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Comments on IMLCC's proposed Expedited Licensure rule: (48 total)

Comment 1:
Dear Mr. Bowen:

I am writing to share my disdain for the proposed Compact as it currently stands. Physicians have spent countless hours in training and certification to afford them the ability to practice medicine. As part of our ongoing training we continue to obtain continuing education credits, advance our education through academic and collegial pursuits, and collaborate with other physicians to better serve our patients and our communities.

While I am proud of my board certification, the current recertification process and MOC process is outdated and serves only as a punitive method for practicing physicians. The evolution of medical knowledge and the fund of its body of work is expanding at an epic rate, and the current mechanism fail to capture the volume of work and progress that is occurring. The Compact does not take into account any formal data or scientific proof that recertification exams have a link to excellent (or for that matter, even standard) medical care. Requiring something that lacks sufficient evidence seems preposterous.

There are a variety of certification processes that maintain current and up to date standards for competency and the ABMS is an antiquated group lacking in any evidence to require their recertification. Please consider removing this requirement as you move forward with your discussions.

Regards.

Gerry

Gerard J. Stanley, Jr., M.D.
Medical Director/Cosmetic Surgeon
 
Comment 2:
Dear Commissioner Bowden,

I am writing to make suggestions on a simpler and more ethical approach to an interstate medical license compact. The current proposal leans in favor of benefitting the American Board of Medical Specialties and related organizations, ultimately forcing physicians to comply with expensive, demoralizing and clinically irrelevant testing and certification.

I suggest removing any requirement for board certification. Until that can be accomplished, it would be preferable to a) allow other alternative certification and recertification boards like ABPS and NBPAS to meet the requirement and b) reinstate previously considered language allowing past certification to meet the requirement: “Currently holds, or has previously obtained specialty certification."

Respectfully,

Manisha Wadhwa,MD
 
Comment 3:
Dear Commissioner Bowden:

I am writing with concerns about the requirement in section 5.4(1)d of the rule, mandating certification exclusively by ABMS- or AOA-approved boards . I request this be removed and the related provision in the Compact should also be stricken as:
a) No single medical board in the United States requires such certification as a licensing requirement.
b) It creates a discriminatory process for physicians with time-limited certification.
c) The American Board of Medical Specialties (ABMS) & AOA (American Osteopathic Association) have been subjected to significant criticism regarding anti-competitive practices, financial impropriety, and misrepresentations about quality improvement due to certification and maintenance of certification.
d) Two other certification boards, NBPAS and ABPSUS, exist in the USA and multiple exist internationally. It is notable that the Compact and Commission fail to allow physicians certified by these entities access to Compact licensure, especially given the fact that there is no indication the certificates matter at all in any way to quality or improvements in care.

Is the omission of these alternatives, in light of the close ties of the FSMB and ABMS, the result of inappropriate and potentially illegal collusion of the various entities involved in writing the Compact and its rules and those benefiting financially from the implementation of the Compact?

There may be different levels of concern by physicians currently, because at present physicians are effected to different degrees as many have been grandfathered-in and not required to participate in the maintenance of certification process which continues to roll out and affect more and more physicians. It did not personally effect me until 2014. Now that my certificate is time limited, not participating in this supposed voluntary process of maintaining certification prohibits me from maintaining hospital privileges. Now I see it would prohibit me from getting an expedited license through the Interstate Medical Licensure Commission. Please consider the practical and legal applications of the language of these requirements.


Lisa Frappier DO
 
Comment 4:
September 19, 2016

Comments on Interstate Medical Licensure Commission Proposed Administrative Rule Chapter 5, “Expedited Licensure.”

To: Commissioner Mark Bowden, Interstate Medical Licensure Compact Commission, Bylaws and Rules Committee Chair and Committee Members

Dear Commissioner Bowden,

Thank you for the opportunity to provide comments on the Proposed Administrative Rule on Expedited Licensure.

We would like to raise a number of concerns about the proposed rule for the committee to address.
The rule. Leaves out residents and recent graduates. There should be a carve out exemption for them for a limited time, lets say six years after residency.
There should be no linkage between licensure and board certification!

