The Maryland Department of Health (MDH) released an updated policy manual at the end of September for the 2025 Conrad 30 Waiver Program application cycle, which opened October 1st. Changes include an online-only submission process, flexibility for the three-providers- per-practice-site limitation, and guidance regarding telehealth. The Conrad 30 program is one avenue for an immigrant physician to obtain a waiver of the two-year home residency requirement and help alleviate the physician shortage in the United States. (For an overview of the J-1 Clinical Waiver, click here. For an overview of changes implemented in 2022 by the MDH, click here.)
The MDH’s changes for FFY 2025 are welcomed by both employers and physicians. There are three key amendments to the policy manual.
First, the MDH has set forth guidelines for the provision of medical services via telehealth by a J-1 waiver physician within the state. Many patients find it burdensome to travel to a physician in person, whether due to lack of transportation options, limited mobility or other reasons. In addition, federal law requires that at least 20 of the 30 selected physicians practice exclusively at facilities in federally designated shortage areas.
Despite the prevalence of telemedicine during the COVID-19 pandemic and the benefits of extending care options to underserved communities, federal law continues to be silent regarding the use of telemedicine by J-1 physicians completing their Conrad 30 service period. In 2020, the U.S. Citizenship and Immigration Service (USCIS) issued temporary guidance allowing J-1 physicians completing waiver service terms in H-1B status to provide telehealth through the facilities at which they had been approved to work to patients located in the same state as that facility. This expansion automatically expired with the federal Public Health Emergency for COVID-19 on May 11, 2023.
With its new guidance, the MDH expressly permits approved J-1 waiver physicians to provide telehealth services during their Conrad service period, with the following stipulations:
- The employment agreement or contract must expressly include telehealth.
- The majority of the direct patient care hours must be provided in person.
- Telehealth services must be provided from a location within Maryland, in accordance with state and federal regulations.
Allowing telehealth increases the attractiveness of physician employment within the state.
Second, the MDH is implementing a new online submission process that is expected to facilitate the review and recommendation of applications by the U.S. Department of State, which hopefully will reduce processing times.
Third, if the MDH receives fewer qualified applicants than available waiver slots, employers may be able to secure the services of greater than three waiver physicians per practice site. This flexibility will be especially beneficial to patients of large regional centers and newer facilities looking to rapidly expand services.
With the expansion of the HHS Clinical Service Waiver program, competition for Maryland Conrad 30 waiver slots has decreased; nonetheless, from federal fiscal year 2020 to the present, the MDH used nearly all of its slots annually. The FFY 2025 application period will close Dec. 1. Considering this deadline, employers and physician candidates should prepare waiver applications as soon as possible.
Opinions and conclusions in this post are solely those of the author unless otherwise indicated. The information contained in this blog is general in nature and is not offered and cannot be considered as legal advice for any particular situation. The author has provided the links referenced above for information purposes only and by doing so, does not adopt or incorporate the contents. Any federal tax advice provided in this communication is not intended or written by the author to be used, and cannot be used by the recipient, for the purpose of avoiding penalties which may be imposed on the recipient by the IRS. Please contact the author if you would like to receive written advice in a format which complies with IRS rules and may be relied upon to avoid penalties.
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