Modification of Licensing Requirements
In response to the COVID-19 public health emergency, states have taken measures to alleviate the occupational licensure policy burdens that impede state response efforts and which are counterintuitive to social distancing practices. The following information presents a collection of policy actions states have implemented to modify licensing requirements.
The attainment and maintenance of an occupational credential/license normally involves several components including testing, background checks and education/experience verification. To the effect that it will relieve regulatory burdens in the time of the public health emergency and limit physical contact, many states have suspended certain requirements regarding obtaining and renewing licensure, including continuing education and exam requirements. The suspension of these requisites also serves to lessen the regulatory barriers that may impede licensed practitioners actively involved in the COVID-19 response.
Click to view each state’s actions
Arizona
- EO 2020-17 – Defers licensing renewal and continuing education requirements; allows for waiver of licensing fees; allows for provisional licenses where electronic testing cannot be delivered.
- EO 2020-28 – The Board of Examiners of Nursing Care Institution Administrators and Assisted Living Facility Managers shall certify an individual who completes on-the-job training instead of standard statutory training requirements.
Colorado
- EO D 2020 015 – Authorizes the Executive Directors of certain state gencies to promulgate and issue emergency rules extending the expiration date of licenses and other documents.
- EO D 2020 038 – Permits certain nurses, physicians, and respiratory therapists to cross train, supervise, and delegate responsibilities concerning the temporary care and treatment of patients.
- EO D 2020 042 – Extending Executive Order D 2020 015 authorizing the issuance of emergency rules extending the expiration date of licenses and other documents due to the presence of COVID-19.
- EOs D 2020 063, D 2020 97, and D 2020 131 – Extend EO D 2020 038.
- EO D 2020 075 – Amending and extending Executive Orders D 2020 015 and D 2020 042 authorizing emergency rules extending the expiration date of licenses and other documents for thirty (30) additional days due to the presence of COVID-19.
EOs D 2020 111 and D 2020 141 – Extend Executive Order D 2020 75.
Connecticut
- EO 7O – Authorizes the Commissioner of Public Health to waive licensing, renewal, and inspection requirements necessary to ensure the provision of adequate healthcare during, and mitigate the effects of, this public health and civil preparedness emergency, and to issue any implementing orders, she deems necessary.
- EO 7HHH – Authorizes the continued temporary suspension of the requirements for licensure, certification, or registration of out-of-state providers.
Illinois
- Department of Financial and Professional Regulation Grants of Variance – Extends license renewal deadlines; waives in-person continuing education requirements.
- EO 2020-23 – Suspends fingerprint requirements for health care workers; suspends certain requirements for the funeral director profession.
- EO 2020-28 – Suspends the provision in the Radiation Protection Act that limits the validity of industrial radiography certifications to 5 years and trainee certifications to two years. Additionally, certifications that have expired or will expire may be extended.
- EO 2020-22 – Suspends the requirement in the Health Care Worker Background Check Act that designates students, applicants, and employees must have fingerprints collected and transmitted to IDSP within 10 working days, so long as they are transmitted within 30 days of enrollment in a CNA program or start of employment.
- EO 2020-33 – Reissues Executive Orders 2020-03 through 2020-31, extending most provisions through May 29, 2020.
- EO 2020-39 – Reissues Executive Orders 2020-03 through 2020-37, extending most provisions through June 27, 3030.
- EO 2020-44 – Reissues Executive Orders 2020-03 through 2020-43, extending most provisions through July 26, 2020.
- EO 2020-48 – Issues most executive orders, extending a majority of the provisions through August 22, 2020, including Executive Order 2020-30.
Iowa
- Proclamation of Disaster Emergency – Suspends background check requirements, internship requirements, in-person continuing education requirements, renewal requirements and examination deadlines for certain occupations.
- 3/26 Proclamation of Disaster Emergency – Suspends regulatory provisions which limit the number of clinical hours that can be satisfied through simulation activities for nursing students.
- 4/2 Proclamation of Disaster Emergency – Extends 3/22 Proclamation and waives education requirements for medical workers and suspends application/examination deadlines for various licensed occupations.
- 4/24 Proclamation of Disaster Emergency – Allows for telehealth and suspends licensing requirements for dental practitioners.
- 5/26 Proclamation of Disaster Emergency – Extends 3/22 and 4/2 Proclamations.
- 6/25 and 7/24 Proclamations of Disaster Emergency – Extend 3/22 and 4/2 and 5/22 Proclamations.
Kansas
- EO 20-19 – Extends expiration date and continuing education requirements of all licenses, certificates, permits, and registrations set to expire during the State of Disaster Emergency to 90 days after the termination of the Emergency.
- EO 20-28 – Reissues Executive Orders 2020-01 through 20-26, extending most provisions through May 31, 2020.
- EO 20-35 – Allows out-of-state physicians to utilize telemedicine when treating patients within the state without a license to practice medicine in the state, provided advise the Board of their practice in writing. These provisions may be extended to other healthcare professionals. Allows the Board to grant a temporary emergency license and waive some requirements.
- EO 20-39 – Extends renewal deadlines for occupational or professional licenses in the state.