1) The model proposed for expedited licensure is unnecessarily complex and bureaucratic. Consider that the nursing licensure compact allows for licensing of nurses in all member states with ONLY one license while the Interstate Medical Licensure Compact requires a physician to license in each and every state at substantial cost. The Interstate Medical Licensure Compact along with the proposed rule does not meaningfully reduce the costs for multi-state physician licensure.

In addition, nurses are now increasingly practicing medicine and the structure and rules of the Interstate Medical Licensure Compact creates selective disadvantages to physicians in competition with NPs.

Congress has also introduced legislation, H.R.3081 - TELE-MED Act of 2015, to allow Medicare patients to receive care from a Medicare-enrolled physician licensed in any state. Similar reciprocity is granted to U.S. military and VA physicians, thus demonstrating the cost-effectiveness and safety of allowing cross-state medical practice, without the need for the complexities added by the Commission under development. Legislation granting reciprocity to physicians serving athletic organizations has been passed or is under consideration in numerous states and the U.S. Senate just this month introduced HR 921, the Sports Medicine Licensure Clarity Act of 2016, to institute such reciprocity on a federal level.

2) The requirement in section 5.4(1)d of the rule, mandating certification exclusively by ABMS- or AOA-approved boards, should be removed and the related provision in the Compact should also be stricken as:

a) No single medical board in the United States requires such certification as a licensing requirement.

b) This creates a discriminatory process for physicians with time-limited certification.

b) The American Board of Medical Specialties (ABMS) & AOA (American Osteopathic Association) have been subjected to significant criticism regarding anti-competitive practices, financial impropriety, and misrepresentations about quality improvement due to certification and maintenance of certification. By the ABIM’s own admission "they got it wrong" and have repeatedly changed their recertification requirements. The Commission must ask if they will ever "get it right"?

3) “Primary Source Verification” is defined in item “dd” of the proposed rule’s definitions and the definition includes reference to the FSMB’s FCVS. However the term “Primary Source Verification” is not otherwise mentioned in in the proposed rule text. Our concern is that the definition signals the possibility that the additional purchase FSMB-controlled services, like the FCVS, might be required for Compact participation. A need to register with the FSMB's FCVS would represent an additional overcharge as the rule already proposes a current "letter of qualification" from the medical board in the state of primary licensure. This letter should satisfy any and all need for primary verification of any and all documents. Presumably all have been already primary verified by the home state licensing board. This possibility suggests the inefficiency and blatant and primary attempt of FSMB to increase revenues unnecessarily to their organization.

4). Section 5.6(1)b of the proposed rule states that a “letter of qualification is valid for 365 days from its date of issuance to request expedited licensure in a member state. There shall be no waiver of this time limit."

It is unclear what demands are to be set to allow issuance of such "letter of qualification" after the first 365 days have passed. If a physician seeks Compact licensure in an additional state after the expiration of the letter presumably the physician will be required to apply again with his principal state of license to obtain another letter of qualification. Would this mean that the physician’s ABMS- or AOA-approved certification would have to be current when seeking a new letter? Despite the provision in 5.4(1)d that current certification is only required on the initial determination of eligibility, the 365-day rule creates ambiguity that begs clarification.

And most if not all states have licensing requirements lasting periods of 2 years-much longer than 365 days. How does this 365-day rule impact physicians with existing multi-state licenses at the time of their initial Compact eligibility? If such physicians plan to seek future “expedited” licensure via the Compact in these states, and the relevant renewal dates are more than 365 days in the future, will they again need to obtain a letter of qualification?

I have additional concerns, beyond the scope of this particular proposed rule, that raise questions about the solvency of the Compact. We will name just two of many: 1) the FBI questioning the authority of the investigatory powers delegated to the non-government regulatory entity, the Interstate Medical Licensure Commission. 2) concerns about the appearance of pay-for-play created by FSMB-lobbying of Congress and federal agencies and subsequent federal taxpayer-funded grants received by FSMB for Compact operational funding.

In conclusion, as the Compact preserves the existing requirement to purchase multiple licenses in every state of practice, with the addition of additional service fees, and the enormous costs associated with the board certification mandate, not to mention the possibility of requiring the purchase of other services like FCVS, the entire Compact as structured is not a meaningful solution to the problem it seeks to solve.

Without a significant reworking of the Compact concept, perhaps using the more efficient nursing compact as a guide, physicians may very well find it more cost effective, and even faster, to bypass the Compact and continue to license directly with each state of practice.

