Overview of Continuing Medical Education, Maintenance of Certification and Maintenance of Licensure for California Physicians By Sue Lockridge, CPCS, CPMSM Director of Medical Staff Services, Mercy Medical Center, Merced Chairman of the CAMSS Education and Publication Committee Some states do not have any requirement for physicians to document participation in Continuing Medical Education (CME) to renew medical licenses. California Doctors of Medicine (MD s) however, must meet the Medical Board of California s standard for continuing medical education to renew their licenses. MD s must complete 50 hours of CME during the renewal cycle, i.e., the two-year period immediately preceding the expiration date of the license. Doctors of Osteopathic Medicine (DO s) are required to complete150 credit hours within a three year reporting period. Physicians who cannot certify compliance with the CME requirement must apply for and receive a waiver. Waivers must be based on, disability, military service, or undue hardship. Applications for a waiver are available from the Licensing Program at the Medical Board of California. It is unprofessional conduct, which may result in disciplinary action or a citation and fine, for any physician to misrepresent his or her compliance with the CME requirements. California physicians must also complete a mandatory, one-time requirement of 12 hours CME in pain management and the treatment of terminally ill and dying patients (Business and Profession Code 2190.5). Additionally, all general internists and family physicians who have a patient population of which over 25 percent are 65 years of age or older must complete at least 20 percent of all mandatory CME in a course in the field of geriatric medicine or the care of older patients (Business and Profession Code 2190.3) Each year the Medical Board of California audits a random sample of physicians who have reported compliance with the CME requirement. Those physicians selected for audit must document their compliance with CME requirements. Any physician who has been certified as complying with the CME requirement by either the California Medical Association (CMA) or the American Academy of Family Physicians (AAFP) will not be required to submit documentation or records of CME coursework completed, but instead may request the records be directly submitted to the Board from the certifying organization. Any physician who takes and passes a certifying or recertifying examination administered by a recognized specialty board shall be granted credit for four consecutive years (100 hours) of continuing education credit for relicensure purposes. Such credit may be applied retroactively or prospectively. Sixty hours of continuing education shall be granted to a physician for receiving the American Medical Association Physician s Recognition Award (AMA PRA ). A maximum of six hours of continuing education shall be granted for each month that a physician is engaged in an approved postgraduate residency training program or approved
clinical fellowship program accredited by Accreditation Council for Graduate Medical Education (ACCGME) for relicensure purposes. The California Legislature has directed the Medical Board to consider the inclusion of courses in the following subjects in the continuing medical education requirement for physicians. The Board doesn t require specific continuing medical education coursework in these subjects at present. However, physicians are encouraged to voluntarily participate in continuing education in the following areas (Business and Professions Code 2191): human sexuality child abuse detection and treatment acupuncture nutrition elder abuse detection and treatment early detection and treatment of substance abusing pregnant women special care needs of drug addicted infants spousal or partner abuse end-of-life care geriatric pharmacology pain management Commencing July 1, 2006, all continuing medical education courses presented by an organization accredited by the State of California, must contain curriculum that includes cultural and linguistic competency in the practice of medicine (Business and Professions Code 2190.1(b)(i). Cultural competency is defined in law as a set of integrated attitudes, knowledge, and skills that enables a health care professional or organization to care effectively for patients from diverse cultures, groups and communities. At a minimum, cultural competency is recommended to include the following: Applying linguistic skills to communicate effectively with the target population. Using cultural information to establish therapeutic relationships Eliciting and incorporating pertinent cultural data in diagnosis and treatment Understanding and applying cultural and ethnic data to the process of clinical care. Linguistic competency is defined by law as the ability of a physician to provide patients who do not speak English or who have limited ability to speak English, direct communication in the patient s primary language. Code Five of the AMA (American Medical Association) Principles of Medical Ethics states, A physician shall continue to study, apply and advance scientific knowledge, maintain a commitment to medical education, make relevant information available to patients, colleagues, and the public, obtain consultation, and use the talents of other health professionals when indicted. John Shaw Billings, 1838-1913 American librarian and surgeon said when speaking September 2012 2
