Non-Standard Training (NST) Programs

Scope

This policy applies to all Indiana University School of Medicine (IUSM) Graduate Medical Education (GME) programs that are not ACGME accredited or ABMS certified but will provide training to trainees on J-1 visas. 

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Policy Statement

The ACGME offers Recognition to Sponsoring Institutions that have non-standard training (NST) programs. NST programs provide clinical training for international medical graduates (IMGs) in advanced subspecialty programs for which there is no ACGME accreditation or American Board of Medical Specialties member board certification.

IMGs receive J-1 visas sponsored by the Educational Commission for Foreign Medical Graduates (ECFMG) to enable their participation in NST programs. NST Recognition will be conferred upon Sponsoring Institutions only and will not be conferred upon individual NST programs.  Failure to abide by ACGME requirements for NST programs may result in ECFMG sanctions being placed on the institution. 

Institutional Responsibilities

IUSM must ensure the availability of adequate personnel, clinical activities, and other resources for conducting NST programs without adverse impact on the education of trainees in the Sponsoring Institution’s ACGME-accredited programs.  Additionally, IUSM and each of its NST programs must provide a learning and working environment in which NST trainees have the opportunity to raise concerns and provide feedback without fear of intimidation or retaliation and in a confidential manner as appropriate.

IUSM must sponsor an ACGME-accredited program in the most closely related specialty/subspecialty for each NST program. That program must maintain a status of Continued Accreditation or Continued Accreditation with Warning.

IUSM must ensure that NST trainees are provided with a written agreement outlining the terms and conditions of their appointments. The agreement must directly contain or provide a reference to the following items:

• NST trainee responsibilities, including any requirements for successful completion of the NST program;
• duration of training;
• financial arrangements related to the NST trainee;
• grievance and due process;
• professional liability coverage, including a summary of pertinent information regarding coverage;
• the availability of health insurance benefits for NST trainees and their eligible dependents; and
• vacation and leaves of absence for NST trainee(s), including medical, parental, and caregiver leaves of absence, and compliance with applicable laws.

IUSM must monitor each of its NST programs with regard to implementation of terms and conditions of the agreement.

GMEC Responsibilities

The GMEC must review and approve the program description of each NST program within the Sponsoring Institution. Additionally, the GMEC must review and approve the appointment of each of its NST program directors.

At least annually, the GMEC must complete and document an assessment of supervision and assessment of NST trainees.

At least annually, the GMEC must complete and document the impact of NST programs on the Sponsoring Institution’s ACGME-accredited programs.

Program Responsibilities

NST trainees’ assignments/rotations must be limited to the participating sites of the most closely related ACGME-accredited program, as identified by the Sponsoring Institution and listed in the ACGME Accreditation Data System (ADS).

Each NST program must define the prerequisite education and/or training for entry into the NST program and must ensure that NST trainees appointed to the NST program meet prerequisites for entry into the NST program.

The NST program must make available to NST trainees and faculty members a curriculum that includes:

• overall educational goals for the NST program;
• delineation of NST trainee responsibilities for patient care, responsibility for patient management, and supervision during the NST program; and
• a description of required educational experiences, didactic sessions, assessment methods, and procedural experience requirements.

NST Trainee Assessments

No later than three months after the trainee’s starting date in the NST program, each program director must complete an initial competence assessment of each trainee in the NST program, including an ACGME Milestones assessment from the most closely related ACGME-accredited specialty or subspecialty.

• A supervising faculty member must be physically present to supervise the NST trainee with all patients until the NST program director has documented the NST trainee’s ACGME Milestones achievement as a sufficient basis for delegating progressive authority and responsibility and conditional independence, as assigned by the NST program director and faculty members.
• For each NST trainee appointed to an NST program for one year or longer, the NST program director or the NST program director’s designee must meet with the NST trainee to review a semi-annual evaluation of the NST trainee’s performance.
• Programs that fail to assess NST trainees as described above may not be allowed to onboard J-1 trainees in the future. The GMEC may review the eligibility of any program not meeting these requirements.

Each NST program director must provide a summative evaluation for each NST trainee upon the NST trainee’s completion of, or separation from, the NST program.

Clinical and Educational Work Hours

Clinical and educational hours of NST trainees must be limited to no more than 80 hours per week, averaged over a four-week period, inclusive of all in-house clinical and educational activities, and clinical responsibilities completed at home.

NST trainees must be scheduled for a minimum of one day in seven free of required clinical and educational responsibilities (when averaged over four weeks). At-home clinical responsibilities cannot be assigned on these free days.

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Reason for Policy

The purpose of this policy is to define procedures for programs without ACGME accreditation or ABMS certification to seek Non-Standard Training (NST) Recognition in advance of training an international medical graduate (IMG) who will train on a J-1 visa. 

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Procedures

New NST Program Application

IUSM must provide information for each of its NST programs in the ACGME’s Accreditation Data System (ADS). In order to provide complete and accurate information, any non-ACGME accredited program hiring a J-1 visa trainee must complete the IUSM NST Program Application. The application will then undergo the following process:

• The completed form should be submitted to the Assistant Director for Accreditation, who will add the form to the subsequent GMEC Executive Committee agenda.
• The GMEC Executive Committee will review the application against the ACGME’s requirements.
• If the application adequately meets those requirements, the application will then be presented to the GMEC for review and approval.
• NST programs approved by the GMEC will then be entered into the ACGME ADS by the Assistant Director for Accreditation.

The ACGME will process the application and add the program to Intealth so that the institution can seek the proper J-1 documentation from the ECFMG.

GMEC Oversight

The GMEC will provide oversight of the following:

• Assessments: The Assistant Director for Accreditation will present an annual report to the GMEC that details which non-ACGME programs had J-1 trainees and the dates that initial and final (and if applicable, semi-annual) evaluations were conducted.
• Work Hours: All IUSM programs (both ACGME-accredited and non) are required to submit trainee work hours in MedHub. These are reviewed by the Assistant Director for Accreditation quarterly, and programs that are substantially non-compliant are discussed with the GMEC Executive Committee.

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Definitions

A traineetrainee is an IUSM resident or fellow who provides clinical care as part of a GME program. 

ACGME is the Accreditation Council for Graduate Medical Education. 

ABMS is the American Board of Medical Specialties.

NST is Non-Standard Training, which is defined as training provided by a program for which there is no ACGME accreditation or American Board of Medical Specialties member board certification.

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Implementation

The Designated Institutional Official (DIO) for GME is responsible for implementation of this policy.   

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Oversight

Policy authority for this document resides with the Graduate Medical Education Committee. The DIO and the Graduate Medical Education Committee are responsible for oversight. This policy will be reviewed every three years or more often if deemed necessary. 

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Forms

IUSM NST Program Application

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History

1. gme-adm-0053, 11 March 2026, first draft of policy.
2. Policy approved by GMEC 18 March 2026.

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