Thank you for taking my comments into consideration. We look forward to the Committee’s response to my concerns.

I am representing my own perspective and concerns separate and distinct from official policy and positions of the American Society of Anesthesiologists and the RI Society of Anesthesiologists.

Sincerely,

Brett Arron, MD

Brett Arron, MD
Department of Anesthesia
Lifespan Miriam, RI & Newport Hospitals
Providence, Rhode Island

Clinical Assistant Professor
Department of Surgery (Anesthesiology)
Alpert School of Medicine
Brown University

Executive. Committee
RI Society of Anesthesiologists

Director
American Society of Anesthesiologists (ASA)

Vice-Chairman
ASA New England Caucus

Committee on Patient Safety and Educationv American Society of Anesthesiologists
 
Comment 5:
Mr. Bowden,

Please find attached American Well’s comments on administrative rule Chapter 5, “Expedited Licensure.”
Thank you, in advance, for the Commission’s consideration, and please let me know if you have any questions.

Best,
Kofi

Kofi Jones
Vice President of Government Affairs
American Well


Attachment
 
Comment 6:
To the commission;

1. They should work to remove the Certification requirement entirely.
2. Until they can remove the requirement they should a) allow other alternative certification and recertification boards like ABPS and NBPAS to meet the requirement and b) reinstate previously considered language allowing past certification to meet the requirement: “Currently holds, or has previously obtained specialty certification.”

- Danny Wilkerson
 
Comment 7:
Marsha Y Blakeslee, D.O. comments to the Interstate Medical Licensure Compact

Comment Attachment

 
Comment 8:
Spyrie D Mays, MD, FACS comments to the Interstate Medical Licensure Compact

Comment Attachment

 
Comment 9:
Charles C Adams, MD comments to the Interstate Medical Licensure Compact

Comment Attachment

 
Comment 10:
South Dakota's comments to the Interstate Medical Licensure Compact

Comment Attachment

 
Comment 11:
Montana's comments to the Interstate Medical Licensure Compact

Comment Attachment

 
Comment 12:
Commissioner Mark Bowden:

I am a board-eligible Obstetrician/Gynecologist who has been practicing locum tenens (temp fill in) in rural areas for the past 6 years of my career. In many areas, like the one I'm in now, in northern Indiana, I may be the ONLY Ob/Gyn in the entire county. Sometimes, I'm the only Ob/Gyn in several counties. I am licensed in 5 states, have no malpractice claims, and love what I do. I am *not* board certified, am I am no longer interested in seeking board certification, as it has obviously lost it's true value and has become nothing more than another hoop to jump and a money grab. Due to this and the current onerous process & expense of board certification, maintenance of certification, ongoing treat of overwhelming obstetric litigation, and the discriminatory process of excluding non-board certified, residency-trained, physicians, I will be stopping the valuable service I have provided to rural and low-income women for the past 6 years, at the end of this month. I am dropping Obstetrics, and will move into a less hectic lifestyle and pace.....mostly because I have experienced nothing but expense and hassle when dealing with government entities, licensure, insurance, and board certification. Frankly, in as many words, it's just not worth it, and not what I signed up for. The state and federal government has made it easier and easier for non-physicians to enter our scope of practice, but have only increased our burdens.

By requiring Board certification, by virtue of initial, on-going certification, or maintenance of certification, the commission is effectively discriminating against, and promoting the loss of potentially tens of thousands of working, qualified, safe physicians. Multiple choice exams due not make "good doctors", any more than "common core" makes for good engineers. While the Compact would be helpful in allowing physicians such as myself to provide valuable services to communities in need, any wording of mandatory Board Certification should ABSOLUTELY BE REMOVED. Doctors are smart folks. And we can be smart doing a hundred other jobs. Please don't run the rest of us out of the field simply so cronyism can continue at our elite levels.

Respectfully, Karyn Tapley, MD
 
Comment 13:
Hello Mark-

Wanted to give you feedback on the proposed rule. As a practicing physician who has opted out of American Board of Internal Medicine (ABIM) certification in favor of certification by an alternative Board, the National Board of Physicians and Surgeons, largely due to the onerous and irrelevant busy-work imposed by the Maintenance Of Certification process required by the ABIM, I feel it is arbitrary and excessively burdensome to require applicants to the FSMB certification process to be certified by a particular Board. In the same vein, even the remote idea of requiring ANY Board certification for professional licensing smacks of an unprecedented and unwarranted power grab on the part of parties involved. The FSMB must not be allowed to rewrite regulations and policies that have been in place for a very long time, to the detriment of the conscientious members of my precious profession.

