Licensure Pathways for Internationally Educated Nurses in the United States (2026 Outlook)

Summary
The United States healthcare sector is currently navigating a protracted workforce crisis, characterized by a widening gap between the supply of domestic nursing professionals and the escalating demand driven by an aging demographic and expanded healthcare access. As we move through 2026, the reliance on Internationally Educated Nurses (IENs) has transitioned from a supplementary staffing strategy to a structural necessity for American healthcare resilience. For foreign-trained Registered Nurses (RNs), the United States represents the apex of professional opportunity, offering competitive remuneration, advanced clinical specialization, and career mobility. However, the path to entry is guarded by a complex, fragmented regulatory apparatus comprising over 50 distinct jurisdictions, each with sovereign authority over licensure requirements.
This report provides an exhaustive, expert-level analysis of the optimal entry points—colloquially termed the "easiest" states—for IENs to secure their initial US nursing license in 2026. "Ease" in this context is strictly defined by regulatory accessibility for applicants who typically lack a US Social Security Number (SSN) at the time of application, may require flexibility regarding English proficiency testing during the initial licensure phase, and seek transparent, efficient credential evaluation processes. Based on a rigorous synthesis of current regulatory statutes, processing metrics, and administrative protocols, this analysis identifies New York, Montana, Texas, Illinois, and New Mexico as the primary strategic gateways for IENs. Furthermore, the report examines the Northern Mariana Islands as a critical tactical jurisdiction for "Score Transfer" methodologies.
The analysis delves into the microscopic details of the application procedures, financial implications, and timeline expectations for each jurisdiction. It further explores the second-order effects of these pathways, including the implications of the Nurse Licensure Compact (NLC), the interplay between state licensure and federal immigration requirements (VisaScreen), and the long-term career mobility afforded by each state's license. This document serves as a comprehensive operational manual for IENs, recruitment agencies, and policy analysts navigating the US nursing regulatory landscape in 2026.
1. The Macro-Regulatory Environment of US Nursing
To accurately navigate the licensure process, one must first understand the idiosyncratic nature of the US regulatory framework. Unlike the centralized healthcare systems common in the UK (NMC), Canada (provincial but coordinated), or Australia (AHPRA), the US system is federalized. The authority to license nurses rests exclusively with the individual states, not the federal government. This results in a patchwork of requirements where a nurse qualified in New York is not automatically qualified in California.
1.1 The Triad of Licensure Requirements
For an IEN in 2026, the licensure equation is composed of three non-negotiable variables, although the timing and specific proof required for each vary by state:
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Educational Equivalency: The state must verify that the applicant’s foreign nursing education is substantially equivalent to a US nursing degree. This is almost exclusively outsourced to private Credential Evaluation Services (CES) such as CGFNS International, ERES, or Josef Silny & Associates.1 The rigor of this evaluation varies; some states require a simple document verification, while others mandate a granular course-by-course analysis of theory and clinical hours (e.g., California’s strict requirements on concurrent clinicals).2
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English Proficiency: While English is the language of US healthcare, states differ on when and how this competency must be proven. Some states mandate passing scores on exams like the TOEFL iBT or IELTS Academic before eligibility to take the NCLEX is granted. Others, most notably New York, operate under the presumption that passing the NCLEX-RN (an English-language technical exam) demonstrates sufficient proficiency for licensure, deferring the formal language test until the federal immigration stage.3
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Identity and Security (The SSN Bottleneck): This is the single most significant barrier for IENs. Most states utilize the Social Security Number (SSN) as a primary identifier for professional registries and background checks. However, the US Social Security Administration issues SSNs only to individuals with work authorization. This creates a regulatory paradox: an IEN needs a license to get a job offer (and visa), but needs a visa (and SSN) to get a license. The "Top 5" states identified in this report are distinguished primarily by their solution to this paradox—typically through the use of affidavits, waivers, or paper-based application workarounds.4
1.2 The Nurse Licensure Compact (NLC)
The strategic value of a state license is heavily influenced by the Nurse Licensure Compact (NLC). The NLC is an interstate agreement allowing a nurse to hold one "Multistate License" (MSL) in their home state and practice in all other Compact states without additional licensure. As of 2026, over 40 jurisdictions are NLC members.6
The IEN Residency Limitation:
It is critical to clarify a common misconception: obtaining a license in a Compact state (e.g., Montana or Texas) does not automatically grant an IEN a Multistate License. The NLC rules mandate that a nurse must declare a Primary State of Residence (PSOR) within a Compact state to be eligible for an MSL. "Residence" is legally defined by tax returns, voter registration, or a driver's license. An IEN applying from abroad has no US residence; therefore, even if they apply to a Compact state, they will initially receive a Single State License. The strategic advantage of applying to a Compact state lies in the future: once the IEN immigrates and establishes residency in that state, the license can be converted to an MSL, granting immediate access to a massive labor market. Conversely, a license from a non-Compact state (like New York) remains valid only in that state, requiring endorsement applications (and fees) to practice elsewhere.
