Announcement Regarding Emergency Licensing Provisions for COVID-19 (updated 3/25/2022)
Please note: this applies to only the professions licensed by the Board of Medical Practice (MD, PA, DPM, AA, and RA). Members of professions regulated by the Office of Professional Regulation (e.g., DOs, APRNs, and Naturopaths) should contact OPR.
Deemed Licensure for Health Care Professionals Licensed in Other States
By virtue of Act 85 of 2022, through June 30, 2023, health care professionals who are licensed in another U.S. jurisdiction and in good standing in all states where licensed, and who are not currently subject to disciplinary proceedings in another state or barred from practice in Vermont, are able to practice in Vermont for up to six months without obtaining a license, in the following circumstances:
- Practice as part of the staff of a licensed facility
- Practice at a Federally Qualified Health Center
- Practice as a volunteer with the Medical Reserve Corps (MRC)
Those who are practicing with the MRC or as staff of a licensed facility or FQHC must have the organization submit to the Board their name, contact information, and locations at which they will be practicing. This authority applies until June 30, 2023, so long as the individual remains in good standing in all jurisdictions where licensed to practice, however, for all but those practicing with the MRC, it may be used for only six months after the date of enactment, March 22, 2022.
After relying on this provision for a period of six months that begins on or after March 22, 2023, the health care professional must obtain a license to continue practice in Vermont. This means that someone who was practicing as of March 22, 2022 and who continues to practice may rely upon this provision until September 22, 2022. Someone who begins practice in Vermont on January 1, 2023, may practice until June 30, 2023. Someone who begins practice after January 1, 2023 may practice under this authority only through June 30, 2023, not for the full six months. The only exception to the six-month limitation is for those who limit practice to the MRC. The provisions of Act 85 of 2022 that allow practice without a license as described above are at pages 7 through 9 of the law.
Deemed Licensure for Vermont Physicians Whose License Became Inactive within the Past Three Years
Health care professionals whose Vermont licenses became inactive within the past three years and who were in good standing also have been, and continue to be, eligible to be “deemed” licensed to practice until June 30, 2023 in the same circumstances as listed above: with the MRC or as staff of a licensed facility or FQHC. If you began practicing in Vermont under this authority within three years of the date on which you no longer held an active license and have continued to practice, you will remain eligible to practice through June 30, 2023, so long as all other conditions are still satisfied. That is to say that you have not been subjected to discipline or barred from practice in Vermont. The extension of the provision that allows those whose licenses became inactive within the past three years to be deemed to be licensed to practice are found at pages 10-11 of Act 85 of 2022.
Emergency Licensure for Health Care Professionals Whose Vermont Licenses Became Inactive Between Three and Ten Years Ago
Health care professionals whose Vermont license became inactive more than three years ago are not able to be “deemed” licensed as described just above. However, those whose Vermont licenses became inactive between three and ten years ago may apply for a temporary emergency license to practice with the MRC or as staff of a licensed facility or FQHC. They must fill out an abbreviated application, which will be reviewed by the Board. Limitations may be placed on such licenses. Licenses obtained under this provision may also be extended through June 30, 2023, as provided by Act 85 of 2022 at page 11.