Scott Cunningham, MD
3540 S. Poplar Street
Suite 305
Denver CO 80237

 
Comment 14:
Dear Commissioner Bowden,

Thank you for soliciting feedback on the proposed rule under consideration by the Interstate Medical Licensure Commission.

Attached are comments submitted on behalf of the Association of American Physicians and Surgeons for consideration by the committee.

Sincerely,
Jeremy Snavely
AAPS Business Manager

Comment Attachment

 
Comment 15:
Dear Commissioner Bowden,

I would ask that the MOC requirement be removed for the following reasons.
1. There is no oversight of MOC issuing institutions. Where are the checks and balances? Why is there no judicial review?
2. MOC generates a financial conflict of interest between professional societies and their ABMS boards.
3. MOC wastes health care resources, time, and money of hard working physicians.
4. There is no evidence based data to commend MOC.
5. The premise that MOC would increase safely is but a ruse for financial gain, control, and ownership (since control is the economic definition of ownership) of healthcare physician practices.

Thank you letting me communicate my concerns.

I would also ask that until the MOC plank is removed, that other boards such as ABPS and NBPAS be included. Furthermore, it seems that "currently holds, or has previously obtained specialty certification" was removed and should be reinstated.

Sincerely,
Holly Fritch, M.D.
Unlimited time certificates in Internal Medicine and Dermatology Without a financial conflict of interest...merely wishing the best for the medical profession and our patients

 
Comment 16:
Dear Mr. Bowden,

I am vehemently opposed to the Interstate Medical Licensure Compact proposal because it is unnecessarily unfair and unworkable.

Neither physicians nor other professionals, having been licensed by their respective states, should have the onerous burden of taking examinations for medical Board Certification in order to practice medicine across state lines. Board Certification may or may not be truly meaningful or important, and it certainly is not related to whether a physician in good legal and professional standing should be permitted to practice medicine across state lines. I am a psychiatrist in rural Northern Utah about forty miles from the Idaho border and fairly close to Wyoming. Psychiatrists are scarce in these parts, relative to the demand. By being able to practice in other states, I could actually fulfill a public health need and save suffering patients the ordeal of traveling possible a hundred miles in order to get treated.

I support EVERY WORD of the protest you received from the Association of American Physicians and Surgeons. The specialty boards are not generally focused on the best interests of physicians and patients. Board Certification does not help sick people get well. This proposal is discriminatory against physicians, as other professionals are not subjected to such unreasonable requirements in order to practice widely in response to public demand and need.

Thank you very much.

Sincere,

Laura Fisher, M. D.
1590 Canyon Road
Providence, UT 84332

 
Comment 17:
Dear Commissioner Bowden and members of the Interstate Medical Licensure Commission:

I have just learned that there is a proposal to adopt "expedited licensure regulations" that according to paragraph 5.4.(1)d. - - require specialty board certification. While I personally do hold a lifetime board certification from an ABMS member board, and this proposal is not likely to affect me personally, I am deeply concerned for my younger colleagues who have time limited certificates.

No state requires or should ever require a specialty board certification for a medical license. Please do not permit the corrupt and racketeering American Board of Medical Specialties (ABMS) - - or the osteopathic equivalent - - to impose specialty board certification as a requirement for interstate or any other medical licensure.

Also, the Commission needs to know that there are other certification and re certification boards, for instance the National Board of Physicians and Surgeons (NB PAS), which meet the needs of many doctors who are fed up with the self serving and corrupt profiteering by ABMS member boards. The ABMS has required their member boards, at the expense of their diplomats, to conform to ridiculous requirements to repeatedly take "re-certification" exams and participate in "MOC" programs - - with no evidence that either do anything to improve the quality of doctors, but with lots of evidence that they enrich the ABMS board members and increase their undeserved power.

I am also concerned that the proposed regulations appear to require physicians to continue to pay each separate state in which they wish to be licensed a separate state license fee, in addition to an interstate Federation of State Medical Boards fee. The point of an interstate medical license should be to lower costs by having a single low fee that provides a license for all states. I am sick of being milked like a cash cow by every state in which I keep a license.