1.3 The Role of Third-Party Evaluators
State Boards do not have the internal capacity to interpret transcripts from global institutions. They rely on approved vendors. The selection of a vendor is a strategic decision for an IEN.
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CGFNS International: The gold standard and accepted by virtually all states.
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Josef Silny & Associates: Accepted by specific states (e.g., Montana, New Mexico,). Known for significantly faster processing times but stringent on translation requirements.10
- ERES (Educational Records Evaluation Service): A viable alternative accepted by states like Illinois and Texas, offering a middle ground in speed and cost.1

2. Strategic Analysis: New York (The Global Gateway)
Accessibility Ranking: #1
Compact Status: Non-Compact (Pending Legislation)
SSN Requirement: None for Licensure
English Exam: Not Required for Licensure
New York State maintains its position in 2026 as the preeminent entry point for Internationally Educated Nurses. The New York State Education Department (NYSED), specifically the Office of the Professions, has engineered a regulatory framework that effectively decouples professional licensure from immigration status. This approach allows IENs to secure a prestigious US nursing license strictly on the merit of their education and examination performance, without the prerequisite of a US social security number or immediate English proficiency testing.2
2.1 The "No SSN" and "No English Exam" Policy
New York’s most distinct advantage is the absence of an English proficiency exam requirement for licensure. Unlike boards that mandate an overall IELTS band of 6.5 or a TOEFL score of 83 prior to issuing an Authorization to Test (ATT), NYSED relies on the applicant's ability to pass the NCLEX-RN as the definitive proof of language competence required for safe practice.3 This allows IENs to focus their cognitive resources exclusively on clinical preparation for the NCLEX.
Furthermore, New York is one of the few jurisdictions that explicitly processes applications without an SSN. The application form allows foreign candidates to bypass this field, and the licensure database assigns a dummy identifier until the nurse eventually immigrates and provides a real SSN. This policy eliminates the circular dependency that blocks entry in stricter states.5
2.2 The Credential Verification Service (CVS)
New York utilizes a specialized verification product from CGFNS known as the Credential Verification Service for New York State (CVS). It is imperative to distinguish this from the standard "CES Professional Report" used by other states.
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The Mechanism: The CVS is strictly a verification of authenticity. CGFNS collects the transcripts and license validations from the source to confirm they are genuine. CGFNS does not evaluate the content for equivalency; they simply package the authenticated documents and transmit them to NYSED.
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The Evaluation: The actual comparison of the foreign curriculum against New York’s nursing standards is performed internally by NYSED staff. This two-step process (CGFNS authenticates -> NYSED evaluates) contributes to the state's longer processing timelines but ensures a standardized interpretation of foreign credentials by state officials.11
2.3 Mandated State-Specific Coursework
While New York is lenient on English and SSN, it is rigid regarding public health mandates. All applicants, regardless of experience, must complete two specific state-approved training modules:
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Child Abuse Identification and Reporting: This coursework (Form 1CE) is mandated by NY Social Services Law. It trains nurses to recognize physical and behavioral signs of abuse and understand their legal duty as mandated reporters.12
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Infection Control and Barrier Precautions: Mandated by the NY Department of Health, this training covers the transmission of bloodborne pathogens (HIV, HBV, HCV) and sepsis prevention.3
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Accessibility: These courses are widely available through NYSED-approved online providers. They are relatively inexpensive (typically under $50 combined) and can be completed remotely from any country.3
2.4 The Application Lifecycle and Timeline
The primary drawback of the New York pathway is the timeline. Due to the sheer volume of global applicants and the internal evaluation process at NYSED, the cycle is lengthy.
