Intealth ECFMG

Educational Commission for Foreign Medical Graduates

ECFMG 2023 Information Booklet

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Irregular Behavior

A. Policies Regarding Irregular Behavior

1. Irregular behavior includes all actions or attempted actions on the part of applicants, examinees, potential applicants, others when solicited by an applicant and/or examinee, a medical school official, or any other person or entity that would or could subvert the examination, certification or other processes, programs, or services of ECFMG, including, but not limited to, the ECFMG Exchange Visitor Sponsorship Program, ECFMG International Credentials Services (EICS), the Electronic Portfolio of International Credentials (EPIC), and Electronic Residency Application Service (ERAS) Support Services at ECFMG. Such actions or attempted actions are considered irregular behavior, regardless of when the irregular behavior occurs, and regardless of whether the individual committing the action is certified by ECFMG or eligible for ECFMG Certification and in the case of a medical school, regardless of whether a medical school official is also charged. Examples of irregular behavior include, but are not limited to, submission of any falsified or altered document to ECFMG, whether submitted by the individual or by a third party, such as a medical school or other entity, on behalf of the individual; failing to comply with United States Medical Licensing Examination® (USMLE®) or ECFMG policies, procedures, and/or rules; falsification of information on applications, submissions, or other materials to ECFMG; taking an examination when not eligible to do so, submission of any falsified or altered ECFMG document to other entities or individuals; a medical school providing false information to ECFMG regarding its students or a medical school providing misleading information to its students regarding ECFMG Certification.

2. The Medical Education Credentials Committee’s determination of irregular behavior is sufficient cause for ECFMG to bar an individual from future examinations, to bar an individual from other ECFMG programs and services, to withhold and/or invalidate the results of an examination, to withhold an ECFMG Certificate, to revoke an ECFMG Certificate, or to take other appropriate actions for a specified period of time or permanently. The Medical Education Credentials Committee’s determination of irregular behavior is also sufficient cause for ECFMG to remove a Sponsor Note from the World Directory of Medical Schools in accordance with its Medical School Requirements for ECFMG Certification Eligibility Policy and Procedures (aka “ECFMG Medical School Listing Policy”) for a specified period of time or permanently or to take other appropriate actions. ECFMG may report the Medical Education Credentials Committee’s determination of irregular behavior to the USMLE Committee for Individualized Review, Federation of State Medical Boards of the United States, U.S. state and international medical licensing authorities, directors of graduate medical education programs, and to any other organization or individual who, in the sole judgment of ECFMG, has a legitimate interest in such information.

3. If the Medical Education Credentials Committee determines that an individual engaged in irregular behavior, a permanent annotation to that effect will be included in the individual’s ECFMG record. This annotation will appear on the ECFMG Certification Verification Service (CVS) and ECFMG Status Reports for the individual. If the individual has an EPIC Portfolio, a permanent annotation will be included on all EPIC Reports with respect to that individual. Additional information explaining the basis for the determination of irregular behavior and the resulting action(s) will accompany every ECFMG Status Report, CVS Report, and EPIC Report, and may also be provided to legitimately-interested entities; this additional information may be provided, regardless of the date of the conduct or activity that comprises the irregular behavior.

4. If the Medical Education Credentials Committee determines that a medical school has committed irregular behavior, ECFMG may remove its Sponsor Note for the medical school in accordance with the ECFMG Medical School Listing Policy. ECFMG may report the determination of irregular behavior to any organization or individual who, in the sole judgment of ECFMG, has a legitimate interest in such information.

5. Notice of the Medical Education Credentials Committee’s determination of irregular behavior is periodically reported to the ECFMG Board of Trustees.

B. Procedures Regarding Irregular Behavior

1. After receipt of a report or other information suggesting irregular behavior on the part of an individual or entity, ECFMG staff will review the information and will assess whether there is sufficient evidence of irregular behavior to proceed with an investigation. When indicated and feasible, staff will conduct a follow-up investigation to gather additional information.

2. If the individual is an examinee and the review referenced above will not be concluded until after the typical period for the reporting of exam scores, the examinee will be notified that the reporting of the exam scores in question is being delayed.

