Wednesday, January 20, 2016

My response to ABIM’s “Assessment2020”

Two years after the rollout of its new MOC program, ABIM has heard the outcry of physicians in every form of medial despite deleting physician comments on their own website. However, except for temporary suspension of certain part of MOC, this forceful expansion of power did not stop. CMEs now are MOC-certified. ABIM also wants every EP lab to have an ABIM-certified director, a pattern that very quickly can be adapted to every other field. The complete time line of MOC can be found here.

With growing resistance and boycotting to MOC, emerging of an alternative board, and criticisms from societies such as ASN (So proud of ASN!!), ABIM did acknowledge its disconnection with physicians. It is now planning to implement changes to MOC in their Assessment 2020

ABIM has asked all societies to give feedbacks on this Assessment. So far I have seen the response from AAIM. It appears that there are many societies still baring the mindset of "MOC is here to stay. We have to work with it". As a practicing physician, I strongly believe that our societies have to give up this notion and start to question the legitimacy of ABMS/ABIM expanding their power without any limitation or oversight.

Here I want to give my feedback for ASN to consider when they give their response. I am encouraging every doctor to speak up and inform your society and ABIM where you stand, and what you envision the board certification should be in 2020.  

Before commenting on this “Assessment”, we need to clarify the role of different players in health care delivery.  

Certifications are to demonstrate that the trainee has acquired an acceptable level of knowledge and is entitled to practice in a medical specialty or subspecialty. Health care is multi-dimensional. Using one certification to gauge every aspect of health care delivered is unrealistic, and gives special groups the opportunity for unbalanced influence over physicians and hospitals, and completely devoid of checks and balances.  

The ABIM is a proprietary organization in the business of credentialing. They should not speak for educational entities, our scientific or clinical societies, our hospitals or our state medical boards. The legitimacy of the ABIM in promoting more credentialing processes such as MOC is therefore questionable, and raises significant issues, including potential financial conflicts.  

Next, let’s take a closer look at the quality of this “Assessment”. 

Dr. Baron claims that the “Assessment” is made by “outside expert”. I am not sure what he meant by “outside”. The Task force members are certainly not representative of practicing physicians.  Many have never taken the re-certification tests they are pushing for. 

There are many statements about engaging physicians that are questionable at best and inaccurate at worst. Here are a few examples:

“…we listened to our stakeholders (physicians…)” - The ABIM website deleted every single comment by physicians and has yet to show the public comment session.  

“…incorporated input about MOC though data” - ABIM, are any these data public?

“…social media outreach”, “…response on social media was steady but marginal” – they only selected what they wanted to hear

“…effort was made transparent on the ( website to inform open conversation” – how was or will this be accomplished?  There is no place to leave comments on the website every time I checked! In addition, how transparency it can be when ABIM is hiding its archives 

Based on these observations, I can’t help but wonder how the view of this Assessment 2020 is not selective and heavily vetted. It is biased and does not reflect practicing physicians’ opinion despite ABIM claims to the opposite. 

As a result, our societies need to take the opportunity to defend physicians, our profession, and importantly, to maintain the integrity of medicine in a proactive manner. Professional societies should be the leader and real representatives of physicians, not the follower of a self-appointed organization with a blatant financial conflict of interest. Our societies have the responsibility to protect health care, patients, and physicians from becoming victims of groups such as ABMS/ABIM. The ABMS/ABIM has been shown to be an organization with no credibility, devoid of accountability, and worst of all, no oversight whatsoever. Therefore, it is critical for professional societies and, to the extent it is possible, physicians, to eliminate the ABIM, and any other certifying agents’ ability and future attempts to arbitrarily raise certification requirements, and thus appoint themselves judge and jury about our profession's ongoing educational needs.  

