Last v. Virginia State Board of Medicine

Benton, J.,

dissenting.

Dr. Joel I. Last graduated from an offshore medical school. During his medical school studies, he was assigned to classroom clinical rotations at hospitals in the United States that did not have approved residency programs. Following his graduation, he completed a year of residency in a hospital with an approved program and then completed a three year postgraduate program in psychiatry at the Georgetown University Medical Center. Part of his duties at Georgetown included supervising and training medical students. Currently, Dr. Last is licensed as a physician in Pennsylvania and the District of Columbia. He is employed as a clinical instructor of psychiatry at the Georgetown University Medical Center and at the Veterans Administration Hospital. His duties include training medical students and psychiatry residents.

The credentials committee of the Board of Medicine recommended that Dr. Last’s application for licensure by endorsement in Virginia be denied because he failed to meet “the requirement of . . . Code []§ 54.1-2930(4).”9 After a formal hearing pursuant *916to Code §§ 9-6.14:12 and 54.1-110, the Board accepted the committee’s recommendation and voted to deny the application for licensure. It concluded “that Dr. Last has not met the requirements as set forth in Section 54.1-2930(4) of the Code and VR 465-02-01, Part IV, Section 4.1(B)(2) of the General Regulations of the Board.”10 On appeal, the circuit judge ruled that the Board did *917not err in interpreting Code § 54.1-2930(4) to limit its discretion as it pertained to its consideration of Dr. Last’s application. Dr. Last contends that the Board failed to exercise its discretion in reviewing his application and that the rulings below reflect an error of law. See Code § 9-6.14:17. I agree that the Board committed an error of law.

The Board issues regulations pursuant to the authority granted by Code § 54.1-2400 for the administration of the basic laws contained in Code § 54.1-2900 et seq. The basic law authorizes the Board to issue licensure by endorsement as follows:

The Board, in its discretion, may issue certificates or licenses to applicants upon endorsement by boards or other appropriate authorities of other states or territories or the District of Columbia with which reciprocal relations have not been established if the credentials of such applicants are satisfactory and the examinations and passing grades required by such other boards are fully equal to those required by the Virginia Board.
The Board may issue certificates or licenses to applicants holding certificates from the national boards of their respective branches of the healing arts if their credentials, schools of graduation and national board examinations and results are acceptable to the Board. The Board shall promulgate regulations in order to carry out the provisions of this section.

Code § 54.1-2927(A).

In denying Dr. Last’s application, the Board applied the criteria of Code § 54.1-2930, a statute that is inapplicable to the issue whether Dr. Last met the requirements for licensure by endorse*918ment. Code § 54.1-2930, by its explicit terms, applies only to requirements for admission to take the medical examination. It does not apply to Dr. Last’s application for licensure by endorsement. Simply stated, the Board committed plain error. The only provision in the basic law that is pertinent to application for licensure by endorsement is Code § 54.1-2927(A). Dr. Last was entitled to have his application judged by the criteria contained in that statute because he is licensed in Pennsylvania and the District of Columbia.

Prior to the enactment of Code § 54.1-2927 in 1988, Code § 54-310 gave the Board discretion to “arrange for reciprocity with . . . the District of Columbia and other states and territories . . . and issue certificates [of licensure] to applicants who have met such requirements.”11 That statute also gave the Board discretion to issue certificates of licensure to applicants from states “with which reciprocal relations have not been established; provided the credentials of such applicants are satisfactory and the examinations and passing grades required by such other boards are fully equal to those required by the Virginia Board.” Code § 54-310 (1985 cumulative supplement). In 1988, Code § 54-310 was repealed and re-enacted in its current version, Code '§ 54.1-2927. It would appear that the Board’s decision whether to license applicants who have obtained endorsements from boards or other ap*919propriate authorities of other states or the District of Columbia with which reciprocal relations have been established would be made consistent with the understanding, if any, governing the reciprocal relations. Such a conclusion is implicit from the language of Code § 54.1-2927(A), which gives the Board discretion to license applicants for endorsement who are licensed in states “with which reciprocal relations have not been established.”

The record before us does not establish whether Virginia has reciprocal arrangements with either Pennsylvania or the District of Columbia, places where Dr. Last is currently licensed. The record also does not establish whether the credentials committee would have reached the same conclusion if it had not acted upon the mistaken premise that Code § 54.1-2930 governed its review. Furthermore, because the Board based its denial of Dr. Last’s application in part upon the application of Code § 54.1-2930(4), the record is unclear whether the Board views Regulation § 4.1 to be promulgated to effect the purposes of Code § 54.1-2927(A) or Code § 54.1-2930(4). In any event, the regulation itself does not distinguish between (i) applicants who have endorsements by other states with which reciprocal arrangements have been established, and (ii) applicants who have endorsements by other states with which reciprocal arrangements have not been established. If Dr. Last’s application falls within the former category, the record does not show whether a reciprocal understanding governs the review of his application. If his application falls within the latter classification of applicants, Dr. Last is entitled to have his application judged in accordance with the discretion explicitly vested in the Board by Code § 54.1-2927(A).

