Public Consultation: Regulation Amendments to enhance pathways for international physicians
CPSM requests feedback from the public, registrants, regulated health professions, and other stakeholders regarding three regulation amendments to better support and attract qualified and competent internationally trained physicians, ensuring a fair and efficient pathway for their integration into the Manitoba healthcare system.
- Removing restrictions that delayed American Board-Certified physicians becoming fully licenced registrants;
- Reducing barriers for Provisional Registration of Family Registrants;
- Allowing Clinical Assistants to use the title “Dr.” or “Doctor” in conjunction with “Clinical Assistant” or “Cl.A.”
These amendments will expand opportunities without compromising quality or safety for those eligible to practice medicine in Manitoba.
Background
CPSM protects the public by ensuring registrants have the proper qualifications to practice medicine.
In early 2025, CPSM raised concerns and made recommendations to the Manitoba Government about amending certain provisions of the CPSM General Regulation M.R. 163/2018 that are unnecessarily restrictive and may be limiting qualified professionals applying to practice medicine in Manitoba.
As is outlined below, the proposed changes will increase the number of qualified professionals eligible to apply to practice medicine without compromising public safety.
Amendments to the CPSM General Regulation require a 30-day public consultation.
Proposed Changes
1. American Board-Certified Physicians
The first proposed change will allow all physicians from the United States to apply directly for full (practicing) class if they meet the following requirements:
- have successfully completed a residency program accredited by the Accreditation Council for Graduate Medical Education,
- hold certification from a Member Board of the American Board of Medical Specialists (ABMS), and
- have an independent or full licence to practice with a U.S. state medical board
Currently, these individuals must first apply for provisional registration, which places limitations on their ability to practice medicine (such as requiring supervisors, assessments, and practice location restrictions). These restrictions are costly and time-consuming. They place a significant disincentive on qualified physicians applying to practice medicine in Manitoba.
Rationale
The Canadian Free Trade Agreement (CFTA) entitles physicians who hold an independent practice licence in another Canadian province or territory to apply as a Regulated Member Full Practising class without having to undergo significant additional training, examination or assessment. Accordingly, what is occurring in other provinces is relevant to Manitoba:
- Medical Regulatory Authorities in British Columbia, Saskatchewan, New Brunswick, Prince Edward Island, and Nova Scotia have introduced similar provisions. Quebec has them for family medicine.
- In Ontario, the College of Physicians and Surgeons of Ontario has established alternative pathways for U.S.-trained physicians. Specifically, physicians who have completed an Accreditation Council for Graduate Medical Education (ACGME)-accredited residency and hold certification from an ABMS member board may be eligible for a restricted certificate of registration to practice independently within their scope. This is essentially equivalent to full licensure in Manitoba and has been recognized by CPSM under the CFTA.
- In Alberta, the College of Physicians & Surgeons of Alberta (CPSA) initiated a five-year pilot project as of January 2023, streamlining the Practice Readiness Assessment process for internationally trained physicians from approved jurisdictions, including those with certification from the American Board of Medical Specialties (ABMS) This initiative aims to expedite the integration of qualified U.S.-trained physicians into Alberta's healthcare system. The pilot project waives the first 3-month PRA requirement. Internationally trained physicians go directly to their identified communities and begin practising independently for three years while completing their Supervised Practice Assessment. Successful practice during those three years (as determined by CPSA) allows transfer to the general register without the requirement of Canadian certification in the discipline of practice.
- Physicians who have completed accredited postgraduate training in the United States and hold certification from an ABMS member board may be eligible for provisional licensure in Newfoundland and Labrador.
While specific studies directly comparing the safety and competence of American Board-certified physicians practicing in Canada to their Canadian-trained counterparts are limited, it is generally accepted that, as a category, these physicians are competent and safe practitioners.
CPSM’s approach to ensuring safe practice is to address individual practitioners rather than imposing blanket requirements for all as a means of ensuring these individual physicians are practicing medicine safely. They will, within the first year of practice in Manitoba, be required to participate in a Quality Assurance audit process.
We also recognize there are challenges for all internationally trained registrants who have recently come to Manitoba in adjusting to the practice of medicine in the province. As such, by the end of 2025, CPSM plans on implementing an orientation program for all International Trained Physicians who are new to the Canadian or Manitoba practice
2. Reducing barriers for Provisional Registration of Family Registrants
Provisional registration is granted to physicians who meet some but not all requirements for full practicing registration. A registrant who is provisionally registered will be entitled to practice medicine with certain limits and conditions at a geographic location approved by the Minister of Health. Conditions include the need for supervision and practice audits. A provisional registrant will have five years to attain all the requirements for full registration.
The CPSM General Regulation lists the requirements an individual must have to apply for provisional registration. There are multiple pathways for registration in the provisional (family practice-limited) class, one of which is that the applicant has completed at least one year of post-graduate clinical training in family medicine and has “at least three years of practice experience in family medicine in the preceding five-year period.” Candidates who follow this route to provisional registration will typically require a Workplace-Based Assessment (i.e., a Practice Readiness Assessment through the Manitoba Faculty’s International Medical Graduate (IMG) Program).
Rationale
The prerequisite of having at least three years of practice in family medicine in the preceding five-year period to apply for provisional registration was separately reviewed by the Manitoba Faculty and CPSM’s Board of Assessors (which was established to consider complex registration applications). They recommended the prerequisite be amended to “a total of at least 960 hours of direct patient clinical practice experience in family medicine in the preceding 36 months.” This is approximately equivalent to six (6) months of practice in the past three years.
CPSM and the Manitoba Faculty believe that these changes will increase the number of individuals who meet the registration requirement and Practice Ready Assessment eligibility, and at the same time improve the likelihood that they will successfully complete the requirements of provisional registration.
3. Allowing Clinical Assistants to use the title “Dr.” or “Doctor” in conjunction with “Clinical Assistant” or “Cl.A” when they have a medical degree from a nationally approved faculty of medicine in another jurisdiction
Clinical Assistants are CPSM registrants who have a critical role in the delivery of health care in Manitoba. Many have a medical degree from a nationally approved faculty of medicine in another jurisdiction or, in some cases, Canada. However, those with medical degrees are not entitled to use the title “Dr.” or “Doctor” in the practice of medicine, even though they were previously able to use the title while in residency in Canada, or as a practicing physician in another country.
Other health care professionals who may use the “Dr.” or “doctor” title in Manitoba, in conjunction with identifying their profession include optometrists, dentists, chiropractors, and naturopaths.
Rationale
The proposed change would favorably enhance the Manitoba practice environment by recognizing this class of professionals’ credentials through appropriate dignity and respect. Associate Physicians and Clinical Assistants can use the title in other jurisdictions, including British Columbia, Alberta, and Saskatchewan.
It must, however, be clear that use of the title is in conjunction with the Clinical Assistant title. This is to avoid confusion that they are licensed and practicing as a physician or surgeon. An example of how this will be used is “Dr. Smith (Clinical Assistant).”
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Request for feedback
CPSM seeks your thoughts and perspectives on these three proposed changes to the CPSM General Regulation.
Questions to consider:
Do the amendments remove unnecessary impediments for qualified individuals applying to practice medicine in Manitoba?
Do these changes negatively impact patient safety?
Or are the current regulatory requirements appropriate?
View the proposed regulatory changes
View a “side by side” comparison of the current regulation to the proposed changes
How to submit your feedback
- Review the proposed regulatory changes and details for each proposed change above.
- Submit your comments in writing by email to: CPSMconsultation@cpsm.mb.ca
The deadline for feedback is 11:59 p.m. on May 25.