Mid adult female patient being assisted by physical therapist while doctor applauding

The Foreign Credentialing Commission on Physical Therapy (FCCPT) has announced that USCIS has re-authorized it to issue Health Care Workers Certificates (also known as VisaScreens).

In connection with the re-authorization process, FCCPT has revised its requirements for the Type I Certificate. In its announcement, FCCPT stated the following:

Effective April 1, 2017, FCCPT will consider the education of foreign-educated PTs comparable to or substantially equivalent to the U.S educated PT if the education demonstrates the following:

1. Post-bachelor’s degree: The first professional degree in physical therapy must be a bachelor’s degree or higher. If the first professional degree is a bachelor’s degree, the candidate must also possess a Master’s degree or higher in any subject. Transitional DPT (tDPT) post-professional degrees offered by regionally-accredited universities that also have a CAPTE-accredited professional DPT program will be accepted as post-bachelor’s degrees.
2. Meets CWT6 Requirements: The education meets the content requirements of the Coursework Tool 6 (CWT6); and
3. Minimum Credits – 210: The education (general + professional education) possesses a minimum of the equivalent of 210 U.S. semester credits. The professional education component of the education must contain a minimum of 90 credits. (These credit requirements do not apply to application for licensure).

The April 1, 2017 effective date applies to all Type I services currently “In Review” or “Pending”, and all new applications for the Type I Reviews received on or after April 1st. It does not apply to renewals.

Interestingly, the new standard represents a marked modification of the standard that FCCPT announced last fall that it would be using effective January 1, 2017.

Last fall, FCCPT said that a of January 1, 2017, FCCPT would require all foreign-educated Physical Therapists to possess a Doctor of Physical Therapy and 234 total semester credits. FCCPT claimed it was forced to do this by USCIS in order to be re-certified.

When asked about this by the American Immigration Lawyer’s Association (AILA), USCIS denied it forced FCCPT to go to the Doctoral degree standard. In doing so, it stated the following:

When it comes to the licensing requirements for physical therapists, USCIS relies on subject matter experts such as CAPTE. CAPTE indicates that as of January 1, 2016, the DPT is required for U.S. physical therapists entering the occupation. However, despite FCCPT’s statement, USCIS did not require that FCCPT apply a specific minimum standard for the number of credit hours required for finding equivalency to U.S. Masters and Doctoral degrees in Physical Therapy when evaluating the credentials of foreign-educated physical therapists. Nor did USCIS mandate that FCCPT reject any Type I certificate application where the applicant submits a physical therapy degree with the title of “Bachelor’s;” Moreover, USCIS did not require FCCPT to defer to a degree title in their analysis. USCIS has issued a request to FCCPT asking them to remove this statement from their website. As we do not control third party websites, the USCIS website is the best place to find USCIS guidance. The credit hours referred to in our notice to FCCPT were obtained from a CAPTE report and were cited as a point of reference as to why our agency questioned lower existing standards used by FCCPT in the CWT5 and CWT6 coursework evaluation tools. However, USCIS has accepted FCCPT’s revised standards as responsive to our concerns relating to the CWT5 and CWT6 tools, and we will continue to work to ensure that foreign-educated physical therapists have a comparable level of education, training and experience to what is required for physical therapists educated in the U.S. based on the evidence in each individual record.

USCIS was also asked by AILA if it had asked CGFNS to follow these standards. USCIS responded: “as explained above, the standards referenced in FCCPT’s statement were not mandated by USCIS.”

Finally, when asked by AILA about the rationale for requiring evaluators to defer to the degree title, rather than permitting a review of the degree and courses completed for substantial equivalency to the first professional degree requirement, USCIS responded: “USCIS did not mandate that FCCPT defer to the degree title when evaluating the credentials of foreign-educated physical therapists.”

Clearly there is a disagreement about who was the driving force behind this change. Nonetheless, we welcome the lower standard and the decision not to go all the way to the DPT standard for the time being.