Accordingly, I would reverse the decision and remand for a new hearing upon application of principles consistent with this opinion.

Code § 54.1-2930 reads as follows:

§ 54.1-2930. Requirements for admission to examination. — The Board may admit to examination for licensure to practice medicine, osteopathy, chiropractic and podiatry any candidate who has submitted satisfactory evidence verified by affidavits that he:
1. Is eighteen years of age or more;
2. Is of good moral character;
3. Has successfully completed all or such part as may be prescribed by the Board, of an educational course of study of that branch of the healing arts in *916which he desires a license to practice, which course of study and the educational institution providing that course of study are acceptable to the Board; and
4. Has completed one year of satisfactory postgraduate training in a hospital approved by an accrediting agency recognized by the Board for internships or residency training. At the discretion of the Board, the postgraduate training may be waived if an applicant for licensure in podiatry has been in active practice for four continuous years while serving in the military and is a diplómate of the American Board of Podiatric Surgery. Applicants for licensure in chiropractic need not fulfill this requirement.
In determining whether such course of study and institution are acceptable to it, the Board may consider the reputation of the institution and whether it is approved or accredited by regional or national educational or professional associations including, but not limited to, such organizations as the Accreditation Council of Graduate Medical Education or other official accrediting body recognized by the American Medical Association, by the Committee for the Accreditation of Canadian Medical Schools or their appropriate subsidiary agencies, by any appropriate agency of the United States government, or by any other organization approved by the Board. Supervised clinical training which is received in the United States as part of the curriculum of a foreign medical school shall be obtained in an approved hospital, institution or school of medicine offering an approved residency program in the specialty area for the relevant clinical training. The Board may also consider any other factors that reflect whether that institution and its course of instruction provide training sufficient to prepare practitioners to practice their branch of the healing arts with competency and safety in the Commonwealth.

(Emphasis added).

The following are the pertinent provisions of the regulation:

§ 4.1. Licensure by endorsement.
A. An applicant for licensure by endorsement will be considered on his merits and in no case shall be licensed unless the Credentials Committee is satisfied that he has passed an examination equivalent to the Virginia Board of Medicine examination at the time he was examined and meets all other requirements of the Virginia Board of Medicine.
B. A Doctor of Medicine who meets the requirements of the Virginia Board of Medicine and has passed the examination of the National Board of Medical Examiners, FLEX, or the examination of the Licensing Medical Council of Canada may be accepted for licensure by endorsement without further examination. No applicant for licensure to practice medicine and surgery by endorsement will be considered for licensure unless the applicant has met all the following requirements for pre or postgraduate training as follows:
*917* * * 2. Graduates of schools of medicine not approved by an accrediting agency recognized by the board who served supervised clinical training in the United States as part of the curriculum of a foreign medical school, shall serve the clerkships in an approved hospital, institution or school of medicine offering an approved residency program in the specialty area for the clinical training received.

Licensure by Endorsement, Part IV, § 4.1, Regulations Governing the Practice of Medicine, Osteopathy, Podiatry, Chiropractic, Clinical Psychology, and Acupuncture, 6:8 Va. R. 1151 January 15, 1990.

Prior to the enactment of Code § 54.1-2927(A) in 1988 its predecessor read as follows:

The Board, in its discretion, may arrange for reciprocity with the authorities of the District of Columbia and other states and territories having requirements equal to those established by this chapter and the rules and regulations of the Board, and issue certificates to applicants who have met such requirements. The Board, in its discretion, may require physical therapist or physical therapist assistant candidates for licensure to meet professional activity requirements or serve as traineeship as set forth in its rules and regulations. The Board, in its discretion, may issue certificates to applicants upon endorsement by boards or other appropriate authorities of other states or territories or the District of Columbia with which reciprocal relations have not been established; provided the credentials of such applicants are satisfactory and the examinations and passing grades required by such other boards are fully equal to those required by the Virginia Board.
The Board may issue certificates to applicants holding certificates from the national boards of their respective branches of the healing arts; provided their credentials, schools of graduation and national board examinations and results are acceptable to the Board. The Board shall promulgate rules and regulations in order to carry out the provisions of this section.

Code § 54-310 (1985 Cum. Supp.).