Friday, May 21, 2010

FSMB Discusses the Collection of Physician Data under the Proposed MOL Framework

In April, the Federation of State Medical Boards (FSMB) released a report outlining the implementation of the Maintenance of Licensure (MOL) program. Many NAMSS members have already started to ask questions about how the MOL may affect the credentialing process.

Frances Cain, Director of Post-Licensure Services for FSMB has provided the following information. Feel free to leave any questions or comments that you may have for FSMB and Ms. Cain in the blog's comment field.

Although FSMB has adopted a framework for MOL, there are still some questions as to how state medical boards might implement MOL and how it may look “on the ground” for physicians. The FSMB has recently established a MOL Implementation Group, which has been charged to create a template to assist state medical boards in implementing MOL. This will include a more detailed exposition of the options for complying with MOL that fall outside of Board-certification. FSMB hopes to have this report out for comment in the fall, and will send a copy to NAMSS.

There have been many questions about the types of data physicians may have to collect in order to comply with MOL and how that information may be used by the state medical board. To date, all of the committees and workgroups that FSMB has convened to explore the issue of MOL and to develop the MOL framework that was adopted by our House of Delegates last month have all been very sensitive to the concerns of physicians about the privacy of their data. As such, the final report and MOL recommendations that were adopted by FSMB as policy includes the following statement:

“Practice performance data collected and used by physicians to comply with MOL requirements should not be reported to state medical boards. Third party attestation of collection and use of such data (as part of a professional development program) will satisfy reporting requirements.”

Therefore, under the proposed MOL framework, physicians could be able to comply with MOL through participation in the very same activities in which they are already participating (e.g., CME, procedural hospital privileging, 360 evaluations, medical professional society/organization clinical assessment/practice improvement programs, CMS and other similar institutional-based measures). Participation in these activities could be verified by the state medical board through third-party attestation, rather than direct reporting of the data. A more detailed listing of proposed activities that physicians could use to comply with each of the three components of MOL are provided in the MOL Advisory Group report (see pages 79-80 of the adopted MOL policy report at

To use the example of CME, under MOL a state medical board may choose to require that CME used for license renewal be related to the physician’s area of practice; however, the board could use the same system it currently has in place (i.e., a random audit of a small group of licensees) to verify physicians’ compliance with those requirements.

Although central to the FSMB’s proposed MOL framework is the concept that each state medical board would adopt its own guidelines for applying MOL, through our Implementation Group and future pilot projects with individual state medical boards, we would hope to develop recommendations that will be consistent across state lines. MOL will be an “evolutionary” process and will require much thought such that it provides public protection while paying attention to the concerns of physicians and the resources available to state medical boards.

FSMB encourages input from all stakeholders as we proceed with this task.

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