Apr 15, 2017

Mandate? Hardly.

As in a bad Freddy Krueger movie, rumors of a binding, incestuous relationship between the Interstate Medical License Compact and Maintenance of Certification (MOC) just will not die.

Let’s set the record straight.

The Interstate Medical License Compact is a multistate agreement that allows physicians to obtain a license in a new state faster and with fewer hassles. Here are some basic facts to remember:

1.      The Compact does not replace, override, or reduce the need for the physician to meet the licensing requirements of the new state.

2.      Physicians who, for any reason, do not want to use the Compact still may apply for a license in the new state using the traditional route.

3.      Physicians who want to use the Compact must have an active board certification at the time of the license application through the compact. The Compact does not require MOC before, during, or after that procedure.

Mandate? Hardly.

Now, as to the position of the Texas Medical Association (TMA):

TMA opposes mandatory MOC requirements for licensing, credentialing, hospital privileges, health plan contracts, or payment. This position was adopted by votes of the TMA House of Delegates in 2013 and in 2016 in adopting these policies:

·         Maintenance of Certification Requirement: TMA supports the American Medical Association’s Principles of Maintenance of Certification (MOC) H-275.924 to ensure physician’s choice of lifelong learning, and will pursue legislation that eliminates discrimination by the State of Texas, employers, hospitals, and payers based on the American Board of Medical Specialties’ proprietary MOC program as a requirement for licensure, employment, hospital staff membership, and payments for medical care in Texas. (2016)

·         Opposition to Maintenance of Licensure: TMA opposes any efforts by the Texas Medical Board (1) that require the Federation of State Medical Boards’ Maintenance of Licensure (MOL) program as a condition of licensure, and (2) that unilaterally implement different Maintenance of Licensure requirements other than those currently in place for physicians in Texas. (2013)

In the current (2017) session of the Texas Legislature, TMA is strongly supporting Senate Bill 1148 by Sen. Dawn Buckingham, MD (R- Lake Travis). That would prohibit the sole use of MOC status to credential, license, or pay physicians. Kim Monday, MD, a neurologist from Houston and former president of the Harris County Medical Society testified for the bill in committee on behalf of TMA. Dr. Monday called the requirement “burdensome, expensive, and filled with irrelevant curriculum.” She noted the combined cost including materials, fees, and time away from patients and the medical practice to undergo the process can be as high as $10,000. Dr. Monday referred to MOC as a “moneymaking scheme” with “little applicability to day-to-day practice.”

The Interstate Medical License Compact provides a route for Texas to recruit and quickly deploy physicians currently licensed in other states. Given the desirability of practicing medicine in Texas and the state’s severe physician shortage, adopting the Compact by the Texas Legislature would have a positive outcome.

In 2015, the TMA House of Delegates considered but did not adopt a resolution calling on the association to “oppose the Federation of State Medical Board’s (FSMB) Interstate Medical Licensure Compact as currently written.”


Anonymous said...

Hello, I would respectfully as TMA to consider this information related to the arguments made in this post about MOC and the Compact.

To your point #1: "The Compact does not replace, override, or reduce the need for the physician to meet the licensing requirements of the new state."

For physicians seeking a license through the Compact, the Compact's requirements do indeed override the state's own requirements:

"(d) After receiving verification of eligibility under
subsection (b) and any fees under subsection (c), a member board
shall issue an expedited license to the physician."

And the IMLCC bylaws:

"5.5 (4) Upon receipt of all licensure fees required, and receipt of the information from the application, including the letter of qualification, the member board(s) shall promptly issue a full and unrestricted license(s) to the applicant, and provide information regarding that license to the Interstate Commission to maintain in its coordinated information system."

Other states have raised this objection to the Compact.

To point #2: "Physicians who want to use the Compact must have an active board certification at the time of the license application through the compact. The Compact does not require MOC before, during, or after that procedure."

Physicians with a time-limited certificate who don't comply with MOC requirements are not considered to have a current or active certification.