about lifelong learning, The education of the doctor which goes on after he has his degree is after all, the most important part of his education. Physicians are committed to be lifelong learners. The AMA authorizes the Accreditation Council on Continuing Medical Education (ACCME) to accredit state agencies and medical societies to provide CME. The ACCME is a national organization formed through and accountable to the joint membership of seven other key national organizations: American Board of Medical Specialties (ABMS) Federation of State Medical Boards (FSMB) American Medical Association (AMA) American Hospital Association (AHA) Association for Hospital Medical Education (AHME) Association of American Medical Colleges (AAMC) Council of Medical Specialty Societies (CMSS) The ACCME, directly or indirectly accredits organizations that offer CME activities for AMA PRA Category 1 Credit. The most recent CME standards which were released in September 2006 require that CME activities support improvements in the Quality of Care. Competencies developed by the Institute of Medicine (IOM), the American Council on Graduate Medical Education (ACGME), and the ABMS are used to plan CME activities. The content of CME must address more than just clinical knowledge. It must include communication, working in teams and systems, use of information technology, patient-centered care, professionalism, commitment to lifelong learning and quality improvement. The Institute for Medical Quality/California Medical Association (IMQ/CMA) specifies the following criteria of eligibility for accreditation. Organizations which offer a program of continuing medical professional medical education on a regular and recurring basis to physicians, and who serve registrants of whom more than 70% are from within California and its bordering states. Organizations that offer regular and recurring activities to registrants of whom more than 30% are from beyond California and its bordering states, should apply for national accreditation. To obtain and maintain CME accreditation, provider organizations must pass a rigorous accreditation survey. They must demonstrate compliance with the 2006 ACCME Accreditation Criteria. The Criteria were designed to assure that CME provides balanced, non-promotional, unbiased, scientific information designed to maintain, develop or increase the knowledge skills and professional performance and relationships that a physician uses to provide service for patients, the public or the profession. The content of CME is the body of knowledge and skills September 2012 3
generally recognized and accepted by the profession as within the basic medical sciences, the discipline of clinical medicine and the provision of healthcare to the public. Prior to the survey, the applicant must submit documentation of compliance from several CME activities that were either joint sponsored by another accredited provider for new applicants, or directly sponsored by the accredited provider. They must also provide a mission statement which includes the CME purpose, content areas, target audience, type of activities provided and expected results of the program must be submitted for review. A surveyor visits the site to interview the CME Committee and based on the review of documents and the interview, the surveyor will make a recommendation to the CMA/IMQ CME Committee. The CME Committee reviews the findings of the surveyor and typically renders one of the following decisions, with or without a requirement for interim report to monitor any area of non-compliance found during the survey. Type of IMQ/CMA Accreditation Non-Accredited (new application) or Probation (reapplication) Provisional Continued Commendation Requirements Decision may include a request for an Interim Report and the deadlines for compliance for any areas of noncompliance. Compliance with Criteria 1 to 3 and 7 to 12 and all Accreditation Policies Compliance with Criteria 1 to 15 and all Accreditation Policies Compliance with Criteria 1 to 22 and all Accreditation Policies Length of Term 1 year 2 years 4 years 6 years Of the regulatory accrediting bodies, National Committee for Quality Assurance (NCQA), Utilization Review Accreditation Commission (URAC), Accreditation Association of Ambulatory Health Care (AAAHC), and the Centers for Medicare and Medicaid Services (CMS), Medicare Conditions of Participation do not specifically address CME in their standards. Det Norske Veritas (DNV) requires that CME be considered in decisions about reappointment, renewal or revision of individual clinical privileges. DNV recommends that the individual s application for appointment/reappointment or initial or subsequent clinical privileges be withheld until the CME information is available and verified. Healthcare Facilities Accreditation Program (HFAP) may request evidence of continuing education activities every two years. Joint Commission Standard MS.12.01.01 requires that all licensed independent practitioners and other practitioners privileged through the medical staff process participate in continuing education. 1. Hospital-sponsored educational activities are prioritized by the organized medical staff. September 2012 4
