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Warner Norcross + Judd LLP is a corporate law firm with over 230 attorneys serving clients in nine offices throughout Michigan. Among the largest law firms in Michigan, Warner works in virtually all areas of business law.

Michigan Law Firm - Warner Norcross + Judd LLP

For hospitals and health systems seeking to recruit talented physicians, navigating J-1 waiver programs is essential. Foreign physicians who have completed a training program in the U.S. must either return to their home country for two years or obtain a waiver of the foreign residency requirement.

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The two key routes for securing this waiver in Michigan are the Conrad-30 program and the federal Health and Human Services (HHS) Clinical-Care waiver. Michigan’s Conrad-30 program opened on Sept. 1 with a limited number of physician waiver slots, while the federal HHS clinical-care waiver is open year-round with no numerical cap. Understanding these programs can help hospitals and health systems plan and compete for top talent in a challenging recruitment environment.

Michigan’s Conrad-30 program allows the state to recommend up to 30 J-1 waiver applications each year. Applications for the 2025-2026 cycle opened on Sept. 1, and will remain open through Nov. 1, with a potential second round if slots remain open.

To qualify under Michigan’s Conrad-30 program, physicians must:

Commit to three years of full-time clinical service at a site located in, or serving, a Health Professional Shortage Area (HPSA) or Medically Underserved Area/Population (MUA/MUP).

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Begin employment within 90 days of receiving the waiver approval.

Have a valid employment contract. Michigan discourages the use of noncompete clauses and restrictive covenants.

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Michigan generally prioritizes primary care specialties such as family medicine, general internal medicine, pediatrics, OB/GYN and psychiatry. However, slots are available for sub-specialists depending on state work-force needs. Because slots can be competitive, early planning is essential.

<strong>HHS Clinical-Care Waivers</strong>

The federal HHS Clinical-Care waiver offers a year-round alternative with no cap on the number of waivers granted annually, making it especially valuable for hospitals that either miss the state filing window or do not qualify under a specialty restriction.

To qualify under the federal HHS Clinical-Care program, physicians must:

Complete their residency within the 12 months immediately preceding the commencement of employment under the employment contract.

Commit to three years of full-time clinical service at a site located in or serving a HPSA with a score of 7 or higher.

Practice family medicine, general internal medicine, pediatrics, OB/GY or psychiatry.

Because the HHS program runs continuously, it provides greater flexibility for hospitals and health care systems.

Hospitals hiring Canadian physicians should be aware of one unique advantage: Canadian citizens can enter the U.S. in H-1B status while their J-1 waiver application is pending and without first receiving approval of their J-1 waiver. This allows Canadian physicians to begin serving patients in an underserved area, giving hospitals immediate relief while the waiver process moves forward.

<strong>Next Steps for Employers</strong>

Employers considering J-1 physician hires should begin by confirming the eligibility of their practice site and drafting contracts that meet state and federal requirements. For Michigan’s Conrad-30 program, packets should be prepared for the Sept. 1 to Nov. 1 window, while eligible primary care and psychiatry candidates can take advantage of an HHS filing.

Our team can help determine the most effective pathway, prepare compliant contracts and supporting documentation, oversee submissions to MDHHS or HHS and manage the subsequent H-1B process, while also advising on compliance and reporting throughout the three-year service obligation.

Talent Without Borders

Senior Counsel

Sarah R. Bileti

Associate

Christopher M. LeClair

Daniel C. “Dan” Persinger

Immigration

Michigan Conrad-30 and HHS Clinical-Care Waivers: Key Options for Hiring J-1 Physicians in 2025-2026

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Michigan Conrad-30 and HHS Clinical-Care Waivers: Key Options for Hiring J-1 Physicians in 2025-2026

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