On this basis, the important issues need to be addressed immediately are:

a.      Certification should be distinct from all quality measures.  “Quality” is such an easy, catchy, hard to dispute yet hard to define goal. It has become the passport for implementing variety of rules and regulations to health care. In the last few years, there is exponential increase of changes, such as “Meaningful Use”, mandating of ICD 10, etc, in addition to MOC. Not only these are changes caused significant disruption of care delivering, they are shameless abuse to physicians and our system. In UK. A nationwide strike is on due to controversial contract that will be implemented for “the promise of the same high-quality care every day of the week”. This kind of abuse is now to a critical level. Physician groups and professional societies must take every opportunity to establish oversight on quality measures proposed, and to advocate for legislation to stop intrusion into health care by certification organizations, or any organization or group, in the name of “quality”.

b.      Certification should be distinct from any insurance reimbursements. Associating certification by ABMS/ABIM with payment for services provided is of no value to patients or physicians, except serving only as leverage for the ABIM to pressure physicians in paying for and participating in MOC. The fact that ABIM has been workingwith insurance companied closely has said it all. Disconnect certification and insurance reimbursement should again be on all professional societies' advocating agenda. 

c.       Certification should be distinct from any credentialing, licensure and privileges managed by each state and hospital.

d.      All professional societies should dissociate their educational programs from the ABIM’s MOC. None educational program should be labeled as “MOC”.

e.      Professional societies should accept viable alternative to ABIM to help physicians to fight ABIM monopoly.

f.       Establish a contracture relationship between certifying agents and physicians so that any change in certification process needs to be approved by a professional society representing majority of practicing physicians.

So, here is my breakdown response to ABIM's Assessment 2020 and a certification plan suitable for Nephrologists:

ABIM’s stance 1: stated mission

1.      Mission 1 - “Enhance quality of health care”.

Response: Disagree


a.     ABIM has significant conflict of interest in quality measures due to its connection with National quality forum; ABIM should not be involved with any quality measures

b.     Nephrology is a subspecialty with quality assessments highly monitored and deeply regulated by both CMS and industry. Practice improvement and reporting is also being performed regularly. The report itself is 259 pages. There is no reason to add more.

a.      Leave quality measures to hospitals, state boards, and payers such as CMS. The AAIM response euphemized a similar point. “[Do] not try to measure everything that is part of “keeping up” and being a good physician.” AAIM also suggested more execution on the local level.

b.      There should definitely be no more added quality measures to avoid high cost, waste of resources, redundancy and importantly, burden on physicians and hospitals. 

2.      Mission 2 - “certifying internists and subspecialists who demonstrate the knowledge, skills and attitudes essential for excellent patient care.”

       a.   Partly agree with certifying “knowledge”;
       b.   Disagree with certifying “skills and attitudes”.


a.      Re-certification has not been shown to improve care after 25 years.

b.      No other country in the world requires repeated testing to maintain “certification” yet they have better and cheaper health care.

c.       Lifelong learning should not be limited to one organization’s agenda or trademarked product.

d.      A centralized “certifying” scheme for “skills and attitude” is an attempt to change the interactive and highly personal health care process into a machinery assembly line. This is posed threat to the freedom of physicians and their relationship with patients.


a.      Initial certification is acceptable;

b.      Re-certification should be abandoned

e.      Professional societies should work with ACCME to create robust CME programs.  Many CMEs are already test based, including ASN’s NephSap and KSAP.

f.        Procedures, team work, etc should be evaluated by each hospital.  

ABIM’s stance 2: recommendations derived from the Assessment 2020 Task Force

1.      “Replace 10 year MOC exam with more frequent assessment”

Response: Partly agree (with eliminating 10 year recertification test), but disagree with more frequent assessment


a.      A high stake re-certification test relies heavily on memory and has not shown to be of benefit. All other countries not using re-certification test have better health care outcomes.

b.      There has been a system in place for continuous evaluation of physicians’ activity of keeping up – CME, which has to be approved by ACCME. The activity is overseen by the hospital credentialing committee and state medical board. Adding MOC to the process is mere redundancy.


a.      Eliminate a high stake re-certification test.

b.      Initial certification test is OK and necessary

c.        “..potential ideas for changes of MOC” (Appendix H) are still attempts to adding more tests; ie test “every 6 months”. We should not support any of these MOC proposals. Again, many CMEs are test-based (ASN’s NephSap and KSAP). MOC adds nothing but payment to ABIM, the annoyances and distractions of performing irrelevant tasks, and taking irrelevant exams.

d.      As long as physicians are meeting CME requirements, they should be able to remain certified.

e.      Many of our ongoing learning efforts should be taken into consideration:

                                                                    i.            ACCME approved CME activities

                                                                  ii.            Professional society approved educational materials

                                                                iii.            Self-directed literature review. Potentially a system to track physicians’ self-directed learning should be developed by specialty societies, ACCME and journals, PubMed, etc.

