Saturday, January 24, 2015

Stop talking and start taking ACTIONS on MOC

It is exciting when there is the appearance of progress. The publication of articles that raise doubt about the utility of MOC brings hope. These have appeared in the New York Times, NEJM, JAMA, etc. The original petition is a success, having collected more than 21,000 signatures. The excesses of the ABIM have been revealed and its integrity questioned. Progress has been made with launch of an alternative board, the NBPAS.

In reality, there has been little progress. The threat posed by MOC and resistance to MOC remains unchanged. The other petition, “a pledge of non-compliance with ABIM’s MOC, has only gathered a little more than 7,000 signatures. The disappearing 14,000 signatures is nothing but “when idealism meets realism”. Noncompliance risks the loss of income, collapse of career, theft of our freedom and years of work, control of our lives, and the stifling of our passion and dreams. Unfortunately, there has been no modification of the requirements for MOC. The ABIM remains inflexible. The only change is that the poorly designed PIM now has a new name–“patient voice”.  

Doctors, it is time to stop talking. It is time to take more aggressive efforts!

First, we need clear goals. Do they include modifying current ABIM MOC proposals, abolishing ABIM MOC, creating an alternative MOC, or stopping the requirement for recertification? What would be the priority? What would be the most achievable? What would be the most ideal? Importantly, what would be our bottom line? What is our plan if the line is crossed?

I do not believe that our goals can be achieved by working with the ABIM. It is clear the ABIM was central in the design of ACA MOC requirements given the similarity of language in ACA and ABIM documents. Thanks again for Dr. Wes’ extraordinary work. WE are being naïve if we still put all our hope on ABIM, who definitely benefits from these MOC tests.  

Therefore, we do not have much choice but relying on an alternative pathway. The NBPAS is new and inexperienced, but I have hope that we can work with it to bring about change, if we act together and stay united.

These are my proposals:

1.      Let’s all apply for NBPAS certificate, no matter how many years your ABIM certificate is valid for. This is to support the new board and to send strong message to everyone.

2.      All of us should start to advocate for NBPAS Certificate as an alternative to the ABIM immediately. We must develop a plan to educate everyone on this issue. Edit this letter and send it to our credentialing committees, state medical societies, Chiefs of Staff, and insurers. Talk to everyone on the committee at every opportunity. This will be a difficult fight. However, if we can achieve acceptance of NBPAS certification, ABIM monopoly will break. ABIM MOC and recertification will become irrelevant.

3.      NBPAS should work to address the ACA requirements (see red and blue squares) ASAP. I believe that ACA requirements can be met by an alternative MOC program (see green squares).  There needs to be a program but not necessarily ABIM MOC, and there is definitely no mandate for repeated testing. We could push for using the hospital surveys that are already in place. If we have to do a required PIM at 10 years, it will painful but tolerable.
Screen shot of The Affordable Care Act (ACA) modified Sections 1848(k) and 1848(m) of the Social Security Act which defines how CMS pays physicians for their services.
4.      We need recognized, respected, influential physicians of other specialties to be on the NBPAS board and subspecialty board. Methods to ensure and facilitate practical and meaningful lifelong learning are to be developed. Please volunteer! It is not just for your colleagues, it is for yourself as well. We have a lot of such wonderful people. Do not underestimate yourself. Look at our Surgeon General!

5.      Because NBPAS is still new, we can be more involved and help constructing it into a organized and approachable structure, one that remains responsive to the needs of practicing physicians. Legal and financial expertise will be needed during this process.

 
I want to remind you again to stop wasting time on ABIM and its subspecialty societies. Most do not care. They have no motivation to resist MOC. To this day, they are still promoting MOC despite the outcry of thousands of physicians! It is time to move forward deliberately. Let us start taking steps.

P.S. some extra info provided by another physician:
The ACA sections that deal with MOC:  They are so specific that for practical purposes MOC as sold and promoted by ABMS and ABIM and member boards is enforcing the LAW. NBPAS will have no choice but to do the same.
Go to the PPACA as passed:
http://www.gpo.gov/fdsys/pkg/PLAW-111publ148/pdf/PLAW-111publ148.pdf
Then go to page 844 approximately:

SEC. 10327. IMPROVEMENTS TO THE PHYSICIAN QUALITY REPORTING SYSTEM. 
‘‘(3) 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, as described
in section 1848(p)(2) of the Social Security Act (42 U.S.C.
1395w–4(p)(2)).’’.

Notice that the wording is the same as that of the Boards. In the last part of that section, PQRS/MOC requirements are coupled to medicare physician fee schedules. NBPAS will not be able to bypass this.