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Step 1: Submit Form 1 (Application for Licensure) online at the NYSED portal. Fee: $143.
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Step 2: Apply for CVS
CVS via CGFNS (Optional): $425
CGFNS collects documents from your nursing school and licensing authority.
Direct NY BON Application: CVS is no longer required and may reduce processing time.
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Step 3: Complete the Child Abuse and Infection Control courses online.
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Step 4: Wait. Once CGFNS transmits the report, NYSED review can take 2 to 3 months.
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Step 5: Receive Authorization to Test ( ATT) via email and register with Pearson VUE.
NCLEX Fee: $200 + applicable taxes
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Step 6: Pass the NCLEX to receive your New York RN license.
No digital license copy available.License can be verified via NY BON website or Nursys. Physical certificate is mailed (international delivery may take time)
2.5 Strategic Implications
For an IEN who has not yet taken an English test (IELTS/OET) and is willing to wait, New York is the optimal choice. The license is highly respected and can be endorsed to other states later. However, the nurse must understand that they will eventually need to pass an English exam to obtain the VisaScreen certificate required for a US visa. The NY pathway simply allows them to sequence the difficult NCLEX exam before the English exam.1
3. Strategic Analysis: Montana (The Efficiency Leader)
Accessibility Ranking: #2
Compact Status: NLC Member
SSN Requirement: Waiver Available
English Exam: Required (Exemptions for English-speaking countries)
Montana offers a compelling alternative to New York for applicants prioritizing speed and future Compact mobility. The Montana Board of Nursing has streamlined its processes to welcome IENs, distinguishing itself with rapid turnaround times and acceptance of faster credential evaluation services.13
3.1 The SSN Waiver Protocol
Montana law technically requires an SSN for licensure to comply with child support enforcement regulations. However, the Board acknowledges the plight of international applicants and provides a formalized SSN Affidavit/Waiver.
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Process:.During the online application process, the applicant simply declares that they do not currently have a U.S. Social Security Number.
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Effect: The Board processes the application as normal. Upon passing the NCLEX, the license is issued. The nurse is legally required to provide the SSN only after they arrive in the US and are issued one.14
3.2 Accelerated Credential Evaluation
Unlike New York, which forces the internal review bottleneck, Montana accepts the CES Professional Report from either CGFNS or Josef Silny & Associates.10
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The Silny Advantage: Josef Silny & Associates is renowned for speed. Silny can often complete an evaluation in weeks, provided the transcripts are received directly and are in order. For an IEN rushing to get an ATT, choosing Montana and using Josef Silny is a high-velocity strategy.
3.3 English Proficiency and Exemptions
Montana generally requires proof of English proficiency but provides multiple exemption pathways. The English exam is waived if the nurse’s entry-level nursing education was completed in recognized English-speaking countries such as the United Kingdom, Australia, Canada (except Quebec), or New Zealand.
Additionally, an applicant may not be required to take an English proficiency exam if their nursing education and textbooks were conducted entirely in English, subject to Montana Board of Nursing review and approval.
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Non-Exempt: Applicants from non-exempt countries (e.g.,India, Nigeria) must submit passing scores from TOEFL, IELTS, or similar exams. This adds a step compared to NY, but the speed of processing often compensates for the time spent testing.15
3.4 Fingerprinting Logistics
Security checks are a friction point in Montana. The state requires a fingerprint-based background check.
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Logistics: The Board mails physical fingerprint cards to the applicant. The applicant must take these cards to a local police station or embassy in their home country to have their fingerprints "rolled" in ink.
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Submission: The completed cards, along with a fee (typically $30), are mailed back to the Montana Department of Justice. This physical mail process can introduce delays depending on international postal reliability.10
3.5 Operational Data
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Application Fee: $100 for Licensure by Exam.
