Dear Esteemed Future Colleagues,
As future physicians who depend on your support, we urge you to take action and protect both the future medical professionals and the communities which will be threatened by the irresponsible actions of the National Board of Osteopathic Medical Examiners (NBOME) who have not followed the lead of the National Board of Medical Examiners (NBME) in canceling the Step 2 CS exam.
As you are aware, each portion of both the COMLEX and USMLE licensing exams have been disrupted by the SARS-CoV-2 pandemic. Many adjustments have been made to continue administering these exams in a safe environment so that the medical schools of this county can continue to graduate fully certified physicians able to enter residency training and provide care to patients -- a need further highlighted by the strain this unprecedented pandemic has caused to our healthcare system. Despite these adjustments, one of these exams is unable to be safely administered due to the current global climate: the USMLE Step 2 Clinical Skills (CS) and COMLEX Level 2 Physical Exam (PE). These exams require medical students entering their final year of training to travel to skills assessment centers and perform 12 encounters with standardized patient actors to demonstrate competency after 12 months of supervised encounters with real patients. Several months of scheduled appointments were canceled on a rolling basis as this pandemic has evolved citing the risk of disease transmission to the students, the patient actors, the testing site staff, the airlines and other travel agencies involved in the travel plans of thousands of students, and the communities where these testing centers are located.
The USMLE Step 2 CS is administered at 5 testing centers in the United States: Atlanta, Chicago, Houston, Los Angeles and Philadelphia. The COMLEX Level 2 PE is administered at 2 testing centers: Chicago and Conshohocken. The risk to these communities is enhanced as medical students whose training is conducted inside the very hospitals caring for those patients most severely affected by COVID-19 are traveling into their communities for a full day of testing. The NBME has acknowledged this risk and has accordingly suspended the administration of the USMLE Step 2 CK for “12-18 months.” Furthermore, the USMLE has already guaranteed students that Step 2 CS will not be required to sit for Step 3 and the FSMB “has reviewed state statutes for medical licensing and confirmed that no legislative changes will be required because of the CS suspension. FSMB will work with the handful of state medical boards whose administrative rules list passage of Step 2 CS. NBOME has not taken these steps and testing is scheduled to resume on September 1st, 2020.
The NBOME has repeatedly stated that the cohort of students the NBME serves is larger and therefore not comparable. However, we believe this is a very selective interpretation of facts. In 2018-19 (year chosen because the data was readily available — we recognize that most of us affected by the PE this year are 2017-18), according to the AAMC, allopathic schools had 21,622 first years matriculate. Osteopathic schools had 8,124. When this data is framed in light of the differing number of testing site between the two boards:
• 21,622/5 = 4,324.4 USMLE students
• 8,124/2 = 4,062 NBOME students
This is a difference of fewer than 300 students and the International Medical Graduates seeking US licensure. However, we have also been informed that podiatry students in the US also utilize NBOME testing sites. In 2019, 567 podiatry students matriculated in the US. Assuming the same for 2017:
• (8,124 + 567)/2 = 4,345.5 NBOME students
This means that there are actually more US-based medicals students who need each of the NBOME test sites than the NBME.

We condemn the decision to continue Level 2 PE testing as posing an unprecedented and irresponsible risk both to ourselves as those who are at the mercy of the national licensing board and to the communities of Chicago and Philadelphia whose only involvement is to be the unfortunate locations of properties utilized by the NBOME. Inbound medical students from 59 teaching institutions across the country provide an unconscionable risk to the citizens of these communities. We have repeatedly raised these concerns to the NBOME to no avail. Therefore, we are reaching out to our professional organizations for help.
All other major medical organizations on a national and international level have enacted policies to limit the travel of medical students to protect both individuals and the greater community.
● The CDC continues to recommend social distancing at all times and advises against air travel where this cannot be adhered to.
● The WHO strongly advocates for social distancing to limit the spread of disease and has country-by-country guidance regarding travel limitations.
● AAMC recently published guidelines from a working group that represents 13 different medical licensing organizations which recommended severely limiting travel that medical students would normally undertake to out of state rotations and residency interviews.
● As previously stated, the NBME has discontinued administration of the USMLE Step 2 CS for a minimum period of 12-18 months.
● The ECFMG which previously required that IMGs take USMLE Step 2 CS to become certified for residency in the US has waived this requirement and put forward alternative pathways.
● Working groups from all specialities have been formed to advise and protect students from unnecessary health risks in these unique times, as exemplified by the citied statement from the Emergency Medicine specialty committees.
The use of USMLE Step 2 CS and COMLEX Level 2 PE has been in practice for less than two decades and these exams already have a storied and controversial history. For the sake of public health, we must set aside old arguments and take action together. All other medical students entering the 2021 Match, including US MDs, US IMGs, and international IMGs, have been protected from needless exposure to the global pandemic. Only DO students are still being forced to travel.
Future colleagues, as those professionals who will soon be joining you in enormous responsibility for the health and wellbeing of others, please help us step into the role we have committed to dedicating our lives too. Help us protect ourselves and others by condemning the irresponsible actions of the NBOME to disregard concerns from all levels, choosing to endanger the public. We ask you this, not just on behalf of ourselves, but on behalf of the rest of the public who has not been granted a voice in this debate.
Sincerely,
The Osteopathic Medical Students of the United States