If you are an International Medical Graduate (IMG) wondering whether you can practice medicine in the United States without completing a US residency, Tennessee has opened a real and legal pathway for you.
In 2023, Tennessee became the first state in the US to pass a law allowing IMGs to practice medicine without repeating their residency in America. The law went into effect on July 1, 2024, and as of 2025, it remains one of the most significant opportunities available to foreign-trained doctors seeking to build a medical career in the US.
This guide breaks down exactly how it works, who qualifies, and what the path to full licensure looks like.
Why Tennessee Changed Its Law
The United States is facing a serious physician shortage, and Tennessee is no exception. A 2020 study published in Human Resources for Health projected a shortfall of nearly 6,000 physicians in Tennessee alone by 2030. Rural and underserved communities are hit hardest, often going without access to specialists in cardiology, oncology, neurology, and primary care.
At the same time, thousands of qualified IMGs with years of medical training and clinical experience were being locked out of the US healthcare system simply because they had not completed an ACGME-accredited US residency, a process that takes 3 to 7 years, is extremely competitive, and is particularly difficult for graduates who completed their training several years ago.
Tennessee’s response was the Graduate Physicians Act (HB1311 and HB1312), signed by Governor Bill Lee in April 2023.
The Two Pathways: HB1311 vs HB1312
Tennessee created two distinct licensing tracks. Understanding the difference is critical before you decide which applies to you.
HB1311 — Graduate Physician License (Collaborative Practice)
This pathway is designed for IMGs who completed residency abroad but have not yet practiced for several years.
Eligibility requirements:
- Completed at least 3 years of an accredited medical residency outside the US or Canada
- Passed USMLE Step 1 and Step 2 within 2 years immediately before applying (and no more than 3 years after graduating from medical school)
- Credentials verified through a recognized credentialing organization
How it works:
- You enter a supervised collaborative agreement with a fully licensed, board-certified physician
- You must practice in a designated medically underserved area, pilot project area, or rural health clinic
- The license is valid for 2 years and is non-renewable
Important limitation: This license does not lead directly to full licensure. It is best understood as a structured entry point into the US healthcare system, not a permanent solution on its own.
HB1312 — Provisional Medical License (Hospital-Based Pathway)
This is the more practical route for most experienced IMGs and the one most likely to lead to full, unrestricted licensure.
Eligibility requirements:
- Completed a 3-year residency abroad, OR practiced medicine legally for at least 3 of the past 5 years
- Passed all 3 steps of the USMLE
- Credentials verified through an approved organization
How it works:
- You receive a provisional medical license to work under supervision in a Tennessee hospital that has an accredited residency program
- After 2 years of supervised practice in good standing, you become eligible for a full, unrestricted medical license in Tennessee
- This full license has no special restrictions on practice setting or specialty (though specialty board certification requirements remain separate)
This is the primary pathway for IMGs who want a clear route to permanent licensure without going through a US residency.
Step-by-Step: How to Pursue the HB1312 Pathway
⚠️ Note: The application process and administrative rules are set by the Tennessee Board of Medical Examiners and may be updated. Confirm the latest requirements at tn.gov/health before beginning your application.
- Verify your USMLE scores: All 3 steps must be completed. If you have pending steps, prioritize completing them before applying.
- Get your credentials verified: Work with ECFMG (Educational Commission for Foreign Medical Graduates) or another recognized credentialing body to authenticate your medical degree and training records.
- Identify a sponsoring Tennessee hospital: The hospital must have an accredited residency program. A list of Tennessee hospitals with accredited programs is available through the ACGME directory.
- Apply to the Tennessee Board of Medical Examiners: Submit your application along with verified credentials, USMLE transcripts, and proof of prior practice or residency completion.
- Begin supervised practice: Work under an attending physician at your sponsoring hospital for the 2-year period required under HB1312.
- Apply for full licensure: After 2 years in good standing, submit for your full, unrestricted Tennessee medical license.
What You Can and Cannot Do Under These Licenses
| HB1311 (Graduate Physician) | HB1312 (Provisional License) | |
|---|---|---|
| Practice setting | Underserved areas / rural clinics only | Tennessee hospital with accredited residency |
| Supervision required | Yes, collaborative agreement with licensed physician | Yes, under hospital attending |
| License duration | 2 years, non-renewable | 2 years, then eligible for full license |
| Leads to full licensure | No | Yes |
| Specialty practice | General medicine only | General medicine (specialty boards separate) |
| USMLE required | Steps 1 and 2 | All 3 steps |
Is Tennessee Still the Only State Doing This?
No. Tennessee was the first, but it has since influenced other states to act.
Illinois passed a similar law in September 2023, allowing IMGs to work in underserved areas for two years under supervision before receiving a full license. Florida, Virginia, Alabama, Colorado, Idaho, and Washington have all taken legislative steps to reduce residency barriers for IMGs. Several other states including Arizona, Iowa, Massachusetts, Missouri, Nevada, and Vermont have introduced or are actively considering similar bills.
The momentum is real. If you are an IMG evaluating your options, it is worth tracking developments in multiple states, but Tennessee remains the most clearly defined and operational pathway as of 2025.
Who Should Seriously Consider This Pathway
This law is most valuable for:
- IMGs who graduated several years ago and are no longer competitive in the residency match
- Experienced physicians who practiced for years in their home country and want to transition to the US
- IMGs who have passed their USMLE steps but have been unable to secure a residency position
- Doctors in specialties with high demand in rural Tennessee (family medicine, internal medicine, psychiatry)
It is less suitable for IMGs who are early in their training, have not yet completed all USMLE steps, or are specifically targeting competitive specialties that require US residency training for fellowship eligibility.
Final Thoughts
Tennessee’s Graduate Physicians Act is a genuine and working opportunity for qualified IMGs. It does not eliminate all barriers, supervision is required, and the path takes two years, but it offers something that did not exist before: a clear, legal route to full US medical licensure without completing a US residency.
If you are an IMG evaluating your options in 2025, this pathway deserves serious attention.
Legal Disclaimer: The information in this article is provided for general informational purposes only and does not constitute legal, medical, or licensing advice. Regulations governing medical licensure can change at any time. USMLE Strike makes no representations as to the accuracy or completeness of any information on this page. Always verify current requirements directly with the Tennessee Board of Medical Examiners before making any licensing decisions.
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