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Processing Time: The Board targets a 30-business-day turnaround once all documents (CES, Fingerprints, Application) are received. This is significantly faster than New York or California.13
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Renewal: Licenses must be renewed every two years. In 2026, Montana has eliminated mandatory continuing education (CE) hours for renewal, further simplifying maintenance.18
4. Strategic Analysis: Texas (The High-Volume Hub)
Accessibility Ranking: #3
Compact Status: NLC Member
SSN Requirement: Online Application Workaround
English Exam: Required (Strict cutoffs)
Texas is a powerhouse in the US healthcare market, hosting massive medical centers in Houston, Dallas, and San Antonio. The demand for nurses is insatiable. The Texas Board of Nursing (BON) is IEN-friendly but operates with strict procedural gates that must be navigated precisely.2
4.1 The "Online Application" Strategy
Texas has moved to a sophisticated online "Nurse Portal" for domestic applicants.
The Workaround: IENs without an SSN must submit an Online Application for Licensure by Examination.
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Implication: Applicants must ensure every field is legible and correct to avoid mail-back rejections.The Texas Board of Nursing has long required all applications to be submitted online, regardless of U.S. Social Security Number status.19
4.2 The Nursing Jurisprudence Exam (NJE)
Texas is unique among the "easy" states in requiring a separate licensure exam in addition to the NCLEX.
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The Exam: The Texas Nursing Jurisprudence Exam (NJE) tests knowledge of the Texas Nursing Practice Act and Board Rules.
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Format: It is a 50-question, 2-hour exam.
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Accessibility: Crucially, this exam is online and open-book. Applicants can (and should) have the Board's rules open in another browser tab while testing. Passing the NJE is a prerequisite for receiving the ATT for the NCLEX. It is not a significant barrier in terms of difficulty, but it is an additional administrative step.21
4.3 Credential Evaluation Flexibility
Texas accepts CES Full Education reports from CGFNS, ERES, or IERF.
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ERES Strategy: Many applicants find ERES to be more responsive than CGFNS. Using ERES for the Texas application can streamline the credentialing phase.19
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English Requirement: Texas requires English proficiency scores (TOEFL/IELTS/PTE) unless the nursing program was conducted in English. The standards are non-negotiable (e.g., IELTS 6.5 overall with 6.0 minimum in all modules).19
4.4 Market Context
While the process involves an online application and an additional exam, the reward is substantial. A Texas nursing license opens the door to one of the most robust economies in the U.S., offering a lower cost of living compared to coastal states and no state income tax. The sheer number of employers in Texas willing to sponsor visas makes it a high-priority destination for internationally educated nurses.23

5. Strategic Analysis: Illinois (The Outsourced Model)
Accessibility Ranking: #4
Compact Status: Non-Compact (Pending Implementation)
SSN Requirement: SSN Affidavit
English Exam: Required (Waiver possible based on education)
Illinois offers a distinct pathway centered on the Chicago metropolitan area. The regulatory structure here is unique because the Board outsources the initial application processing to a private testing service, Continental Testing Services (CTS).24
5.1 The CTS/IDFPR Dual Structure
Navigating Illinois requires understanding the division of labor:
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Continental Testing Services (CTS): This is the gatekeeper. IENs apply to CTS first. CTS collects the fees, reviews the CES report, and determines eligibility to test. They issue the ATT.
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IDFPR (Illinois Department of Financial and Professional Regulation): Once the NCLEX is passed, CTS transfers the file to IDFPR, which issues the final license.
5.2 The SSN Affidavit
Illinois accommodates IENs via an SSN Affidavit. This document allows the applicant to declare they are ineligible for an SSN. It serves as a placeholder in the IDFPR system until the nurse immigrates.24
5.3 Fingerprinting Challenges (OOS-FP)
For applicants outside Illinois (which includes all IENs applying from abroad), fingerprinting is complex.
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Process: The applicant must obtain an Illinois State Police (ISP) Fee Applicant Card.
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Action: Take the card to a local police authority for ink prints.