2. These activities relate, at least in part, to the type and nature of care, treatment, and services offered by the hospital. 3. Education is based on the findings of performance improvement activities. 4. Each individual s participation in continuing education is documented. 5. Participation in continuing education is considered in decisions about reappointment to membership on the medical staff or renewal. CME is transitioning from the old paradigm of imparting knowledge, to the new paradigm of performance improvement CME at the local level and Maintenance of Certification (MOC) at the national level. The American Board of Medical Specialties and the Federation of State Medical Boards (FSMB) have developed the Maintenance of Certification program. The American College of Family Physicians was the first to adopt the MOC program. There are four components to this new concept of Maintenance of Certification. Maintenance of Certification Part I Licensure and professional Having a valid unrestricted medical license standing Part II Lifelong learning and self assessment Doing self assessment by participating in regularly required activities and participating in CME Part III Cognitive expertise Taking a secure exam on specialty specific Part IV Practical performance assessment knowledge and skills Demonstrating practice assessment and improvement Recognizing that CME activities that are unrelated to a physician s actual practice does not support the vision for MOC, the ABMS has implemented a policy that only CME related to the physician s own practice can be used to meet the CME requirements for MOC. The FSMB has endorsed a similar principle for Maintenance of Licensure (MOL). In 2010, the FSMB released a recommendation for all state licensing boards to adopt requirements similar to those required for Maintenance of Certification, including participating in CME, a proctored exam and performance improvement. They also recommended that this be a 5-year cycle, and that all 70 state licensing medical and osteopathic boards adopt this within 10 years. Although voluntary, some states have already started implementing the requirements and as more states adopt this policy, it will create momentum for all states to adopt. The California Board of Osteopathic Medicine has already started implementing these requirements; however, the Medical Board of California has not. It remains to be seen if CME at the local level will survive, as the emphasis from the Medical Boards for MOC takes away the attractiveness and perceived need of locally sponsored CME. One prestigious hospital system in the Midwest is negotiating with individual specialty boards to assume the MOC process with and replace with local initiatives for their medical staff. They September 2012 5
currently have agreements in place with 16 of 24 of the specialty boards. Other providers are tying CME to their OPPE (Ongoing Professional Practice Evaluations). Glossary of CME Alphabet Soup AAAHC.Accreditation Association of Ambulatory Health Care AAFP.American Academy of Family Physicians AAMC Association of American Medical Colleges ABMS.American Board of Medical Specialties ACCME..Accreditation Council on Continuing Medical Education ACCGME Accreditation Council for Graduate Medical Education AHA American Hospital Association AHME.Association for Hospital Medical Education AMA...American Medical Association AMA/PRA..American Medical Association Physician s Recognition Award AOA...American Osteopathic Association CMA...California Medical Association CME...Continuing Medical Education CMS Centers for Medicare and Medicaid Services CMSS..Council of Medical Specialty Societies DNV...Det Norske Veritas (accrediting body) September 2012 6
DO.. Doctor of Osteopathic Medicine FSMB..Federation of State Medical Boards HFAP..Healthcare Facilities Accreditation Program (AOA Program) IMQ.Institute for Medical Quality IOM.Institute of Medicine MD..Doctor Medicine MOC Maintenance of (Board) Certification MOL...Maintenance of Licensure NCQA..National Committee for Quality Assurance OPPE Ongoing Professional Practice Evaluation (Joint Commission Requirement) URAC...Utilization Review Accreditation Commission References: Guide to the Laws Governing the Practice of Medicine by Physicians and Surgeons, Medical Board of California, Sixth Edition: 2010 Medical Board of California Osteopathic Medical Board of California 2011 IMQ/CMA Accreditation Standards Climate Change: It s Not About the Weather Continuing Medical Education and Maintenance of Certification of Licensure by Carol Haven, M.D., & Jeffry Malin, M.D., The Permanente Journal. NAMSS 2010 Comparison of Accreditation Standards September 2012 7