                                                                 iv.            Lectures given

                                                                   v.            Daily patient care

                                                                 vi.            Teaching

2.      “assessment on cognitive and technical skills”

Response: Disagree

Recommendations: This should not be required for recertification

3.      “Recognize specialization”

Response: Agree

Recommendations: This should be left to specialty professional societies.

ABIM’s stance 3: 3 general goals of MOC according to the 2015 standards set by ABMS

1.         Include ACGME core competencies

Response: Disagree


a.         The 6 competencies are evaluated rigorously by all education entities (med schools, residencies, and fellowships), then by our employees, peers, patients and state boards. It is completely redundant for ABIM to mandate these additional evaluations.  Further, the downstream utility of these competencies outside of education is completely unproven

b.         It is unacceptable that ABMS/ABIM can "out of the blue" take any role in the certification process without evaluation/approval/input from the cohort subject to these policies.

Recommendations: Limit certification to knowledge

2.         To enhance the value of MOC

Response: Disagree


a.         This is a shameless and blatant business move by the ABMS/ABIM.

b.         MOC’s benefits have never been proven. Lacking scientific evidence for utility, they are impractical, irrelevant, arbitrary, and distracting to our profession, posing a significant burden to physicians.

c.          Mandating MOC fosters distrust towards our profession, implying we are not competent without this artificial metric.

d.         Multiple board certifications will be highly unlikely due to the egregious time and financial burdens of MOC. This is contrary to the goal of life-long learning.

a.         ABMS/ABIM raises unsubstantiated questions about CME; a system that is widely accepted as a valid tool for continued learning.  In addition, the fact that ABMS/ABIM can single-handedly change recertification requirements overnight -- without physician input -- is overwhelming proof that it is a monopoly with unfettered political and monetary power.  This behavior must stop. 

b.         There is no reason practicing physicians should have to pay ABIM yearly and essentially buy ABIM’s products in order to continue to work.


a.         The current MOC program, including all of parts 1-4 should be dismantled completely.

b.         Work with ACCME and professional societies on robust CME activity.

c.          Recognize alternative board.  Give us a choice! 

3.         To engage in continued quality monitoring

Response: Disagree


a.      Quality is being monitored constantly and closely already. Adding more QI only adds redundancy, increases unnecessary workload, contributes to physician burnout and importantly, compromise patient care delivery, as shown by the mandatory PIM and patient survey experience.

b.      QI has been utilized by the ABIM as leverage for escalating certification, which serves only the interest of the ABIM. As the result, the ABIM has unscrupulously profited from MOC


a.      There should be no engaging of MOC and quality monitoring

b.       Quality measures should be only be performed by individual institutions (hospitals, dialysis units, etc), state boards, networks, etc. PIM and patient surveys are part of QI and therefore should not be demolished and disassociated with certification.


1.      Professional societies should support initial certification and lifelong learning through robust CME activities tailored to each individual physician’s need, and will continue to work with other professional societies to assist Nephrologists’ need for high quality CME materials. 

2.      ABIM as a certifying organization should continue to provide initial certification. However, re-certification has not been shown to provide any benefit to patients, physicians, or health care. On the contrary, it has become a major distraction to patients, physicians, and care delivery. The Assessment 2020 therefore should focus on initial evaluation of trainee’s ability of utilizing acquired up-to-date knowledge, engaging critical clinical reasoning, and making sound clinical decision. Recertification test and MOC should be eliminated. 

3.      Health care delivery is a complicated process involving not only physicians. The notion that a certificate of a physician would encompass every aspect of the care patient received is impractical, self-serving, certainly conflicted by ABIM’s financial interest. ABIM or any certifying agent’s ability of escalating their business rapaciously is unjustified. Professional societies should work together to advocate for stopping any intrusion to health care, potentially working towards legislation such as a "Physician Practice Freedom Act", which might have already started.


