ECFMG Programs and Irregular Behavior
ECFMG Policies and Procedures Regarding 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, or any other person 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 is certified by ECFMG. 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, 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, or submission of any falsified or altered ECFMG document to other entities
or individuals.
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. ECFMG
may report the Medical Education Credentials Committee’s determination of irregular behavior to the USMLE
Committee on Irregular Behavior and Score Validity, 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 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 Credentials 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. 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, ECFMG
staff will review the information and will assess whether there is sufficient evidence of irregular behavior. 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 ECFMG staff finds that there exists a reasonable basis to conclude that an individual may have engaged in
irregular behavior, the matter will be referred to the Medical Education Credentials Committee. ECFMG may
withhold services from the individual pending a determination from the Medical Education Credentials Committee.
If the individual 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.
4. Using the individual’s last known address, the individual will be advised in writing of the nature of the alleged
irregular behavior and will be provided with a copy of the ECFMG Policies and Procedures Regarding Irregular
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Behavior. The individual 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 set forth in ECFMG’s writing to the individual. Submissions received after the deadline will be considered
by the Medical Education Credentials Committee at its discretion. The individual may also request the opportunity
to appear personally before the Medical Education Credentials Committee, and may be represented by legal
counsel, if the individual so wishes. In instances in which the individual appears personally before the Medical
Education Credentials Committee, a stenographic or audio recording will be made of that portion of the
proceedings during which the individual is in attendance. Any statements made by the individual during a personal
appearance before the Medical Education Credentials Committee will be under oath.
5. All pertinent information regarding the irregular behavior, including any explanation or other information that the
individual 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 engaged in irregular behavior. If the Medical Education Credentials
Committee determines that the individual 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 whether the Medical Education Credentials Committee determined the individual engaged in irregular
behavior and of any action(s) taken pursuant thereto.
6. 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 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 sixty (60) days of the date on which the
notification advising the individual of the Medical Educational Credentials Committee’s decision was mailed to the
individual. The appeal of a decision of the Medical Education Credentials Committee is governed by the Rules of
Appellate Procedure.
7. 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.
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:
Submitting an altered or fabricated letter of recommendation
The ECFMG Medical Education Credentials Committee reviewed an allegation of irregular behavior in
connection with an ECFMG-certified individual who submitted two fraudulent letters of recommendation to
ERAS Support Services at ECFMG.
Following review, the ECFMG Medical Education Credentials Committee determined the individual had
engaged in irregular behavior and took action to revoke the individual’s Standard ECFMG Certificate
and to bar the individual from admission to all ECFMG examinations.
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 for a USMLE examination
submitted to ECFMG. 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.
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