Can ‘Maintenance of Licensure’ limit encroachment on the specialty?
Just when you think you've got a handle on MOC requirements, another M-word is poised to enter the plastic surgery lexicon. "MOL," or Maintenance of Licensure, is an idea being promoted by the Federation of State Medical Boards (FSMB) as a way of ensuring "the ongoing competence of physicians seeking relicensure." The proposed components of a statutory MOL regime would include:
- Reflective self-assessment - most likely some kind of CME-style "pre-test" - similar to those used in performance-improvement CME activities - that would be used to identify knowledge gaps or areas for updating skills.
- Assessment of knowledge and skills - this might be a combination of a test similar to the In-Service Exam and/or some third-party indication of clinical skills such as hospital privileges in a specialty. It is likely, but not certain, that MOC through an ABMS board would suffice for this component.
- Performance in practice - something similar to Part IV of MOC, where physicians must present clinical data from their practices. Again, state medical boards may accept ABMS MOC for this component as well.
The specifics of the proposal are currently being worked out by an MOL Implementation Group appointed by the FSMB. As the details begin to emerge, the Society will, of course, keep ASPS members updated. Needless to say, the FSMB alone does not have the power to implement such a regulatory scheme at the state level. To put such a plan into effect nationwide would require 50 separate pieces of state legislation and/or regulation. The particular requirements will no doubt vary from one state to another.
A benefit to plastic surgeons?
While this effort would represent, on the one hand, yet another new bureaucratic and regulatory burden on practitioners, perhaps there is a hidden opportunity embedded in the MOL movement that could strengthen the position of our membership on scope-of-practice issues. Simply put, if state medical boards are going to assess physician competency on an ongoing basis, they will need to adopt standards to measure competency.
To the extent that this exercise will be practice-based, i.e., you will need to show your competency in the type of medicine you actually practice, there is an opportunity for ASPS to make the case to state medical boards what "competency" in plastic surgery really means. It is already clear that the FSMB proposal intends to rely heavily upon ABMS board certification, which will certainly be helpful.
There will still be an open question, however, regarding the estimated 15 percent or more of licensed physicians who are not certified by an ABMS Board. Since this is also the group most actively encroaching on plastic surgery, it will be important for competency standards to be as specifically procedure-based as possible.
While there is not yet any pending state legislation to adopt an MOL regime, ASPS Health Policy & Public Affairs staff are already working to prepare policy that will go through our internal committee process so that we will be battle-ready when the time comes. We have already met with the new CEO of the FSMB and are talking with other medical specialty societies that also see this as an opportunity to combine forces at the state level.
We also hope that this approach will elevate our scope-of-practice advocacy program from being perceived by policy makers as a "turf war" to the much higher ground of professional competency.
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