Life Science Compliance Update

January 15, 2016

AMA House of Delegate Recommendations on Maintenance of Certification and Licensure

During November's American Medical Association (AMA) House of Delegates (HOD) meeting in November, many resolutions and recommendations were adopted, some of which we have previously touched upon.

In addition to the aforementioned HOD actions relating to price control measures on pharmaceutical products and banning direct to consumer advertising, the AMA House of Delegates also adopted some changes recommended by the Council on Medical Education Report. Council on Medical Education Report 2 reviewed and consolidated existing AMA policy on Maintenance of Certification (MOC), Osteopathic Continuous Certification (OCC) and Maintenance of Licensure (MOL) to ensure that the policies are current and coherent.

AMA Principles on Maintenance of Certification (MOC)

The AMA voted to amend Policy H-275.924, Maintenance of Certification. Some of the changes made were for clarification purposes, such as the change that now requires any changes to the MOC process for a given medical specialty board to occur no more frequently than the "intervals used by that specialty board" for MOC. Previously that requirement had used "intervals used by each board" for MOC, possibly creating some confusion as to whether the longest interval by any specialty board controlled, or the interval used by the specialty board in question.

A new statement was added into the policy, #10. The new statement reads,

"In relation to MOC Part II, our AMA continues to support and promote the AMA Physician's Recognition Award (PRA) Credit system as one of the three major credit systems that comprise the foundation for continuing medical education in the U.S., including the Performance Improvement CME (PICME) format; and continues to develop relationships and agreements that may lead standards accepted by all U.S. licensing boards, specialty boards, hospital credentialing bodies and all other entities requiring evidence of physician CME."

MOC's importance was also clarified, with the AMA now saying that MOC is

"but one component to promote patient safety and quality. Health care is a team effort, and changes to MOC should not create an unrealistic expectation that lapses in patient safety are primarily failures of individual physicians."

Another change made was the addition of the following statement, "Our AMA will include early career physicians when nominating individuals to the Boards of Directors for ABMS member boards."

Additionally, the AMA has also advocated policy so that physicians with lifetime board certification are no longer required to seek recertification and no qualifiers or restrictions should be placed on diplomats with lifetime board certification recognized by the ABMS related to their participation in MOC.

Members of the AMA House of Delegates are encourage to increase awareness of these, and other proposed changes to physician self-regulation, through their specialty organizations and other professional member groups.

AMA Principles on Maintenance of Licensure (MOL)

The AMA House of Delegates recommended a new chunk of requirements be added to these principles.

One new requirement reflects the aforementioned change in MOC above. The new requirement asks that the AMA:

"Continue to support and promote the AMA Physician's Recognition Award (PRA) Credit system as one of the three major CME credit systems that comprise the foundation for continuing medical education in the U.S., including the Performance Improvement CME (PICME) format, and continue to develop relationships and agreements that may lead to standards accepted by all U.S. licensing boards, specialty boards, hospital credentialing bodies, and other entities requiring evidence of physician CME as part of the process for MOL."

Additionally, the AMA is to advocate that if state medical boards move forward with a more intense or rigorous MOL program, each state medical board shall be required to accept evidence of successful ongoing participation in the ABMS MOC and AOA-Bureau of Osteopathic Specialists (AOA-BOS) Osteopathic Continuous Certification (OCC) to have fulfilled all three components of the MOL, if performed.

The AMA will also advocate for acceptance by state medical boards of programs created by specialty societies as evidence that the physician is participating in continuous lifelong learning. The AMA will also encourage state medical boards to allow physicians to choose which programs they participate in to fulfill their MOL criteria.

Lastly, the AMA agreed to oppose any MOL initiative that creates barriers to practice, is administratively unfeasible, is inflexible with regard to how physicians practice (clinically or not), does not protect physician privacy, or is used to promote policy initiatives about physician competence.

An Update on Maintenance of Licensure

The AMA is also set to amend Policy D-275.957. The AMA has agreed to continue to monitor the evolution of Maintenance of Licensure (MOL), continue its active engagement in discussions regarding MOL implementation, and report back to the House of Delegates on the issue. The AMA will also continue to review published literature and emerging data as part of the Council on Medical Education's efforts to review MOL issues and work with the Federation of State Medical Boards (FSMB) to study whether principles of MOL are important factors in a physician's decision to retire or if they have a direct impact on the U.S. physician workforce.

