements:  
(1) Be at least eighteen years of age;  
(2) Possess a high school diploma or a certificate of high school equivalence or have obtained the  
equivalent of such education as determined by the state medical board;  
(3) Have completed two years of undergraduate work in a college of arts and sciences or the equivalent  
of such education as determined by the board;  
(4) Meet one of the following medical education and graduate medical education requirements:  
(a) Hold a diploma from a medical school or osteopathic medical school that, at the time the diploma  
was issued, was a medical school accredited by the liaison committee on medical education or an  
osteopathic medical school accredited by the American osteopathic association and have successfully  
completed not less than twelve months of graduate medical education through the first-year level of  
graduate medical education or its equivalent as determined by the board;  
(b) Hold certification from the educational commission for foreign medical graduates and have  
successfully completed not less than twenty-four months of graduate medical education through the  
second-year level of graduate medical education or its equivalent as determined by the board;  
(c) Be a qualified graduate of a fifth pathway training program as recognized by the board under  
section 4731.091 of the Revised Code and have successfully completed, subsequent to completing fifth  
pathway training, not less than twelve months of graduate medical education or its equivalent as  
determined by the board.  
(5) Have successfully passed an examination prescribed in rules adopted by the board to determine  
competency to practice medicine and surgery or osteopathic medicine and surgery;  
(6) Comply with section 4731.08 of the Revised Code;  
(7) Meet the requirements of section 4731.142 of the Revised Code if eligibility for the license applied  
for is based in part on certification from the educational commission for foreign medical graduates and  
the undergraduate education requirements established by this section were fulfilled at an institution  
outside of the United States.  
(B) An applicant for a license to practice medicine and surgery or osteopathic medicine and surgery shall  
submit to the board an application in the form and manner prescribed by the board. The application  
must include all of the following:  
(1) Evidence satisfactory to the board to demonstrate that the applicant meets all of the requirements  
of division (A) of this section;  
(2) An attestation that the information submitted under this section is accurate and truthful;  
(3) Consent to the release of the applicant's information;  
(4) Any other information the board requires.  
(C) An applicant for a license to practice medicine and surgery or osteopathic medicine and surgery shall  
include with the application a fee of three hundred five dollars, no part of which may be returned. An  
application is not considered submitted until the board receives the fee.  
(D) The board may conduct an investigation related to the application materials received pursuant to  
this section and may contact any individual, agency, or organization for recommendations or other  
information about the applicant.  
(E) The board shall conclude any investigation of an applicant conducted under section 4731.22 of the  
Revised Code not later than ninety days after receipt of a complete application unless the applicant  
agrees in writing to an extension or the board determines that there is a substantial question of a  
violation of this chapter or the rules adopted under it and notifies the applicant in writing of the reasons  
for continuation of the investigation. If the board determines that the applicant is not in violation of this  
chapter or the rules adopted under it, the board shall issue a license not later than forty-five days after  
making that determination.  
THE STATE OF INDIANA  
Physician/Osteopathic Physician  
Application for licensure as a physician/osteopathic physician  
Application Instructions/Checklist - IMPORTANT!  
We ask that you please allow up to two weeks from the submission of an application for review by our  
staff. You will be notified via mail or email if there are any missing documents or issues with your  
application. You may also check the status of your application by clicking here. If you have not received  
a status update after two weeks, you may email us at pla3@pla.in.gov.  
General Information  
To be eligible for a Physician or Osteopathic Physician license, applicants must have received all of their  
medical school education from and graduated from a medical school recognized or approved by the  
Medical Licensing Board. Prior to submitting an application, please refer to the following links to verify  
that your medical school or training location is recognized or approved:  
•
•
•
•
•
•
Approved/Disapproved Foreign Medical Schools  
Approved Allopathic U.S./Canadian Medical Schools  
Approved Osteopathic U.S. Medical Schools  
Approved ACGME-accredited postgraduate training programs  
Approved AOA-accredited postgraduate training programs  
Approved Royal College of Physicians and Surgeons of Canada postgraduate training programs  
If you did not attend or graduate from a recognized or approved medical school or postgraduate training  
program, you may still an submit an application for licensure and request a waiver in writing. Waiver  
requests are reviewed on a case-by-case basis, and may require a personal appearance before the  
Medical Licensing Board. In determining whether to grant a waiver, the Medical Licensing Board will  
consider an applicant's training, experience, and credentials.  