  1. I was wondering if you had seen the ASN response in Kidney News.

    1. Yes, and it is a great start. That editorial is clickable at the 2nd paragraph.

  2. Great analysis ! I personally boycotted the ABIM and now use the NBPAS. I hear there has been a Federal lawsuit against the ABIM ; it will soon be publicized but there are many victims of this coercion and we must stop it or lose our futures to non-working MDs who are false prophets.

    1. Thank you! Hope everyone will give the message to their society too!

  3. The ABIM/ABMS is everyone's nightmare!

  4. Question: Does ABIM/ABMS have a sincere wish to listen as they stated?
    In my experience, unfortunately, the answer is no.

    1. Based on their behavior so far, it is definitely a No. Just hope everyone can see that and stop doing any MOC, stop waiting for them to change. However, we need our societies to stand with us and fight back.

    2. I agree. The specialty societies need to step up to the plate and go to bat for physicians. AACE, for example supports certification only and said we need to END MOC.

      Individualized CME is preferred by all. Except the ABMS executives who are paid millions to create fables for us.

      Individualized CME, which is already tied to state licensure is more relevant, time friendly, and cost effective.

      I would go further and change "initial" certification back to what it was initially - a totally voluntary certificate to decorate an office wall - but only if one wants it.

    3. ABIM: Quality Assessment or Racketeering?

      Money is the root of the quality assessor's evil - this includes MOC, the financial scandals and the politicized activities of the ABIM/ABMS.

      We need to end the medical boards' corruption by taking the money out of it - make it totally voluntary in nature again.

      No executives. They become political pawns and corrupted by corporate greed. We can not tolerate this corruption any longer. Only a highly-vetted volunteer board comprised of members who are actually practicing physicians is acceptable to us.

      No deans or corporate/government proxies, like Cassel, Baron, Wachter, etc. These folks violated the system and turned ABIM into THEIR PARTISAN TV CHANNEL complete with advertisements courtesy of the ABIM Foundation.

      High ranking professional medical politicians controlled physicians by inventing the ELECTRIC SHOCK COLLAR known as MOC. This is disgusting to the core.(ACGME/RRC is another sick BEHAVIORIST'S PIGEON MAZE, also having its corrupt system of carrot and stick along with outrageous compensation for the elitist executives.

      Another element to consider is there is apparently no affection in the harsh "quality system" as mandated by the ABIM/ABMS. There are no humanistic practices or motivations behind the ABIM that are obvious to anyone. This may be a result of the "far removed from practice" executives and their narcissistic tendencies" who remain aloof and silent on things that really matter.

      Even Robert M. Wachter, an assessment 2020 committee member, in the New York Times boldly confirms this lack of humanism when he states that we lack love in the assessment of quality. We are missing the mark without this love when everything and everyone is simply quantified and turned into numbers.

      Wachter is inspired by a quote from the "father of quality assessment" when he says, "Ultimately, the secret of quality is love."

      Wachter takes Donabedian completely out of context and cuts him short from stating the real problem that money and greed prevent real quality. Greed and political ambition stand between the physician and patient in total annihilation of that sacred relationship and the qualitative dimension we strive for.

      Here is the father of quality assessment, Avedis Donabedian, in his own words:

      "It is the ethical dimension of individuals that is essential to a system’s success. Ultimately, the secret of quality is love. You have to love your patient, you have to love your profession, you have to love your God. If you have love, you can then work backward to monitor and improve the system. Commercialism should not be a principal force in the system. That people should make money by investing in health care without actually being providers of health care seems somewhat perverse, like a kind of racketeering."

  5. ABIM's trademarked "we are listening surveys" are a byproduct of the bogus need for more MOC money. Assets are evaporating and revenues are decreasing, while costs are increasing - mostly due to rises in the number of executive positions and sky-high financial compensation.

    Couple this with grandiose political ambitions and their personal greed and it creates the perfect storm for the nightmare to continue.

