Eligibility for patient contact is determined by several factors; NIH designation, immigration status, and whether the foreign medical graduate needs full or incidental patient contact. The information below describes the policies and requirements for full or incidental patient contact broken down by NIH designation and immigration status.
Consult with DIS to confirm the eligibility of a specific foreign medical graduate.
An M.D. or an equivalent degree is required to be eligible for patient contact. No level of patient contact privileges is granted without review and approval by the NIH Credentialing Services Section, Medical Records Department, and the Medical Executive Committee. Contact the NIH Credentialing Services Section if you have questions about a foreign medical graduate’s eligibility for patient contact from a credentialing perspective.
When possible, apply for incidental patient contact (IPC) to be effective at the start of the award, appointment, or assignment period. When in doubt about whether IPC will be needed to fulfill a foreign scientist's research program, apply for it.
- Clear explanation of the need for IPC in the "Description of Proposed Research Program" block of Form NIH 829-1 or NIH 590
- Copy of Educational Commission for Foreign Medical Graduates (ECFMG) certification, if applicable
"Four-Point" Memorandum through the IC Clinical Director, to the designated NIH senior medical official, to outline the participant's clinical duties. The memorandum must include (a) the name of the foreign scientist to whom it refers; (b) the name of the NIH physician who will be responsible for the FMG's patient contact; and (c) address the following four points:
- that the program in which the foreign physician will participate is predominately involved with observation, consultation, teaching, or research;
- that the individual's research program necessitates clinical contact with patients involved in the research -- describe contact;
- the clinical privileges which are essential to carry out the research; and
- that the foreign physician (1) will not be given supervisory responsibilities nor final responsibility for the treatment or diagnosis of any patients, (2) that he or she will be supervised by a U.S. citizen or permanent resident who is licensed to practice medicine in the state of (or has a Public Health Service waiver of that requirement), and (3) that he or she will receive no credit towards medical specialty certification.
Note: A new "4-point memo" is not required for renewal of appointment if there is no change in the program or supervisor. If this is the case, specifically state so on the NIH 829-1 or NIH 590.