3. If the ECFMG staff finds that there exists a reasonable basis to conclude that an individual or entity may have engaged in irregular behavior, the matter will be referred to the Medical Education Credentials Committee. ECFMG may withhold services from the individual or entity pending a determination from the Medical Education Credentials Committee. If the individual referred is an examinee, the examinee’s exam scores will be withheld, if not already released, and the examinee may not be permitted to sit for subsequent examinations, nor will applications for examination be processed. If the individual referred is an applicant for J-1 Sponsorship with the ECFMG Exchange Visitor Sponsorship Program or is currently being sponsored by ECFMG, ECFMG will notify the United States Department of State of the pending allegation if required to do so by regulation. If a school or other academic institution is referred, ECFMG may implement additional requirements on the school and its students to demonstrate that it has the staff, policies/procedures, and facilities necessary for the school’s students and graduates to fulfill ECFMG’s requirements to become ECFMG certified and/or take such other measures to protect the health and safety of the public.

4. Concurrent with the referral to the Medical Education Credentials Committee, the individual or entity will be advised in writing of the nature of the alleged irregular behavior and will be provided with a copy of the Policies and Procedures Regarding Irregular Behavior. If the alleged irregular behavior is related to a shared ECFMG and USMLE policy, the USMLE Program will also be advised of the allegation. The individual/entity will be given an opportunity to provide written explanation and to present other relevant information. Any such written explanation or other relevant information must be received by ECFMG by the deadline communicated to the individual/entity. Submissions received after the deadline will be considered by the Medical Education Credentials Committee at its discretion. The individual/entity may also request the opportunity to appear in person before the Medical Education Credentials Committee, and may be represented by legal counsel, if desired. For in-person appearances before the Medical Education Credentials Committee, a stenographic or audio recording will be made of that portion of the proceedings during which the individual/representative(s) for the entity are in attendance. Any statements made by the individual or individual(s) representing the entity during an in-person appearance before the Medical Education Credentials Committee will be under oath. All hearings involving applicants for ECFMG’s certification program will be held in English and interpreters will not be permitted. For hearings involving applicants to ECFMG’s other programs and services, ECFMG will allow an interpreter if obligated to provide services in languages other than English. In these circumstances, if an interpreter is desired, the applicant must request one in writing by the response deadline outlined in ECFMG’s letter to the applicant. ECFMG will then provide the interpreter. All in- person hearings for entities charged with irregular behavior will be conducted in English and interpreters will not be permitted.

5. Individuals/entities charged with irregular behavior who wish to request a deferral of the ECFMG Committee’s review of the allegation must (1) submit the request in writing and (2) provide the reason for the request. If ECFMG staff determine that the granting of the request could have a material impact on the individual’s or entity’s opportunity to refute the allegation then staff, at its discretion, can grant the request and defer an ECFMG action for up to six (6) months. Unless the individual/entity can demonstrate compelling circumstances, ECFMG staff should not grant more than two deferral requests. Notwithstanding the foregoing, if the individual charged with irregular behavior is ECFMG Certified, a candidate for residency, or practicing medicine, or if the entity is a medical school, ECFMG staff will only grant the request for deferral if, in its sole discretion, ECFMG believes that public health and safety is not at risk. If the deferral request is granted, ECFMG will notify appropriate institutions and authorities of the individual’s or entity’s pending irregular behavior charge.

6. All pertinent information regarding the irregular behavior, including any explanation or other information that the individual/entity may provide, will be provided to the Medical Education Credentials Committee. The Medical Education Credentials Committee, based on the information available to it, will determine whether the preponderance of the evidence indicates that the individual/entity engaged in irregular behavior. If the Medical Education Credentials Committee determines that the individual/entity engaged in irregular behavior, the Medical Education Credentials Committee will determine what action(s) will be taken as a result of the irregular behavior. ECFMG will notify the individual/entity whether the Medical Education Credentials Committee determined the individual engaged in irregular behavior and of any action(s) taken pursuant thereto.

7. The Medical Education Credentials Committee’s determination of irregular behavior and any action(s) taken pursuant thereto (a “decision” of the Medical Education Credentials Committee) may be appealed to the Review Committee for Appeals if the individual/entity has a reasonable basis to believe the Medical Education Credentials Committee did not act in compliance with the Medical Education Credentials Committee Policies and Procedures or that the Medical Education Credentials Committee’s decision was clearly contrary to the weight of the evidence before it. The notice of appeal must be received by ECFMG within thirty (30) days of the date on which the notification advising the individual of the Medical Education Credentials Committee’s decision was mailed to the individual. The appeal of a decision of the Medical Education Credentials Committee is governed by the Medical Education Credentials Committee’s Rules of Appellate Procedure.

