ABMS Public Commentary on New Standards for MOC Ends November 20, 2013!

Well, I just discovered that the American Board of Medical Specialties (ABMS) has been soliciting Public Commentary on new standards it is proposing for the Maintenance of Certification (MOC). I didn’t receive notification about it from my specialty board, the American Board of Psychiatry and Neurology (ABPN). I’m trying to get the word out as quickly as I can in case you’ve missed it as well. The deadline for comments is November 20, 2013 and I’ve just finished mine. Although they said they allowed you to upload a letter, they didn’t let me upload a simple Word document of my letter of protest against MOC, even though I removed all special formatting and web links. It got flagged as “File type not allowed.”

Here is the link to the survey and good luck. It’s very broad and I couldn’t detect much about it that one could dispute, mainly because MOC is accepted as a fait accompli. Because they disallowed my letter, I had to shorten my final comments to the 25o word limit, an excerpt of which follows:

I’ve just learned of the ABMS new MOC standards. I understand the Public Comment period will end on November 20, 2013. The standards are very broad, shift the responsibility for operationalizing the standards to member specialty boards, and they don’t begin to address the mistrust and frustration that many physicians have with the entire process.

I proposed a resolution to support lifelong learning and oppose Maintenance of Licensure (MOL, a move to tie medical licensure to participation in MOC, essentially) this spring at the Iowa Medical Society (IMS) House of Delegates meeting, and it was adopted. It was co-sponsored by the Iowa Psychiatric Society (IPS).

No one asked me what I thought about a MOC program before it was foisted upon me. This is an experiment, unsupported by high level research evidence. We should have a vote on the process, and the empty gesture of a period of public comment on new standards does not persuade me that you now respect and desire my experience and knowledge.

Physicians call organizations like ABMS “fascist”. The ABMS is even the subject of a lawsuit filed in Federal court in April of 2013 regarding MOC.  Tens of thousands of physicians are understandably opposed to MOC even while they struggle to assert they support the principle of lifelong learning.

You had the option of entering your name (which I did) and whether or not you’re in compliance with MOC (which I am).

I think it’s baffling that the ABMS would offer such a survey now, as though they were interested in anyone’s opinion. I’m unhappy that I was not informed by the ABPN about the existence of the survey. I’m also aware that groups opposed to MOC are conducting national surveys of both doctors and patients and plan to give the results to…the boards.

Who else?

The problem I see here is that the pro-MOC and anti-MOC groups are talking past each other and both couldn’t care less about each other’s surveys. We are in a standoff and there is no higher court to which physicians and patients opposed to the MOC can appeal.  Frankly, it had not occurred to me to contact the ABMS before now. I didn’t think they cared whether or not they heard from me and I still don’t think they care a fig about my comments.

But I just couldn’t let it go by and I hope you don’t either.

I regularly receive email notification about psychiatrists who are unhappy with MOC and MOL programs.

The latest communication I got was forwarded to me about a psychiatrist (information de-identified) who was grandfathered in Psychiatry by the ABPN in 1990. The psychiatrist was certified in a subspecialty in psychiatry in 2013, only to be notified by them that he now owed them hundreds of dollars annually in an additional fee and would list him as “certification inactive” as of 2014.

This physician says  board-certified specialists feel dictated to by an “unaccountable elite” and believe they should have recourse to a higher authority to question the rules that have been made without their counsel to govern recertification.

I’m urging my colleagues to let the boards know how they’re being treated. But is that the only place to take our case…the boards? When I think about it, this is like a circle, and the circle is the bottom of a barrel, and we’re the fish. Guess who’s shooting at us.




  1. While we’re at it, please sign my UPDATED petition to support lifelong learning and oppose Maintenance of Licensure (MOL) in Iowa at link http://www.ipetitions.com/petition/iowa-medical-society-house-of-delegates/.

    You don’t have to be from Iowa and you don’t have to be a physician to sign it. You do need to understand basic information about MOC and MOL and the petition itself contains enough background for that.

    Thanks for signing the petition and entering your commentary about MOC on the ABMS website!


  2. Thanks – spelling corrected and thanks for the tip on the total words. I will send them a modified paragraph 4.


  3. Jim – my response:


    Let me know what you think and I will add it to the comments on the ABMS web site.


    • George, it’s great except that ABMS is misspelled as “AMBS” in the last paragraph. It might be too long. They won’t take any response longer than 250 words and I couldn’t upload a Word document letter.

      Thanks and good luck!

      You’re the best.


%d bloggers like this: