Life Science Compliance Update

June 24, 2016

Interstate Medical Licensure Compact – Expands to 17 States

Seventeen states have enacted legislation in an attempt to expand access to health care through expedited medical licensure. The Interstate Medical Licensure Compact offers an expedited licensing process for physicians that are interested in practicing medicine in multiple states. The Compact was created with the goal of expanding access to health care, especially to those in rural and underserved areas of the country, and to facilitate the use of telemedicine technologies in the delivery of health care.

According to the Interstate Medical Licensure Compact website, among the issues driving the need for the Compact include:

[P]hysician shortages, the expected influx of millions of new patients into the health care system as a result of the Affordable Care Act, and the growing need to increase access to health care for individuals in underserved or rural areas through the use of telemedicine. Proponents of telemedicine have often cited the time-consuming state-by-state licensure process for multiple-license holders as a key barrier to overcome in order for telemedicine to continue to grow and thrive. The Compact would make it easier and faster for physicians to obtain a license to practice in multiple states, thus helping extend the impact and availability of their care at a time when demand is expected to grow significantly.

A total of seventeen states have adopted the Compact legislation, with Colorado, New Hampshire, Arizona, Kansas, and Mississippi being the most recent. Other states who have passed the compact include Alabama, Idaho, Illinois, Iowa, Minnesota, Montana, Nevada, South Dakota, Utah, West Virginia, Wisconsin and Wyoming.

Compact legislation is currently either being discussed by the legislature or awaiting the signature of the governor in an additional ten states. States that participate in the Compact agree to share information with each other and work together in new ways to streamline the licensing process.

The Compact has been endorsed by a broad coalition of health care stakeholders, including the American Medical Association (AMA) and the American Osteopathic Association (AOA). The Interstate Medical Licensure Compact Commission is made up of two appointed Commissioners from each state that joints the Compact. The Commission is charged with administering the Compact, creating bylaws and rules for its operation, and otherwise implementing the expedited licensure of physicians as the Compact directs.

In order to be considered eligible to seek licensure through the Compact process, physicians must meet certain requirements, including: possess a full and unrestricted license to practice medicine in a Compact state; possess specialty certification or be in possession of a time unlimited specialty certificate; have no discipline on any state medical license; have no discipline related to controlled substance; not be under investigation by any licensing or law enforcement agency; have passed the USMLE or COMLEX within three attempts; and have successfully completed a graduate medical education (GME) program.

Each license to practice medicine obtained through the Compact will be issued by a state medical board. A license obtained through the expedited procedure will provide the same licensing currently provided for physicians by state medical boards: the only difference is that the process of obtaining a license will be streamlined.

A physician will apply for expedited licensure by designating a member state as the state of principal licensure and select the other member states in which a medical license is desired. The state of principal licensure will then verify the physician's eligibility and provide credential information to the Interstate Commission. The Commission will then collect the applicable fees and transmit the physician's information and licensure fees to the additional states. Upon receipt in the additional states, the physician will be granted a license.

Notably, the Commission may assess processing fees for expedited licensure, helping to off-set any burden on the member states. The Commission is also enabled to seek grants and secure outside funding, through private grants, or federal appropriations in support of license portability.

Effect on MOC

According to the Federation of State Medical Boards (FSMB), the Compact does not require a physician to participate in Maintenance of Certification (MOC). However, with the exception of the declining number of physicians who hold a lifetime certificate, MOC is required to maintain specialty board certification, and thus required to be licensed through the Compact.

While the Compact does not make any specific reference to Maintenance of Certification, its own definition of physician requires MOC for most of the physicians that will participate in the Compact.

According to Jeremy Snavely of the Association of American Physicians and Surgeons, the Compact puts physicians who do not participate in ABMS and AOABOS products at a competitive disadvantage and a state legislature should not be passing laws that are handouts to such private, unaccountable organizations.

The Commission has started to formally meet and is working on implementing the administrative processes that are needed to begin the expedited licensure process, but licenses via the Compact process have not started to be issued yet.

May 06, 2016

ABIM MOC Survey Results Announced

We have previously written about the way the American Board of Internal Medicine (ABIM) is seeking physician input on Maintenance of Certification (MOC) assessments. recently, ABIM announced the findings from that recent survey. All ABIM Board Certified physicians were invited to participate in the survey, and over 9,200 responded, a 4.7% response rate.

ABIM presented the results from the survey ("Improving the MOC Assessment Experience") at a recent ABIM meeting, in front of more than seventy leaders of medical societies. Following the presentation, the ABIM Board of Directors and Council continued discussions, considering physician-guided recommendations about options for updating the MOC assessment process. Through those discussions, ABIM will also create a timetable to seek feedback from physicians, launch a pilot, evaluate the pilot, and eventually implement changes.