The AMA will also encourage the FSMB to continue working with individual state medical boards to accept physician participation in the American Board of Medical Specialties MOC and the AOA-BOS OCC as meeting the requirements for MOL and also to develop alternatives for physicians who are not certified or recertified, and advocate that MOC or OCC not be the only pathway to MOL for physicians.

The AMA will also continue to encourage rigorous evaluation of the impact on physicians of any future proposed changes to MOL processes, including cost, staffing, and time.

Maintaining Medical Specialty Board Certification Standard

Policy H-275.926 will be amended to signify AMA's opposition of discrimination against physicians based solely on lack of ABMS or equivalent AOA-BOS board certification. The AMA also opposed discrimination that may occur against physicians involved in the board certification process, including those who are in a clinical practice period for the specified minimum period of time that must be completed prior to taking the board certifying examination.

The AMA is also encouraging member boards of the ABMS to adopt measures aimed at mitigating the financial burden on residents related to specialty board fees and fee procedures, including ideas like shorter preregistration periods, lower fees, and easier payment terms.

Rescinded Policies

The AMA will rescind a list of policies, including: H-275.923, Maintenance of Certification/Maintenance of Licensure; H-275.944, Board Certification and Discrimination; H-405.974, Specialty Recertification Examinations; and D-275.971, American Board of Medical Specialties – Standardization of Maintenance of Certification Requirements. Most of these rescinded policies contained ideas mentioned above that were added to other policies and standards.

October 23, 2015

CME that Counts for American Board of Internal Medicine MOC Update



In response to requests from physicians and accredited CME providers, the Accreditation Council for Continuing Medical Education (ACCME) and the American Board of Internal Medicine (ABIM) have collaborated to simplify the integration of Maintenance of Certification (MOC) and accredited CME. The goal behind the collaboration is to expand the number and diversity of accredited CME activities that offer ABIM MOC points, and to streamline the process for registering for CME activities in ABIM’s MOC program.

Dr. Richard J. Baron, President and CEO of ABIM states, “While ABIM already offers more than 300 medical knowledge options to physicians engaged in MOC, our diplomates have asked for a more streamlined process to enable them to more seamlessly combine their ongoing educational activities with MOC requirements. By collaborating with ACCME, ABIM will open the door to even more options for physicians engaged in MOC and will allow them to get MOC credit for high-quality CME activities they are already doing.”

On Wednesday, October 14, 2015, the ACCME hosted a webinar entitled, “CME That Counts for ABIM MOC,” where they answered questions about registering CME activities for ABIM’s MOC program in PARS.

There are several changes to the CME activity registration process that are set to make the process more simple and unified. One of those changes is that CME providers are no longer required to submit applications to ABIM for activity peer review approval; instead, they are able to directly use the ACCME Program and Activity Reporting System (PARS) to register activities for ABIM’s MOC program. 

As with any other accredited CME activity, you must first enter all the required activity information into PARS in order to open the activity record. If your activity has already been opened in PARS and you want to register it for ABIM’s MOC program, you can locate the activity record under the Activities tab and click on the update link for that activity. You can update ABIM MOC- eligible activities back to January 2014.

After you have entered the required activity information, you will see a Maintenance of Certification section. Once stating that you would like to “register this CME activity for MOC so that physician attendees may receive MOC credit,” CME providers are required to attest to compliance with requirements for the ABIM Medical Knowledge Assessment Recognition Program, agree to collect the required individual participant completion data and submit it via PARS, agree to abide by ABIM/ACCME requirements for use of the data, agree to allow ACCME to publish data about the activity on ACCME’s website, and agree to comply with requests for information about the activity if it is selected for an MOC audit by the ACCME. 

This ABIM MOC registration process is available for all CME providers in the ACCME system, including state-accredited providers, providers directly accredited by the ACCME, and providers that have received Joint Accreditation for Interprofessional Continuing Education. 

Once a CME provider has registered their activity, physicians can go here and find a sortable list of accredited CME activities that are registered in ABIM’s MOC program.

While this program offers many additional choices, it does not have any new ACCME requirements. CME providers in the ACCME System have the option – but are not required – to offer accredited CME that meets ABIM’s MOC program requirements and to submit activity and participant completion data through PARS to ABIM. 

President and CEO of ACCME, Graham McMahon, MD, MMSc, is looking forward to the collaboration, “The ACCME has long supported the goals of MOC and the alignment of accredited CME and MOC. We share a common mission to facilitate the continuing professional development of physicians. We celebrate this collaboration because it will make a real and meaningful difference to physicians and educators who are working every day to improve healthcare in their communities. This collaboration will generate many more opportunities for accredited CME providers to serve as a strategic resource by delivering relevant, effective, independent, practice-based education that counts for MOC. I look forward to working together with ABIM, our community of accredited CME providers, and our community of diplomates to leverage the power of education to drive quality in our medical profession and improve care for the patients we serve.”

ABIM and ACCME expect to have the process open for accredited CME providers that meet the standards set by ABIM by the end of 2015.

For a step-by-step diagram of the new ABIM MOC PARS process, please click here. If you have any additional questions, the ACCME has created a helpful FAQ page. 

September 21, 2015

Maintenance of Certification: American Board of Anesthesiology Ends 10-Year Exam; ABIM Considers New Continuous Testing Model As Well


Recently, the American Board of Anesthesiology (ABA) announced it will become the first medical board to restructure its Maintenance of Certification (MOC) program. The Maintenance of Certification in Anesthesiology Program, or MOCA, has required physicians to take a recertification test every 10 years. It will be replaced by a program known as “MOCA 2.0,” which will allow anesthesiologists to continuously assess themselves and identify knowledge gaps through an online portal, including a "MOCA Minute" that allows physicians to answer multiple-choice questions at their own convenience.

This shift is noteworthy because over the past few years, the MOC recertification process has been under a great deal of scrutiny by specialists who have expressed dissatisfaction in the process. Hospitals often require their specialists to be board certified; however, the recurring exams are time consuming, costly, and--according to many physicians--often test on topics with little relevance to their own practice. For example, last year thousands of doctors signed a petition for the American Board of Internal Medicine (ABIM) to recall changes to their MOC activities that would further increase the testing frequency. Further, a series of Newsweek articles criticized the ABIM's certification process and financial decision-making. 

ABIM and the ABA are both part of the American Board of Medical Specialties' (ABMS) 24 specialty member boards. ABA is the first specialty to officially break the mold. “We understand that once-every-10-year exams kind of promoted people studying for a couple of months, cramming for the exam, passing it and then moving on,” said Dr. James Rathmell, secretary for the ABA and chair of the department of anesthesiology as quoted in Modern Healthcare. “We all felt that wasn't a very good way of keeping physicians up to date and it probably didn't translate into tremendously better patient care.” 

ABA's changes are summarized on their website, as follows:


Soon after ABA's announcement, the ABIM also announced that it will consider replacing its 10-year MOC exam with shorter, more frequent testing that physicians could take when and where they wanted to. Richard Baron, MD, ABIM's president and CEO, told Medscape Medical News that the ABA's new continuous online testing model could be a good model for replacing ABIM's s 10-year exam. "But the execution issues aren't trivial," Dr Baron said to Medscape. "We'll be monitoring what the ABA does with considerable interest."

The proposal to replace the 10-year MOC exam "quickly garnered praise from the American College of Cardiology (ACC), which represents a major subspecialty in internal medicine," Medscape writes.

The Cardiology Society wrote:

[T]he ACC strongly agrees with the report about the need to develop a new, externally-validated process for measuring competence to replace the 10-year exam – with all deliberate haste! Additionally, the ACC is committed to continuing work with ABIM to research best practices for the maintenance and demonstration of competence with eventual links to patient outcomes, cost and cost-effectiveness.

View the ABIM's Press Release on their MOC discussions here. View their comprehensive report entitled "A Vision for Certification in Internal Medicine in 2020," here

Newsweek's Kurt Eichenwald, who authored the widely publicized MOC critiques, also recently weighed in on ABIM's announcement entitled "To the Barricades! The Doctors' Revolt Against ABIM is Succeeding!"


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