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Submission: The card is not mailed to the Board. It must be mailed to a licensed Illinois Fingerprint Vendor (private companies in IL). These vendors scan the physical card and transmit the digital data to the ISP. The applicant must coordinate payment and logistics with this third-party vendor.26
5.4 English Proficiency
Illinois generally requires the TOEFL or IELTS. However, if the CES report (from CGFNS or ERES) clearly states that the "language of instruction" and "language of textbooks" was English, the Board may waive the exam requirement.
6. Strategic Analysis: New Mexico (The Compact Alternative)
Accessibility Ranking: #5
Compact Status: NLC Member
SSN Requirement: Waiver Available
English Exam: Required
New Mexico provides a solid alternative to Montana and Texas. As a Compact state, it offers high mobility. The New Mexico Board of Nursing (NMBON) is modernized and efficient, though it enforces stricter limits on exam attempts.28
6.1 The "Five Attempts" Rule
A critical regulatory detail in New Mexico is the limit on NCLEX attempts. IENs are permitted a maximum of five attempts within three years of their initial application. This contrasts with states like New York, which allow unlimited attempts. For first-time test takers who are confident, this is a non-issue; for those who struggle with standardized testing, it is a risk factor.28
6.2 Streamlined Evaluation and SSN
New Mexico accepts credential evaluations from CGFNS, ERES, and Josef Silny. This flexibility allows applicants to avoid CGFNS backlogs.
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SSN: The Board permits applications without an SSN. The online portal is designed to accommodate this.
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English: Proficiency is required (TOEFL/IELTS/TOEIC/MET) unless the program was English-based. The acceptance of the MET (Michigan English Test) and TOEIC provides more testing options than many other states.29
7. The Tactical "Score Transfer" Pathway: Northern Mariana Islands
Beyond the "Top 5" states, there exists a highly effective tactical maneuver involving the Commonwealth of the Northern Mariana Islands (CNMI). This US territory is often used not as a final destination, but as a regulatory "bridge" to states like California that are difficult to access directly without an SSN.30
7.1 The Strategy
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Application: The IEN applies for licensure by examination to the CNMI Board of Nursing. CNMI does not require an SSN for the application or the exam.
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Examination: The applicant receives an ATT from CNMI and takes the NCLEX at any Pearson VUE center worldwide (e.g., Manila, Sao Paulo, London).
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The Pivot: Once a CNMI license has been granted, score transfer is no longer applicable, and any future application must proceed through licensure by endorsement.
8. Comparative Data Analysis

8.2 Immigration vs. Licensure: The Crucial Distinction
A recurring theme in this analysis is the distinction between State Licensure and Federal Immigration.
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State Licensure grants the legal authority to practice nursing in a specific jurisdiction.
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VisaScreen (Federal) is a certificate issued by CGFNS required by USCIS for the issuance of an occupational visa (Green Card/H-1B).
The Insight:
Even if a state like New York does not require an English exam for the license, the federal government does require it for the visa. Therefore, every IEN will eventually need to pass IELTS/TOEFL. The strategic value of New York is not in avoiding the English exam forever, but in sequencing. It allows the nurse to secure the license and lock in priority dates for immigration while continuing to study for English proficiency, rather than being blocked at the starting line.
9. Conclusion and Strategic Recommendations
The "easiest" state for an Internationally Educated Nurse in 2026 is a relative concept, dependent entirely on the applicant's current status regarding English proficiency, immigration timeline, and target employment region.
9.1 Profile-Based Recommendations
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For the "English-Hesitant" Applicant: New York is the undisputed optimal choice. By removing the immediate barrier of the IELTS/TOEFL, it allows the candidate to focus entirely on the NCLEX-RN. The processing time (2-3 months) can actually be advantageous, providing ample time for exam preparation without the pressure of expiring documents.
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For the Speed-Focused Applicant:
Montana is the superior pathway. By utilizing TruMerit credential processing (as fast as 7 days) in coordination with Josef Silny & Associates for credential evaluation (approximately 2–4 weeks) and the efficient Montana Board of Nursing (around 30 days), a candidate can theoretically progress from application to ATT in under three months. The SSN waiver is well-established, and Compact status adds significant long-term value.
