Dr. Amos’s Dirty Dozen on MOL in Iowa

Well, I was supposed to participate in a telephone conference call with the Iowa Board of Medicine about Maintenance of Licensure (MOL) in Iowa on April 25, 2013, but when they called me at 3:30 PM, the board was already running 20 minutes late and I was too busy to really participate. On that particular day I was running the psychiatry consultation service by myself for an 800 bed hospital.

I had made a handout for the board members, but by the time of the scheduled telephone conference call it had to be updated anyway. So I updated it and I made this presentation.

The board offered to reschedule for the June 2013 meeting to have the telephone conference call about this issue, although I’m unsure whether or not I’ll be available then either. In any case, I appreciate their offer to keep the lines of communication open about MOL.

Slide 5 is reproduced below for easier reading since it’s the most important piece in defense of the pursuit of excellence rather than competence:

MOL Guiding Principles: FSMB

•Maintenance of licensure should support physicians’ commitment to lifelong learning and facilitate improvement in physician practice.
•FSMB says if I’m compliant with Maintenance of Certification (MOC),  I would be in “substantial” compliance with MOL; however, I think MOC doesn’t facilitate improvement in my practice
•Maintenance of licensure systems should be administratively feasible and should be developed in collaboration with other stakeholders. The authority for establishing MOL requirements should remain within the purview of state medical boards.
•I’m a stakeholder and I feel like the FSMB and member boards are forcing the MOL where it’s neither needed nor wanted. Despite saying MOL implementation is up to member boards, FSMB has a clear 10 year timeline to compliance with MOL for all state member boards. There is no clear plan yet to help administrative psychiatrists or those otherwise not doing patient care to comply with MOL. Some physicians’ licenses would be jeopardized without some added administrative work for member boards to track what all physicians in the state are doing, leading to recommendations to consider creating multiple license types stratified according to physician scope of practice
•Maintenance of licensure should not compromise patient care or create barriers to physician practice.
•Already there are barriers to physician practice; MOC is essentially the same process as MOL and physician privileging and insurance reimbursement is based on MOC by the Centers for Medicare and Medicaid Services’ Physician Quality Reporting System MOC Program Incentive, which started providing a 0.5 % incentive payment  in 2012 to physicians participating in a qualified MOC program  http://www.currentpsychiatry.com/article_Pages.asp?AID=11052, “In 2012, the Centers for Medicare and Medicaid Services’ Physician Quality Reporting System MOC Program Incentive provided a 0.5% incentive payment to physicians participating in a qualified MOC program. Other insurers are examining similar reimbursement incentives tied to practice assessment and improvement. Public reporting of quality metrics also is becoming more prevalent in practice and reimbursement incentives”; penalties for non-compliance with MOC will follow
•The infrastructure to support physician compliance with MOL requirements should be flexible and offer a choice of options for meeting requirements.
•There is little uniformity across state member boards for licensing;  physicians not seeing patients  cannot meet requirements as they now stand because  MOL is based on MOC, which requires Performance in Practice (PIP) modules   which requires comparison of one’s patient care processes and outcomes with a relevant standard
•Maintenance of licensure processes should balance transparency with privacy protections
•Transparency  to the  public will be achieved by publishing names of physicians not compliant with MOC, whether or not they hold  time-unlimited certificates  (according to ABIM web site, http://moc2014.abim.org/q-and-a.aspx , “Grandfathers who do not meet the MOC program requirements will be reported as “Certified, Not Meeting MOC Requirements.” They will NOT be reported as Not Certified for failing to meet MOC requirements.”)


•Why  duplicate this  reporting procedure  with MOL? The language tends to  imply  the  physician  “not meeting  MOC requirements”  is  somehow  less qualified  to practice medicine


•Since MOC is essentially the process which would imply compliance with MOL, ABPN protects privacy of protected health information  by not accepting patient feedback  forms themselves (this  is the  Performance in  Practice (PIP) feedback activity)—again making MOL duplicative and unnecessary

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