About That “Mandated” MOC

People point out to me that Maintenance of Certification (MOC) and Maintenance of Licensure (MOL) are “mandated,” in our Affordable Care Act (ACA), Centers for Medicaid and Medicare Services (CMS), and the Joint Commission.

I think it’s wise to know where to find this information. Those who sign my petition, http://www.ipetitions.com/petition/iowa-medical-society-house-of-delegates/ ought to know where to put their hands on it too.

The Affordable Care Act (ACA) is a vast document, the “condensed” version being 974 pages long. I have not read the entire document, of course, but the link to it is http://www.hhs.gov/healthcare/rights/law/

I will be the first to admit that I don’t know how to read complex legal documents like this. I found MOC mentioned in the ACA, buried deep on page 278 (in the condensed version) in Title III, “Improving the Quality and Efficiency of Health Care, Subtitle A—Transforming the Health Care Delivery System; Part I—Linking Payment to Quality Outcomes Under the Medicare Program.” It’s in Section 3002 “Improvements to the Physician Quality Reporting System.” After the heading “Maintenance of Certification Programs” the document mentions a MOC program “…operated by a specialty body of the American Board of Medical Specialties…” The next sentence reads, “Authority.—For years after 2014, if the Secretary of Health and Human Services determines it to be appropriate, the Secretary may incorporate participation in a Maintenance of Certification Program and successful completion of a qualified Maintenance of Certification Program practice assessment into the composite of measures of quality of care furnished pursuant to the physician fee schedule payment modifier…”

So the context for MOC in the ACA is its role as an incentive payment modifier. In fact it might be easier to read it here, http://www.dpc.senate.gov/healthreformbill/healthbill53.pdf. MOC is mentioned in this version on p. 22 of this 66 page document in Sec. 3002. Improvements to the physician quality reporting initiative.

Improvements to the physician quality reporting initiative. Extends through 2014 payments under the PQRI program, which provide incentives to physicians who report quality data to Medicare. Creates appeals and feedback processes for participating professionals in PQRI. Establishes a participation pathway for physicians completing a qualified Maintenance of Certification program with their specialty board of medicine. Beginning in 2014, physicians who do not submit measures to PQRI will have their Medicare payments reduced. Section 10327 provides an additional 0.5 percent Medicare payment bonus to physicians who successfully report quality measures to CMS via the new Maintenance of Certification program and eliminates the MA Regional Plan Stabilization Fund.

Which brings us to the CMS part of the mandate for MOC, which you can read more about at http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS/Maintenance_of_Certification_Program_Incentive.html

I’m not sure how many physicians actually applied for the PQRI incentive system in 2013, but it seems to me a colleague recently obtained data by way of the Freedom of Information Act which didn’t make the system look very attractive.

The regulatory layer most people don’t mention is the Joint Commission’s Ongoing Professional Practice Evaluation (OPPE), a link to which is http://www.jointcommission.org/mobile/standards_information/jcfaqdetails.aspx?StandardsFAQId=213&StandardsFAQChapterId=74

The Focused Professional Practice Evaluation (FPPE) is another way of monitoring a physician’s competency. Useful perspectives on this as well as on MOC are found at:

http://www.fiercehealthcare.com/story/does-maintenance-certification-ensure-physician-competency/2013-01-04

http://www.fiercehealthcare.com/story/should-hospitals-require-older-docs-take-competency-tests/2012-07-31

Ironically, the OPPE at my hospital uses metrics that don’t apply to me as a psychiatric consultant. Therefore I’m invisible to the OPPE. Ironically, the MOC could be another way for my hospital to document my competency towards privileging. Imagine my dismay.

And if you want the perspective of the American Board of Medical Specialties (ABMS), you can always read it at http://www.abms.org/News_and_Events/Media_Newsroom/pdf/ABMS_Fact_sheet.pdf

What is mandated is not invariably practical or right and readers are now advised to visit http://www.changeboardrecert.com/  and http://www.aapsonline.org/

I don’t necessary agree with everything I hear from either side of this debate about MOC and MOL. But I think it’s important to know something about both.

And I’m so grateful to all who sign our petition.

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