The Geezer’s Little Effort to Stop a Runaway Train

I sent a letter to the Iowa Board of Medicine, the Iowa Medical Society, the Iowa Psychiatric Society, and a couple of state legislators recently. It was a proposal for a resolution to reject Maintenance of Licensure (MOL) in Iowa. I have been talking this subject to death for a couple of years now. For a basic overview of Maintenance of Certification (MOC) and MOL see the link to the February issue of Current Psychiatry, Maintenance of certification and licensing: What you need to know — Current Psychiatry Online. Then look at I’d Rather Not Be Blind to Gorillas – The Practical Psychosomaticist.

Anyway, my letter is copied below:

I recently sent a message to Iowa legislators in support of a bill on tort reform in Iowa. The bill provides support for physicians practicing evidence-based medicine, with which I agree. I also believe it could help attract physicians to Iowa, currently a designated physician shortage area, especially with respect to psychiatrists.

I know there is not a bill to support rejection of the Maintenance of Licensure (MOL) pilot projects currently supported by the Iowa Medical Society, but I think there should be one. There is no credible evidence that either Maintenance of Certification (MOC) or MOL change patient outcomes. Certainly, the addition of yet another costly and empty regulatory measure which does nothing to genuinely improve our ability to provide high-quality medical and psychiatric care to Iowans is unlikely to attract psychiatrists to practice in Iowa, and may be a deterrent to recruitment. In my opinion, both MOC and MOL could have a chilling effect on medical school enrollment rates.

Therefore, I’ve modified a document suggested by the American Association of Physicians and Surgeons (AAPS) and propose that it be reviewed by the Iowa Medical Society and state legislators:

Here I placed a modified version of a resolution in opposition to MOL which you can download from






                                                  Resolution 2013-

Introduced by:  James J. Amos, MD for consideration by the Iowa Medical Society


Subject:            Opposition to Maintenance of Licensure (MOL)


Referred to:   Iowa Medical Society; Iowa Psychiatric Society; Iowa Board of Medicine; Iowa Legislators



1      Whereas, in 2010 the Federation of State Medical Boards, Inc., (FSMB) House of Delegates

2      adopted the Maintenance of Licensure (MOL) framework, a process by which physicians

3      periodically provide, as a condition of license renewal, evidence that they are actively

4      participating in a program of continuous professional development that is relevant to their

5      areas of practice, measured against objective data sources and aimed at improving

6      performance over time; and


8      Whereas, the FSMB website states that, in lieu of MOL, the American Board of Medical

9      Specialties Maintenance of Certification (MOC) program and the American Osteopathic

10   Association Bureau of Osteopathic Specialists’ Osteopathic Continuous Certification (OCC)

11   program incorporate activities generally consistent with the intentions of MOL, state

12   licensing boards may elect to substantially or fully qualify licensees engaged in these

13   activities; and  


15   Whereas, medical organizations have for years opposed any effort to mandate the content

16    of continuing medical education (CME) required for licensure because physician

17    themselves are in the best position to determine what educational opportunities will be most

18    helpful in improving their practice, based on the type of patients that they see and the

19    procedures that they perform; and


21   Whereas, there is no evidence that physicians who have completed the maintenance of

22   board certification procedure make more accurate diagnoses or are more skillful at

23   Performing their treatments; and


25   Whereas; maintenance of board certification is extremely costly and time consuming,

26   requiring time away from patient care or from more relevant study, and greatly exceeds the

27   level of knowledge needed for basic medical licensure; and


29   Whereas, the materials that physicians are forced to study to meet maintenance of board

30   certification requirements may be biased, outdated, or irrelevant to the physician’s

31   actual practice; and


33   Whereas, granting certain organizations the equivalent of monopoly power over

34   maintenance of board certification, and thus licensing and medical practice itself, will

35   tend to increase costs, potentially violate federal antitrust and interstate commerce

36   legislation, and hamper innovation; and


38   Whereas, the reasons to oppose maintenance of board certification apply to MOL; and


40   Whereas, state licensing boards are free to adopt or reject the FSMB MOL program; and


42   Whereas, highly variable licensure requirements, including lack of mandatory continuing

43   medical education (CME), have existed in different jurisdictions for decades, without

44   noticeable difference in quality of medicine related to these varying requirements; and


46   Whereas, there is no evidence to indicate that the vast majority of physicians have any

47   need for mandatory, government-prescribed CME to maintain excellent levels of ongoing

48   education and competency; and


50   Whereas, as many as 25%  of all physicians currently practicing medicine in the U.S. have

51   never been board certified and are thus actively excluded from entry into MOC programs,

52   creating hardship if imposed; and


54   Whereas, 50% of all board-certified physicians in the U.S. currently have lifelong

55   certificates, have been and continue to practice as board-certified physicians and are also

56   similarly non-eligible for MOC programs; and


58    Whereas, legislation has greatly expanded the scope of practice of care to lesser educated

59   “midlevel providers” (i.e. nurse practitioners, physician’s assistants, CRNAs, etc.); and


61   Whereas, driving experienced physicians out of practice because of onerous, costly

62   requirements will result in still more patients being forced to turn to nonphysicians for

63   care;


65   Whereas, there is no existing Iowa Medical Society policy calling for opposition to

66    maintenance of licensure (MOL); therefore be it


68   RESOLVED, that the Iowa Medical Society oppose any efforts  to require the FSMB

69   “Maintenance of licensure (MOL)” program as a condition of licensure.

As always, I’m acting on my own and out of my concern about how MOL might adversely influence my ability to provide the highest quality psychiatric care for Iowans. I am not acting as a representative of any group. That said, on reflection I can see one of the many reasons that MOC and MOL have gained so much momentum nationally and in Iowa—the reluctance of physicians to present a coordinated response in opposition to a process the validity, practicality, and wisdom of which thousands doubt.

I appreciate the thoughtful and thorough attention I’ve received in the past from the Iowa Medical Society, the Iowa Board of Medicine, and the Iowa Psychiatric Society about this issue.

I got a phone call from one of the sitting Iowa board members the day I sent it. The feedback was supportive with encouragement to present the issue to the board at one of their regular meetings. I got the sense there was more support for opposition to MOC and MOL in Iowa than I’d hitherto realized. I’ve communicated with them before and they, as well as the Iowa Medical Society and the Iowa Psychiatry Society, have always listened with respect. I have no illusions about what I’ll be able to accomplish on my own. The MOL is like a great vine that is choking the life out of a tree. tree killed by vineSoon, I’m afraid there will be nothing left but regulatory apparatus and the living tree of physician fellowship in the service of patients will be gone. I have always believed in the importance of continuous improvement in my skills and knowledge as a psychiatrist. I don’t believe the MOL or MOC as they’re presently designed help me do this. I would help change it so that it stands a better chance of helping patients. But I get the feeling that the Federation of State Medical Boards (FSMB) and the American Board of Medical Specialties (ABMS) are not really interested in what I have to say.

The MOL is like a runaway train. I know I can’t stop it alone. After all, I’m just a geezer. But I think it would be wrong for me to just let this train rumble on by. Maybe there’s another train coming, another train overtaking with a whistle so loud you can hear it for miles.

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