Under Immigration and Nationality Act (INA) Section 212(a)(5)(C), health care workers (except physicians) who seek employment in the United States must obtain a health care worker certification from an approved independent credentialing organization. Physical therapists are among those allied health professionals subject to this requirement and commonly obtain the required certification from the Foreign Credentialing Commission on Physical Therapy (FCCPT). Until September 2016, physical therapists who possessed a bachelor’s degree in physical therapy were able to submit their credentials, including evidence of their bachelor’s degree, to FCCPT and obtain the certificate. That standard has changed, effective immediately.
For the remainder of this calendar year, all applications filed with FCCPT by September 15, 2016, that are “in review” (all documents in support of the applications have been received) or “pending” (additional documents are required to complete the applications) must show substantial equivalence to a master’s degree or higher in physical therapy in order to obtain the required certification. Applications filed after September 15, 2016, must include evidence of a master’s degree or higher in physical therapy in order to obtain the required certification. The previously issued certifications to applicants who applied based on a bachelor’s degree prior to this new rule becoming effective remain valid and applicants may obtain subsequent renewals of those certifications (if the currently valid certifications are set to expire) for the remainder of 2016 without meeting the new master’s degree or higher standard.
As of January 1, 2017, applicants for FCCPT certification must meet an even higher educational standard. They must possess a doctorate in physical therapy in order to obtain certifications from FCCPT. Here again, applications for renewals of previously issued certifications would not need to include evidence of this heightened standard in order for renewals to be issued.
This new rule dramatically changes the standards for physical therapists seeking to obtain health care worker certifications from FCCPT. All new applications for the remainder of 2016 must have evidence of a master’s degree or higher in physical therapy and all new applications starting in 2017 must have evidence of a doctorate in physical therapy. It is unclear as of this writing whether the Commission on Graduates of Foreign Nursing Schools (CGFNS), which also is authorized under INA to issue certifications to physical therapists, will change its standards similar to FCCPT’s changes.
Jackson Lewis will monitor any further developments with respect to health care worker certifications for U.S. employment.