General Questions about Licensure  
How Long Does it Take to Get a License?  
Questions Regarding Examinations  
Questions Regarding Criminal Background Checks  
Questions about Criminal Convictions  
Questions Regarding Recognized Medical Schools  
Questions about Translations of Documents  
Helpful Links  
General Questions about Licensure  
Q. How much training must I complete before I am eligible for licensure?  
A. U.S./Canadian graduates must complete 12 months of approved postgraduate training in the U.S. or  
Canada. An International Medical Graduate must complete 24 months of approved postgraduate  
training in the U.S. or Canada.  
Q. Should I report incomplete postgraduate training on the application?  
A. Yes. You are required to document all postgraduate training (internship, residency, fellowship) on the  
application, whether or not the program was completed or credit was granted. You must have each  
postgraduate training program verify your dates of training for each program.  
Q. What are the costs related to licensure?  
A. The fee for the application is $250. If you also require a controlled substances registration, that  
application fee is $60. All fees should be paid my cash, check or money order and submitted with your  
application. Checks and money orders should be made payable to the Indiana Professional Licensing  
Agency. We do not accept credit card payments.  
Q. When should I apply for licensure?  
A. Since a U.S./Canadian medical school graduate is not eligible for licensure until one year of training  
has been completed, you should not submit your application until after six months of training have been  
completed.  
Further, documentation relating to your application can be submitted at any time; you do not need to  
wait until your application has been submitted. The Board will retain documents for 6 months.  
Q. Should I take Step 3 before I apply for licensure?  
A. You are not required to take and pass the USMLE Step 3/COMLEX Step 3 before you apply; however, a  
license will not be issued to any applicant until they have passed all three steps. In Indiana, you must  
pass all three steps of the USMLE within 10 years, with a maximum attempt of three times per step. For  
osteopathic physicians, all three steps must be passed within 7 years, with a maximum attempt of fives  
times per step.  
Applicants who fail to pass all the steps within the required timeframe or within the maximum number  
of attempts may stil apply for licensure and request a waiver. Waiver requests are reviewed on a case-  
by-case basis, and may require a personal appearance before the Medical Licensing Board. In  
determining whether to grant a waiver, the Medical Licensing Board will consider an applicant's training,  
experience, and credentials. Additional conditions, such as agreeing to work in an underserved area,  
may be required if a waiver is granted.  
Q. How long is my license valid?  
A. Upon issuance of your license, your license will remain valid through October 31 of each odd year.  
(https://www.in.gov/pla/professions/medical-licensing-board-of-indiana/physicianosteopathic-  
physician/)  
Best regards,  
Chris Salazar-Fields, MD  
Internal Medicine Resident  
Authority Health  
3031 W. Grand Blvd., Suite 600  
Detroit, MI 48201  
From:  
BPL-BoardSupport  
To:  
Subject:  
Date:  
MacIntosh, Weston (LARA)  
FW: Public Hearing Comment - General Rules  
Thursday, June 2, 2022 7:10:35 AM  
image002.png  
Attachments:  
Thank you,  
Stephanie Wysack  
Departmental Technician  
Boards and Committees Section  
Bureau of Professional Licensing  
Michigan Department of Licensing and Regulatory Affairs  
Phone: 517-241-7500  
Email: BPL-BoardSupport@michigan.gov  
Confidentiality Notice: This State of Michigan message, including any attachments, is intended solely for the use of the  
named recipient(s) and may contain confidential and/or privileged information. Any unauthorized review, use,  
disclosure or distribution of any confidential and/or privileged information contained in this email is expressly  
prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy any and all  
copies of the original message.  
From: Eman Talia <etalia-gme@authorityhealth.org>  
Sent: Wednesday, June 1, 2022 4:40 PM  
To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>  
Subject: Public Hearing Comment - General Rules  
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
Dear board of Medicine,  
I am emailing you to give my comments about changing the requirement for full licensing for  
physician to have MD to be allowed to obtain full licensing after completing one year of  
residency instead of two years. Doing so will have it fair and equal to the fellow physician who  
have a DO degree.  
I urge the board of medicine to look into this and hopefully make the right decision to make  
DO and MD have the same requirements especially now they both have merged together and  
work side to side in residencies, hospitals and clinics.  
Thank you for your understanding,  
Eman Talia, MD  
PGY 2 Internal medicine  
Authority health program  
;