    I personally do not want one more minute of relationship with these current ABMS liars/deceivers or their self-appointed predecessors - the frauds who invented it all.

    Do you?

    It is all just more waste of time. ABIM elites are deceiving physicians into believing that they are included in the new medical order - a medical hierarchy where bureaucrats get more and more power and money.

    If one studies what is going on there are already increases in organizational complexity and the unfettered number of new and improved administrative improvements or "operational restructurings", which takes the practicing physician out of the loop forever.

  6. The ABIM and ABMS wielded this unquestioningly illegal re-certification process as part of a conscious and deliberate plan to grow their personal net worth at the expense of the working class physicians who actually care for and about patients.

  7. They and their bogus MOC cause burnout without reprieve for physicians.

  8. The ABMS umbrella supports special interests with corrupt corporate motives. They illegally (according to actual IRS rulings) participate in disruptive political activities.

    Creating and maintaining close ties to their elite banksters and key stakeholders, they are simply deceivers. Why would the ABIM suddenly pretend to be concerned about "unruly shrill voices" and "we got it wrong" first responders now.

    Truth is, they don't care about anything except themselves and the survival of that "elite high standard of living" for themselves and their "corporate cronies".

    ABIM/ABMS "don't give a rats tail" about physicians, patients or anyone's happiness - let alone our health or civil liberties.

  9. It's a certified sweat shop!January 22, 2016 at 4:52 PM

    Personal experience: I have called on the phone requesting a conversation with various executives, because I felt a vital need to discuss various important issues.

    No getting through to anyone! Except the abused underpaid folks at the phone pool stations. They are the only real people there who will try.

    That's because most of the phone people are dirt poor. They understand what it means to be ignored. Except when the New York Times needs an underling to photograph with the BIG GUY
    Rich Baron. How weird is that!

    Maybe the rich baron could give the "kind phone folks" a little bit more to take home from out of his "big bowl".

    The apparent inequity at the ABIM makes me suffer every time I call, because I grew up in Philly.

    Do you honestly think these elite ABIM executives get it? Do you believe they will ever learn how to give and not just take?


    MOC IS their personal gravy train. It is the ABMS' means of control over physicians and political power.

  10. Question: How can the ABIM respond to concerns or issues if there is no meaningful access and direct dialogue?

    In my experience, they offer no direct access and never will. It is time to abandon them because they abandoned us long ago. They lied to us over and over.

    Their surveys are a distraction to buy them time. Their appeasing words are a head fake because they have been exposed.

    Remember, they did not disclose conflicts of interest repeatedly. They continue this practice of deceit. They will not share their cards or put them on the table even though the ABIM demands this of us. "House rules" for them are where they control all the cards.

    The 2020 task force is severely biased. Members are abusive and are/have been involved in harming physicians - not serving them.

    Others on the committee are simply passive or permissive. That is just as concerning. Uncritical and non-thinking individuals are dead weight and resistance to any meaningful change. They are there as book holders just to support the status quo of money and political power.

    What am I saying? It is extremely crippling to our trust when the key members are not disclosing/admitting their conflicts of interest to us.

    I will leave it for others to discover and write about what the conflicts of interest are. One must be active and comb through ABIM court and corporate documents to find out, but the information is there.

    I suspect there is an investigation already about many of these people concerning their conflicts and political activities, so just in case there is a DOJ/IRS investigation currently in progress, I will refrain from speaking further about this.

    However, it is obvious that the ABIM will never disclose WHAT Assessment 2020 Task Force committee members have done/been involved in to disqualify them from such participation.

    This non-disclosure and failure of ABIM to vet their executives and officers is the kind of deceitful practice which has destroyed all trust in the ABIM and ABMS.

    The personal involvement with activities/relationships are egregious enough that many of them should have recused themselves long ago.

  11. Stop paying into the MOC-ERY. The ABIM Foundation has illegally absconded with our money. There is ample proof of this.

    It is time to get that money back. Sue the pants off of them.

    It is time for the corrupt execs and officers of the ABMS to pay. Not us!

  12. Thank you for your very fine assessment of 2020, Dr. Tangles!