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For the "Big Market" Candidate: Texas offers the most direct route to employment. The massive number of hospitals in Texas willing to sponsor visas makes the administrative effort worthwhile.
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For the "End-Game" Strategist: Using CNMI to pass the NCLEX is a sophisticated maneuver recommended for nurses who have specific family or lifestyle reasons to be in those harder-to-access states.
In 2026, the US nursing market remains open to the world, but access is reserved for those who can navigate the regulatory maze with precision. By selecting one of these five jurisdictions, IENs can effectively bypass the most common bureaucratic blockades—the SSN requirement and initial English testing—and accelerate their integration into the American healthcare workforce.
1. Which US state is the easiest for international nurses to get licensed in 2026? "Ease" depends on your specific barriers. New York is the easiest if you lack English proficiency scores (IELTS/TOEFL) or a Social Security Number (SSN), as it requires neither for the exam. Montana is the easiest if you prioritize speed, offering license issuance in ~30 days with an SSN waiver. Texas is best for maximizing job opportunities.
2. Can I take the NCLEX-RN without a US Social Security Number (SSN)? Yes, but only in specific jurisdictions. New York allows you to apply without an SSN completely. Montana and Illinois provide an "SSN Affidavit" or waiver form. Texas allows it via an online-based application process.
3. Does obtaining a license in a Compact State (NLC) give me a multistate license automatically? No. This is a critical misconception. While states like Montana and Texas are part of the Nurse Licensure Compact (NLC), an international nurse residing abroad cannot establish "Primary State of Residence" (PSOR). Therefore, you will be issued a Single State License. You can only upgrade to a Multistate License after you immigrate to the US and establish tax residency in that state.
4. Why is the New York nursing license process considered the "Global Gateway"? New York is considered the gateway because it decouples professional licensure from federal immigration requirements. It allows nurses to take the NCLEX-RN without first passing an English exam (like IELTS) or holding a US visa. This allows candidates to secure their professional credentials first, then focus on immigration and English proficiency later.
5. What Is the CNMI Licensure Strategy and How Does NCLEX Score Transfer Apply?
The CNMI strategy involves applying for licensure and testing through the Northern Mariana Islands Board of Nursing, which does not require an SSN. Once a CNMI license is issued, NCLEX score transfer is no longer permitted, and any future application to another state must be completed through licensure by endorsement.
6.Which Credential Evaluation Service Is Fastest for Montana or New Mexico?
For speed, Josef Silny & Associates remains the preferred option for states that accept it, such as Montana and New Mexico, with evaluations often completed within a few weeks, provided documents are submitted promptly.
CGFNS International can now complete certain credential evaluation services in as little as 7 days, depending on the service type and document readiness. However, state-specific requirements still apply. For example, New York strictly requires CGFNS (CVS service), and Josef Silny cannot be used for New York applications.
7. Does New York require an English proficiency exam like IELTS or OET? For the state license itself, no. New York State Education Department (NYSED) views passing the NCLEX-RN (which is in English) as sufficient proof of competency. However, you will eventually need to pass an English exam (IELTS, TOEFL, or PTE) to obtain the VisaScreen® certificate required by the federal government for your visa.
8. What are the specific training requirements for a New York nursing license? Regardless of experience, all applicants for a New York license must complete two specific state-mandated courses: Child Abuse Identification and Reporting and Infection Control and Barrier Precautions. These are widely available online, take a few hours to complete, and must be electronically reported to the NYSED by the provider.
9. What is the "Five Attempts" rule in New Mexico? The New Mexico Board of Nursing limits international applicants to a maximum of five attempts to pass the NCLEX within three years of the initial application. This makes New Mexico a riskier option for test-takers who are unsure of their readiness compared to New York, which allows unlimited attempts.
10. How much does the US nursing licensure process cost for an international applicant? The estimated cost ranges from $800 to $1,200 USD initially. This includes the Application Fee ($100–$150), Credential Evaluation Service ($425), NCLEX Registration ($200), and International Scheduling Fee ($150). This total does not include the future costs of the VisaScreen ($700+) or immigration attorneys.
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