See for instance the American Board of Pediatrics website which states: "As of 1988, certificates issued by the ABP are time-limited. To remain Board-certified, pediatricians with time-limited certificates must complete Maintenance of Certification (MOC)."

Also the ABIM states: "Internists and subspecialists certified in or after 1990 remain certified through ABIM’s Maintenance of Certification (MOC) program." and "All ABIM certifications issued in 1990 (1987 for critical care medicine and 1988 for geriatric medicine) and thereafter must be maintained through ABIM's MOC program."

Thank you for considering these points.

Anonymous said...

MOC is Maintenance of Board Certification. In order to have an active Board Certification as is required by point 3, you have to be life certified or up to date on MOC requirements and fees. This means over 59% of physicians will be required to do MOC to be in the Compact.

If every state has a physician shortage, then how does a Compact license tying physicians to the most onerous program of MOC help anyone?
Even if Texas succeeds in passing their MOC control bill, the Compact bill clear states that it supersedes Texas law in case of conflict.
So if board certification which includes continuous MOC for most doctors is required by the Compact then any MOC control bill would be muted.

Additionally the Compact does not have any language that protects physicians from being required by hospitals or insurance companies. Considering that continuous MOC became required by most hospitals and many insurance companies within 2 years, why not just require the "higher standard" Compact instead of "lesser" standard regular license.

If you think that the Compact is not a big foot in the door to linking MOL and MOC to Texas lucensure, then you don't understand how monopolies work or you don't want to for ulterior reasons. Please disclose any potential Conlicts of Interests.
If board certification=Compact and for board certification =MOC for most docs then the Compact=MOC for most docs.

I urge every physician to read the state of Missouri's legal opinion against the Compact.
As physicians we don't often think like a lawyer would, this can cause many problems for physicians. The Compact was written by FSMB lawyers to protect the interests of th FSMB and ABMS including their propriteey products of MOC and USMLE. This is called regulatory capture, a huge ethical problem and conflict of interest. The law was written to ensure their profits. They are even not telling the truth about MOC and board certification because they know physicians hate the MOC. Ask your own lawyer if MOC is required for Board Certification. The ABMS requires it for time limited board certifications to be active.
Think like a lawyer don't get burned by the monopolies. Don't let them turn your Texas Medical education into a 1 or 2 year certificate tied by law to the FSMB's yet to be written rules or their MOL program or the MOC of the ABMS.
Texas physicians deserve better respect than MOC and MOL linked to any "voluntary" license program. The MOC is supposed to be voluntary, now Texas needs a law to try to protect Texas from voluntary continuous board certification programs, the MOC. Just guess what will happen if the "voluntary"Compact program requiring MOC gets linked to law in Texas.
Don't Mess with Texas Doctors, keep the MOC far away from Texas. Don't link it to law via the Trojan horse Compact.

Anonymous said...

The Interstate Compact will supersede Texas authority and jurisdiction. Quite a number of states have already considered and rejected this Compact as too expensive, intrusive, and unnecessary. The Compact will fail because it imposes quite a few extra fees for no added benefit with the exception of the Compact's claim of delivering "expedited" licenses. The Ohio State Medical Board questions the accuracy of this claim. So do I.

Texas does NOT need an extra layer of bureaucracy. The Compact is destined for failure and TMB would be wise in steering clear of a Compact that will cost taxpayers needlessly.

Paul Kempen said...

If the IMLC REQUIRES Board Certification to become licensed through the IMCL, then it REQUIRES MOC to register, I.e. DURING this process!!
The FSMB has TERRIBLE ratings on YELP (https://www.yelp.com/biz/federation-credentials-verification-service-dallas) for their "services". The IMLC is the "New Generation MOL" a device for the FSMB to impose their will-Mantenence of Licensure (MOL) and footprint on all medical boards as a PHYSICIAN ADVERSE organization. They will sell more "products" using the IMLC for example the SPEX and FCVS!
Any physician who uses the IMLC will need to renew the home state IMLC approval every Year at great cost and expense while supporting this FSMB organization out to take control of YOUR $$$$$.