The Word from Big Brother on Mandated CME

I thought I’d share the answers I’ve received from the Iowa Board of Medicine about the mandated CME requirements for chronic pain management and end of life care. I’ve previously posted these comments on the LinkedIn American Psychiatric Association (APA) discussion site.

They think psychiatrists “likely have patient populations in each of these areas…” That’s why psychiatrists were included, never mind what I’ve tried to convey about the low likelihood of psychiatrists actually providing what most of us think of as primary care interventions in these areas.

Some psychiatrists do provide primary care services, but the question is how much is enough to require the mandatory CME? Does getting lipid profiles, fasting blood glucose levels, and glycosylated hemoglobin levels on patients taking atypical antipsychotics constitute primary care, for example? This does raise the issue of integrated care arrangements and might have implications for collaborative care, although the latter usually doesn’t involve psychiatrists actually seeing the patients–those are more like curbside psychiatric consultations, not primary care.

You do have the option of indicating on the medical license renewal application one of three answers to the question about whether or not you’ve completed the CME:

“Yes”, “No”, “Not applicable”.

While you might think “Not applicable” for most psychiatrists would do, the trouble is licensees are subject to a CME audit. If you choose not to complete the CME and you’re audited, “you should be prepared to demonstrate that these areas of practice are not a significant part of your medical practice.” Again, what counts as significant? The board doesn’t specify.

I’ve asked IBM what a psychiatrist would need to document to show these CME activities are not applicable, should an audit arise.

It turns out that the Board’s goal is that all Iowa physicians obtain this continuing education if they routinely provide care to these patient populations. The list of physicians on the board web site provided was intended to provide examples of areas of practice that “routinely provide such care.” While the Board recognizes that not every physician in these specialties routinely provide such care, it will audit “a small number” of renewals annually to ensure licensees are obtaining the required continuing education. If you’re a physician selected for audit, it would be your responsibility to demonstrate to the Board that you don’t routinely provide care to these populations. In fact, the Board could review patient records and the Iowa Prescription Monitoring Program.

Be careful. Big Brother is watching.



  1. Seriously, they’re allowed to review patient records? That’s gotta be some kind of violation.


    • I agree. I fail to see how they can hold themselves to a different standard than the American Board of Psychiatry and Neurology who require us to click a check box to show that we’ve collected patient and peer feedback as well as PIP clinical activities to show we’re compliant with MOC–but then clearly admit they can’t request patient records as part of an audit because of confidentiality restrictions.


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