- House Bill 2016a – Allows a physician licensed in another state to practice telemedicine to treat patients in Kansas. Also allows the state board of healing arts to extend the provisions of this subsection to other healthcare professionals licensed by the board as deemed necessary.
Mississippi
- EO 1471 – Authorizes the Mississippi Department of Health, State Board of Nursing and State Board of Medical Licensure to make, amend and rescind regulations deemed necessary.
EOs 1485, 1494, and 1497 – Extend EO 1471 authorizing regulatory changes to facilitate healthcare provision.
Missouri
- Executive Order 20-04 – Authorizes the Director of the Department of Commerce and Insurance and the Division of Professional Registration and its Boards to temporarily waive or suspend the operation of any statutory requirement or administrative rule during the period of the emergency and subsequent recovery period; Suspends provisions related to teacher certification
Pennsylvania
- PA Department of State Waiver (March 20) – Requirements restricting nurses and nursing school graduates to a temporary practice permit of one year are suspended. Extends temporary licensure terms and waives fees temporarily for registered nurses and practical nurses. All temporary and graduate permits that would normally expire during the next 90 days will be automatically extended for an additional 90 days. Waives some requirements limiting nurses’ prescriptive authority such as physician collaborative requirements and pre-approval requirements. Nurse licensure expiration is extended three months. Nursing school graduates may apply for a graduate permit without taking licensure examinations.
- PA Department of State Waiver (March 22) – The requirement for pharmacists who have an authorization to administer injectables to hold an active CPR certificate is suspended. Allows for expedited temporary licensure of out-of-state licensed pharmacists including continuing education. The Bureau of Professional and Occupational Affairs is authorized to suspend requirements for letters of good standing, background checks, and other administrative requirements.
- PA Department of State Waiver (March 22) – Removes limitations on the use of distance-learning formats for continuing education for respiratory therapists, osteopathic respiratory therapists, psychologists, marriage and family therapists, and professional counselors.
- PA Department of State Waiver (March 22) – The requirement is suspended that temporary authorization to practice as a physician assistant be issued for up to 120 days upon board receipt of a complete written agreement. The requirement that the board must approve the use of a physician assistant at “satellite operations” is suspended.
- PA Department of State Waiver (March 27) – License renewal deadlines are extended by 90 days for graduate medical trainees, registered nurses, clinical nurse specialists, certified nurse practitioners, practical nurses, and nursing home administrators.
- PA Department of State Waiver (March 27) – For registered nurses and practical nurses the English proficiency testing requirement for practice permits has been waived. For certified registered nurse anesthetists, the requirements to administer anesthesia in cooperation with a surgeon is temporarily waived and replaced by a physician and board approval for those unable to take the exam are waived.
- PA Department of State Waivers (March 30) – Continuing education requirements for new osteopathic physicians and surgeons are temporarily waived.
- PA Department of State Waiver (April 13) – Temporarily waives requirements for pharmacists. Pharmacy interns who are within 90 days of graduating from pharmacy school are not required to have “immediate and personal” supervision requirements but can instead be supervised indirectly or off site through surveillance cameras or other remote communication. Pharmacy intern certificates have typically been valid for six years however those provisions have been waived.
- PA Department of State Waiver (June 9) – Extends license renewal deadlines for chiropractors, dietitian-nutritionists and pharmacists. License renewal deadlines falling between September 1st and October 1st are extended 90 days for pharmacists.
South Dakota
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- EO 2020-10 – Suspends certain certification requirements for teachers (examination, student teaching, application) and allows new teachers to obtain a one-year provisional certification.
- EO 2020-16 – Suspends requirements for controlled substances registration for prescribers and pharmacists; suspends background check requirement for new healthcare licensees; suspends requirement of a notarized affidavit attesting to a physician licensure applicant’s qualifications; suspends continuing education requirements for medical professions; waives jurisprudence exams for license reciprocity; waives practical experience requirements for pharmacist and pharmacy tech licensure; suspends pharmacy tech certification exam requirement; delays recertification of EMTs; suspends certification exam and continuing education requirements for electricians.
- EO 2020-19 – Suspends regulations governing the time limit to pass all sections of the examination required to become an abstracter.
- EO 2020-21 – Suspends statutory requirements that temporary or probationary law enforcement officers and 911 operators complete their training within one-year of appointment.
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Tennessee
- EO 15 – Extends license renewal deadlines for healthcare professions; suspends licensure requirements for postdoctoral fellows working in medical labs on COVID-19; allows Commissioner of Human Services to suspend licensure requirements for childcare workers; allows the Dept. of Commerce and Insurance to extend license renewal deadlines for its professions.
- EO 36 – Extends expiration dates of all healthcare and EMT licenses; suspends live patient exam requirements for dentistry students; extends expiration dates of commercial driver’s licenses with medical certifications.
Texas
- Suspension of Regulations to Increase EMS, First Responder Workforce – Governor suspends regulations to allow persons with EMS skills but no license to provide emergency care; extends recertification deadlines for EMS workers.
- Press Release: Gov. Abbott Takes Action to Expand Nursing Workforce – Allows graduate nurses and graduate vocational nurses to practice prior to taking the licensing exam; allows students in their final year of nursing school to exceed the 50% limit on simulated clinical experiences; allows inactive and retired nurses to renew their licenses.
- Press Release: Gov. Abbot Waives Certain Licensing Renewal Regulations, Fees For Nurses – Authorizes a six-month grace period for license renewal for licensees of the Texas Board of Nursing.
- Press Release: Gov. Abbot Removes Licensing Barriers For Advance Practice Registered Nurses – Waives reactivation fees and continuing education requirements for advanced practice registered nurses (APRNs) with inactive licenses.
- Press Release: Gov. Abbott Waives Certain Licensing Regulations For Pharmacists, Technicians – Temporarily extends expiration dates for pharmacist, pharmacy technician, and pharmacy technician trainee licenses; suspends continuing education requirements for pharmacists.
- Press Release: Governor Abbott Suspends Regulations To Increase EMS, First Responder Workforce – Allows individuals who are qualified though not formally licensed to provide critical emergency response services; suspends certain skills testing requirements so that both in-state and out-of-state EMS personnel who are qualified but unable to take the skills test may provide services; suspends regulations to allow first responder organizations to delay submission on their renewal application and completion requirements for licensure.
- Press Release: Gov. Abbott Waives License Renewal Late Fees For Certain Occupational Licenses In Texas – Waives license renewal late fees accrued between March 13 and June 15 for occupational licenses issued by the Texas Dept. of Licensing and Regulation.
Vermont
- Dept. of Health Order – Waives requirements for new physician assistant licensees to provide documentation of their supervisory relationship with a physician
- Addendum 9 to Executive Order 01-20 – Clarifies that unlicensed healthcare volunteers may provide COVID-related care, exempt from liability
- Senate Bill 182 – Extends expiration dates of electrician and plumber licenses; loosens licensure requirements for EMTs with prior on-the-job experience (including in the military or national guard); makes EMT licenses valid for three years
- Dept. of Health Order – Waives requirements for new physician assistant licensees to provide documentation of their supervisory relationship with a physician
Washington
- Dept. of Licensing Emergency Rule 20-07-063 – Allows cosmetology schools to offer up to 100% online instruction during pandemic.
- Proclamation 20-32 – “Waives a plethora of healthcare licensure provisions: Waives continuing education requirements and license renewal deadlines for most medical and nursing professions. Waives restrictions on practice by retired active medical, nursing, and mental health licensees. Waives barriers to practice by healthcare provider volunteers. Waives requirements of physician assistants’ practice agreements that limit PA mobility. Waives practice limitations for physicians serving in fellowships or other limited educational/training capacities”
- Dept. of Health Emergency Rule 20-10-014 – Waives nursing continuing education requirements for active retired licensees; waives clinical experience requirement for nurses with inactive or expired licenses; allows licensed practical nurse (LPN) students to practice as nursing technicians; waives restrictions on simulation in educational programs; and streamlines the process of delegation of nursing tasks.
- Dept. of Health Emergency Rule 20-12-077 – Suspends CPR skills demonstration portion of the certification process for medical marijuana consultants.
- Dept. of Licensing Emergency Rule 20-13-061 – Dept. of Licensing-issued occupational licenses set to expire between June 1 and July 15 are extended until August 1.
- Dept. of Health Emergency Rule 20-13-059 – Provides for a non-patient-based clinical exam for dentistry.
- Dept. of Health Emergency Rule 20-14-066 – Modifies training requirements for nursing assistants to make it easier for students to gain sufficient clinical experience and to facilitate delivery of online instruction.
West Virginia
- EO 7-20 – Suspends expiration dates of medical licenses, requirements for physician assistant licensure, requirement that surgeons hold an active, unexpired license, and requirements that boards of certification/registration conduct investigations within a certain timeframe.
- EO 10-20 – Suspends continuing education requirements for healthcare workers.
- EO 11-20 – Waives license renewal fees for respiratory care practitioners.
Wisconsin
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- EO 16 – Extends all temporary medical licenses; suspends license renewal requirements for physician assistants and nurses.
- EO 35 – Extends lapsed ventilator and CPR certifications for registered nurses; exempts new mental health professionals from orientation requirements.
- Pharmacy Examining Board Grant of Variance – Allows individuals to manufacture PPE without a license.
- EO 21 – Waives requirement that EMS training be completed within 2 years before applying for license. Waives CPR training requirement for EMT license renewal. Suspends late fees for EMT license renewal. Allows Dept. of Health Services to extend EMT license expiration date. Expedites recertification/reinstatement of lapsed EMT licenses. Extends renewal deadlines for EMTs’ cardiac life support certifications. Allows EMT training permits to be renewed. Allows nurses with less than 2 years of experience to serve as nurse aide instructors. Suspends requirement that nurse aide instructors complete an approved training course. Suspends 120-hour training minimum for nurse aides (16 hours still required). Suspends some nurse aide supervision requirements.
- Dept. of Safety and Professional Services Emergency Rule SS 059-20 – Allows individuals who have failed an examination for an occupational license with the Dept. of Safety and Professional Services to retake the exam more than a year after failing (normally limited to one year).
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