Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Medicine
 
chapter
Regulations Governing the Practice of Medicine, Osteopathic Medicine, Podiatry, and Chiropractic [18 VAC 85 ‑ 20]
Action Licensure of foreign physicians through provisional and restricted licenses
Stage NOIRA
Comment Period Ended on 4/23/2025
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4/22/25  6:01 pm
Commenter: Sultana Salam, MD & Afghan Association of Central Virginia

Remove Barriers for Foreign Medical Providers to Serve Virginians
 

My name is Sultana A. Salam, MD, a board-certified  Psychiatrist who has been practicing in the US  for over 43 years. I am an FMG.  I am also a co-founder of the Afghan Association of Central VA since the fall of Afghanistan in 2021.

I have been invited to partner with the Refugee Physician’s Advocacy Committee because of the large number of Afghan Physicians that entered the US in 2021.

I would like to share with you some  of the challenges faced by these physicians that have been shred WITH MWE, 90 of whom are in VA.

The majority of them have practiced in Afghanistan for more than 5-10 years. Many have been in leadership roles, teaching roles, and have held department chair positions. Many are  internists, surgeons, obstetricians, psychiatrists, etc.

They found it difficult to prepare for the ECFMG due to the lack of response or any feedback from them after submitting the necessary documents and Form 186 that were certified by Notarycam.

Many found it difficult to prepare or sit for the USMLE due to the long hours they work to provide for their families ( in menial jobs). But even after having worked long hours, the income they generate would not suffice to pay for Kaplan’s classes or for the application fees to sit for the examinations. So financially they are limited, specially with  the sky rocketing prices of housing rents, auto insurances, medical insurances, food, medical needs, utilities, etc.

Those physicians that did pass ECFMG, USMLE have failed to secure any residency positions, observer ships, or even externships because of the lack of “ recommendation letters”. How can they obtain those from their country of origin when many people, who could provide such recommendations on their behalf, have been displaced or are deceased. The fact that some have been able to obtain their transcripts/medical documents is note-worthy.

One physician that I met a few weeks ago has passed ECFMG, all USMLE steps but unable to find a residency program and is paying a clinic $4 K( her husband started business and therefore able to afford it) every 4 weeks for an externship in order to obtain “ letters of recommendation” to submit with her residency application

Many have applied for work in the health care  field as medical assistants, nurses, etc. but denied because of  being  “ overqualified or need  for  “certifications” which then mandate >3000 hours of supervision despite passing the examinations. How can they obtain supervision hours when no one hires them under their supervision?

Please note that these physicians have encountered many losses ( their country, culture, family, friends, and prestige as professionals in their country) and are clearly experiencing depression, PTSD, anxiety, and demoralization.

I plead with you, to please give them a chance,  a probationary period, to test their skills, their level of competency in their field of expertise,  their ethics, and patient care. Let them undergo both practical and written exams to ensure they know what they are doing

I would like to propose  a structured transitional pathway for the Afghan Medical graduates ( as is available in Missouri and Washington). This could be in the form of  an  accelerated 6 -12 months residency program (for those with medical experiences of 5 years or more) that could open the doors to “ provisional licensing “ but it will also allow them to review/refresh their knowledge and prepare for the USMLE examinations. A “ teaching medical environment” would be more conducive to their acquisition of knowledge faster, pertaining to  the USA methods of assessing, managing, and coding for patient care.  These doctors learn fast, trust me. They also need to hear all the symptoms, differential diagnoses in English.

I would also  like to propose that loans be provided to them to pay for Kaplan’s classes and  USMLE fees  but  postpone their payback to when they are licensed ( very much like owing tuition fees for college students). This will motivate them to study without having to worry about the financial aspects of the classes and examination fees.

Thank you in advance for your time, dedicated hard work and consideration into the case of these physicians who can definitely assist with the shortage of healthcare providers in VA.

 Respectfully,

S. Ayubi-Salam, MD

 

 

 

 

                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           

 

 

 

                                                                                                                                                                                              

                                                                                                                                                                                                                                                                                                                            

 

 

 

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