WHEN USMLE INVALIDATES EXAM RESULTS BASED UPON DATA PATTERNS
Posted September 24th, 2025 by Dennis Abramson.
Categories: ECFMG, Medical Licensing, NBME, NRMP, USMLE.
No one expects to have a passing USMLE score questioned after the fact. For most examinees, receiving an email from the USMLE Secretariat stating that an exam result has been invalidated is an terrifying and confusing development. Passing Step 1, Step 2 CK, and Step 3 is not optional; it is a required condition for entry into residency and for eventual licensure in the United States. An invalidated outcome can therefore have serious and lasting implications for your medical career.
Understanding Score Invalidations under USMLE Policy
Beginning in January 2025, the USMLE adopted Policies and Procedures Regarding the Validity of Passing Level Scores Achieved by a Subset of Examinees. These policies allow the program to cancel a passing score if there is a “good faith basis” to question whether the result reflects a valid measure of knowledge or competence. According to USMLE, this determination is based on forensic and statistical analyses of exam data.
The “Common Questions” document published by USMLE emphasizes that invalidation does not necessarily mean an examinee engaged in irregular behavior. Rather, the program may conclude that the reported outcome is not reliable based on highly improbable performance patterns or other anomalies in the testing record. In the representative email that many examinees now receive, USMLE cites answer similarities and other data trends so unlikely that the probability of their occurring under normal conditions is said to be less than one in one hundred million.
What Happens After Invalidation
The consequences of a score invalidation are significant:
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Suspension: Examinees are automatically suspended from access to all USMLE Step exams for 18 months.
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Transcript Updates: If the invalidated result had been reported, USMLE will issue corrected transcripts to all third parties who previously received your scores.
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Retake Opportunity: After the suspension period, examinees are typically permitted a one-time retake of the invalidated exam at no cost. If the retake is unsuccessful, the examinee faces an additional three-year suspension, and a second failure at that stage results in permanent ineligibility for the USMLE sequence.
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Step 3 Scores: Step 3 results remain listed as “Score Not Available” until valid passing outcomes are in place for both Step 1 and Step 2 CK.
Your Rights After Receiving a Notice
Examinees notified of invalidation are given 15 calendar days to submit a response form. Two paths are available:
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Requesting Reconsideration. An Initial Review Committee made up of staff from USMLE’s sponsoring organizations will evaluate whether your passing outcome should be upheld. If unsuccessful, you may appeal to an ad hoc Appeal Committee appointed by the USMLE Composite Committee. Appeals are limited in scope and must also be filed within 15 days.
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Electing a Retake. An examinee may choose to accept the invalidation and pursue a retake after the suspension concludes.
If you do not respond within the 15-day window, you risk an automatic three-year suspension in addition to the initial 18-month suspension. The notice email also warns that disseminating transcripts containing invalidated results to third parties may itself be treated as irregular behavior, carrying separate disciplinary consequences.
Why This Matters
The impact of a score invalidation goes well beyond the testing program. Residency programs, licensing boards, and (for international medical graduates) ECFMG are all notified when an outcome is revised. This can affect your residency placement, progression through medical school, or eventual ability to obtain a license.
While invalidation does not in itself mean you are being charged with misconduct, the professional consequences are no less real. The choices you make in response to the notice—whether to pursue reconsideration, appeal, or retake—carry risks that should be carefully evaluated.
Seeking Legal Assistance
Because of the strict deadlines, the technical nature of the evidence, and the high stakes involved, many examinees choose to consult counsel familiar with USMLE policies and procedures. An attorney experienced in this area can help review the allegations, assess the strength of a reconsideration request or appeal, and guide you through the process step by step.
If you receive notice that your Step score has been invalidated, it is essential that you act promptly and with a clear understanding of your rights and obligations under the policy.
Our firm has significant experience representing examinees whose test results have been invalidated and/or questions as a result of psychometric similarity data analysis. To the extent you find yourself the subject of an email from USMLE invalidating an examination score, our experienced attorneys stand ready to assist.