8. Petitions for reconsideration of a decision of the Medical Education Credentials Committee will be reviewed by the Medical Education Credentials Committee only in extraordinary cases. Any such petition must first be considered by ECFMG staff, who, after discussion with the Medical Education Credentials Committee Chair, may deny the request or place it on the agenda for consideration by the full Medical Education Credentials Committee at a regularly scheduled meeting. Absent the submission of newly discovered material evidence not previously available to the petitioner and, therefore, not available to the Medical Education Credentials Committee, petitions for reconsideration typically will be denied. Generally, ECFMG will not consider as newly discovered evidence actions that the individual/entity has taken after the irregular behavior has occurred and/or after the finding of irregular behavior by the Medical Education Credentials Committee.

C. Representative Examples of Irregular Behavior

Representative examples of allegations of irregular behavior and actions taken by the ECFMG Medical Education Credentials Committee include, but are not limited to, the following:

  • Providing false information on an application submitted to ECFMG
  • The ECFMG Medical Education Credentials Committee reviewed an allegation of irregular behavior in connection with an individual who provided false information on an application submitted to ECFMG as part of the certification process. In that application, the individual certified he was a student enrolled in medical school when, in fact, he previously had been dismissed from medical school and, therefore, was no longer a student.
  • Following review, the ECFMG Medical Education Credentials Committee determined the individual had engaged in irregular behavior and took action to bar the individual from ECFMG Certification, thereby rendering the individual ineligible to apply for USMLE examinations leading to ECFMG Certification. A permanent annotation was added to the individual’s record.
  • Providing false information to ECFMG as part of the ECFMG On-line Authentication Process, which is a prerequisite to submitting an application for examination
  • The ECFMG Medical Education Credentials Committee reviewed an allegation of irregular behavior in connection with an individual who provided false information to ECFMG as part of the ECFMG On-line Authentication Process, which is used to obtain a USMLE/ECFMG Identification Number and is a prerequisite to submitting an application for examination. During the on-line authentication process, the individual certified he had not previously submitted an application for examination to ECFMG when he had not only previously applied for, but had taken examinations.
  • Following review, the ECFMG Medical Education Credentials Committee determined the individual had engaged in irregular behavior and took action to bar the individual from ECFMG Certification, thereby rendering the individual ineligible to apply for USMLE examinations leading to ECFMG Certification. A permanent annotation was added to the individual’s record.
  • Submitting a fraudulent medical diploma and providing false information on an application submitted to ECFMG
  • The ECFMG Medical Education Credentials Committee reviewed an allegation of irregular behavior in connection with an individual who submitted a fraudulent medical diploma and provided false information on an application submitted to ECFMG.
  • Following review, the ECFMG Medical Education Credentials Committee determined the individual had engaged in irregular behavior and took action to bar the individual from ECFMG Certification, thereby rendering the individual ineligible to apply for USMLE examinations leading to ECFMG Certification. A permanent annotation was added to the individual’s record.
  • Submitting a falsified medical school transcript and providing false information to ECFMG
  • The ECFMG Medical Education Credentials Committee reviewed an allegation of irregular behavior in connection with an authorized medical school official who submitted a fraudulent medical school transcript and provided false information to ECFMG.
  • Following review, the ECFMG Medical Education Credentials Committee determined the authorized medical school official had engaged in irregular behavior and determined that ECFMG will not accept any documents signed and/or certified by the medical school official for ECFMG on behalf of the medical school, or any other medical school, for a minimum of five years. A permanent annotation was added to the medical school official’s record.
  • Submitting a falsified passport and providing false information on an application submitted to ECFMG
  • The ECFMG Medical Education Credentials Committee reviewed an allegation of irregular behavior in connection with an individual who submitted a falsified passport and provided false information on an application submitted to ECFMG.
  • Following review, the ECFMG Medical Education Credentials Committee determined that the individual had engaged in irregular behavior. A permanent annotation was added to the individual's record.

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[Last update: September 14, 2022]

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