Alternate Pathways to Integrate International Medical Graduates (IMGs) into the U.S. Healthcare Ecosystem: A Policy Analysis of Texas HB 2038 (“the DOCTOR Act”).

Abstract

Background: The United States and Texas, in particular, face persistent and worsening physician shortages, disproportionately affecting rural and underserved communities. Texas HB 2038 (“the DOCTOR Act”) establishes alternative licensure pathways intended to streamline the entry of qualified International Medical Graduates (IMGs) into supervised clinical roles, with a focus on service in safety-net and shortage settings.

Objective: To distill the policy architecture of HB 2038 into an implementation-ready framework describing eligibility, site requirements, supervision, geographic constraints, and procedural steps for two licensure routes: the Foreign-Licensed “Provisional” license and the “Physician Graduate” limited license.

Methods: Descriptive policy analysis of an implementation presentation and its cited resources (professional association briefs, state board guidance, and the bill text). Information was extracted, categorized (by eligibility, sites, supervision, geography, and testing), and synthesized into operational checklists and proposed evaluation metrics.

Results: Both pathways require an ECFMG-eligible primary medical qualification (from a WDOMS-listed school with a sponsor note), primary-source verification, and English proficiency as demonstrated by OET-Medicine. The “Provisional” license requires an active foreign license, completed postgraduate training abroad, a Texas employment offer, and completion of the Texas Medical Jurisprudence Exam; practice initially occurs at ACGME-accredited/affiliated sites and, upon renewal, is restricted to rural/MUA/HPSA settings. The “Physician Graduate” limited license requires Texas residency, valid U.S. work authorization/citizenship/permanent residence, a supervising practice agreement, and non-enrollment in a residency program. Practice is limited to clinics in counties with fewer than 100,000 residents and FQHC/FQHC-LAL sites.

Conclusions: HB 2038 offers structured, supervised, and shortage-area–oriented on-ramps for IMGs. Effective execution will hinge on supervisory capacity, safety-net site readiness, jurisprudence, and access to language testing, as well as outcomes monitoring (including access, quality, and retention). (Texas Legislature, n.d.). (Texas Medical Board, n.d.)