ABIM made inferences about the full population of ABIM Board Certified physicians from a representative sample of 1,225 physicians. The random representative sample had a 29.4% response rate; and, in an attempt to correct non-response bias, ABIM "weighted sample responses and performed multiple imputations."

Key Survey Findings from the Representative Sample

Of the representative sample, 86% responded positively to the idea of taking an assessment at home or in their office, instead of the typical testing center, and were comfortable with potential tasks necessary to facilitate secure, remote assessment. 79% of the representative sample liked the idea of taking shorter knowledge assessments, skipping the full-length MOC exam. 76% responded positively to the idea of using online resources during an assessment, and another 76% responded that they would like maintaining their board certification to signify that they are staying current in the knowledge they need to practice. 56% of respondents positively responded to the idea of shorter, more frequent knowledge assessments, though opinions regarding the preferred length and frequency of assessments varied widely.

The survey also highlighted the fact that many physicians are dissatisfied with the current MOC program (69.6%), but 38.5% are satisfied with ABIM's recent efforts to address those needs and concerns of the internal medicine community.

ABIM Responds

According to Richard J. Baron, M.D., President and CEO of ABIM,

In our efforts to deliver a meaningful, performance-based credential that signifies something important about physicians, the survey results provide invaluable guidance as to what physicians favor in the assessment process. These insights will empower our decision making for the future by giving us direct insight into what physicians value as future components of our evolving MOC assessment.

Richard G. Battaglia, M.D., Chief Medical Officer of ABIM, believes that the

opinions from physicians gleaned through the survey will be used to frame future discussions and refine details about potential assessment ideas. Results indicate that physicians are interested in exploring all of the ideas presented in the survey. ABIM will continue to engage physicians and societies to explore assessment models that are reflective of practice today.

Future Surveys

As mentioned by both Dr. Baron and Dr. Battaglia, ABIM will continue to analyze the surveys and continue to solicit feedback from the community on different aspects of MOC assessment models. Dr. Baron stated that ABIM will evaluate the results from a research study, for which hundreds of physicians have already signed up, to understand how an "open book" portion of MOC would impact both the assessment experience, and performance.

Prior to launching any future pilots, ABIM plans to ask for feedback from the community on more detailed aspects of the piloted MOC assessment models. The current assessment will remain in place as the community continues to explore alternatives.

April 04, 2016

ABIM Considers Open Book Testing

We have previously written about the 2020 Task Force organized by the American Board of Internal Medicine (ABIM) on Maintenance of Certification (MOC) assessments. ABIM is using the task force in an attempt to continue perfecting their MOC program and setting a new process for internists and subspecialists.

Most recently, ABIM announced that they are looking at permitting access to online resources for a portion of the maintenance of certification assessments. In a blog post written by President and CEO of ABIM, Richard J. Baron, M.D., MACP, he announced that the idea to "make at least a portion of ABIM's assessment 'open-book" was repeatedly suggested from both medical society leadership, and in broad community dialogue. Many who suggested the idea believe that permitting such "open book assessments" may result in test scores that are "truer to a physician's every day experiences."

In response to those suggestions, ABIM has launched a study to examine the ways ABIM diplomats might have access to online resources during a portion of the MOC assessment. For the study, ABIM is seeking physicians who have either passed the Internal Medicine Certification exam or have taken the Internal Medicine MOC exam within the past five years to participate.

While ABIM has no definite answers as to when the open book option or any other alternatives to the current MOC assessment might be implemented, they have made significant progress, and look forward to being able to shed more light on the future in the coming months.

Possibly permitting open-book test taking is not the only thing ABIM is looking at doing to update their MOC testing. Other ideas include:

  • Developing new approaches to assessment; getting physician input about new approaches through society meetings, focus groups, design sessions, and online surveys
  • Surveying all ABIM Board Certified physicians about the MOC experience and alternate assessment ideas they have. ABIM has received thousands of responses and once they have an opportunity to compile the responses, will share the results
  • Inviting all diplomates within a specialty to participate in blueprint review, a key building block to future assessment discussions
  • Inviting more physicians to participate in the standard setting process

What's Next?

In April, the ABIM Board of Directors and Council will be meeting jointly to consider physician recommendations about what the best options are for updating the MOC assessment process. The two groups together will refine a timetable to pilot, test, and implement changes to the assessment process.

It is expected that alternative assessments will require analysis and piloting to ensure that the approach is impartial, fair, and respectful. ABIM recognizes the importance of physician and society input, and as such, will continue to update and engage them.

Dr. Baron emphasizes that he and the Board of Directors are grateful to the individuals and societies who have joined ABIM in trying to make the process better, and also to those who are urging the process to move faster. ABIM has committed to issuing quarterly progress reports so that everyone knows what the expect, and when to expect it, in the process.

If you have ideas about MOC, Dr. Baron encourages you to reach out to him at


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