Walter Wood, MD, FAAD
1709 Berkeley Way
Berkeley, CA 94703

 
Comment 18:
Commissioner Bowden,

I am writing to comment on the Interstate Medical Licensure Compact before the 23 Sept deadline. The current wording and requirement for Certification creates a situation in which Physicians who are not so “Certified" and/or were saddled with “time-limited” Certifications would be (unintentionally? intentionally?) excluded from participation. As you are undoubtedly aware, the existing nursing compact and model APRN compact (certainly inspiration for the effort to create same for Physicians) require only ONE state license for practice in other States that are compact members. The FSMB driven compact requires Physician licenses in EACH individual state, along with the extortionary fees for “licensure”, which obviously severely restricts the ability of such a Physician to compete with advanced practice nurses who often collect similar fees for services considered specifically in the IMLC.

I would encourage the removal of any certification requirement all together. Until this is accomplished, alternative certifications, such as NBPAS and ABPS should be allowed, and/or the previous language about "currently held" or "previously obtained" specialty certification should be reinstated.

Licensure should never be tied to the caprices of an organization such as the ABMS (or member boards) after the body of evidence regarding their anti-competitive practices, financial improprieties, misrepresentations regarding quality as a function of certification, etc. has come to light.

Certainly there are many other issues that are problematic in the consideration of the IMLC. I don’t wish to imply that the “certification requirement” is the entire concern. It is but the starting point I have time to address with you today.

thank you,

-Dr. Jef Fernley
Ocean City, Maryland

 
Comment 19:
Dear Commissioner Bowden,

I am writing to make suggestions on a simpler and more ethical approach to an interstate medical license compact. The current proposal leans in favor of benefitting the American Board of Medical Specialties and related organizations, ultimately forcing physicians to comply with expensive, demoralizing and clinically irrelevant testing and certification.

I suggest removing any requirement for board certification. Until that can be accomplished, it would be preferable to a) allow other alternative certification and recertification boards like ABPS and NBPAS to meet the requirement and b) reinstate previously considered language allowing past certification to meet the requirement: “Currently holds, or has previously obtained specialty certification."

Respectfully,

Janis G. Chester, M.D.

 
Comment 20:
Dear Mr. Bowden,

I would like to cast my vote in regard to the current Maintenance of Certification requirement by ABMS and the proposed interstate medical licensure compact. I am very much opposed to legislation further strengthening the monopoly held over physicians by the ABMS. I will not recant the details which have much more eloquently been stated by the AAPS - American Association of Physicians & Surgeons however, I have attached a copy of their letter for your review should you be missing it. If you were not aware, the AMA only has about a 11% membership rate in the United States. There is a very good reason for this and it is because they do not represent the physicians of this country and are nothing more than a self serving group and are in no way support the interests of private practice physicians. I am one of the few solo family practice docs left in Memphis Tennessee. It won't be long until I walk away myself and it has nothing to do with money. Believe me, I would have a much better retirement outlook if I had started slinging boxes at FedEx in high school and done their 401K. I drive a 16 year old jeep with holes in the roof and no air conditioner and that is fine. However, what is NOT FINE is the constant increase in total bullshit that I have to deal with. Keep it up and see how satisfied your treasured constituents remain. And believe me, they will know exactly who dropped the ball and that would be you. Thank you kindly for your time and I truly pray that congress can open their eyes past the lobbyist packing their lobby and see what is really going wrong with this country. Hopefully, Mr. Trump will provide a breath of fresh air.

Sincerely,

perry rothrock md



PERRY C. ROTHROCK, III, M.D.
8309 CORDOVA ROAD
CORDOVA, TN 38016

 
Comment 21:
Mr. Bowden,

I am a physician trained in OB/GYN and practicing in the state of CA.
I am writing to comment on the proposed rule on certification requirement for the Interstate Medical Licensure Compact.
I agree with the AAPS position on this rule:
https://docs.google.com/document/d/1hWXP5WvlN83...
The rule is unnecessarily complex and bureaucratic and ties physician licensure to the certification requirements of a single organization, the ABMS which has been widely recognized for anti-competitive and financially improper activities which do not achieve the certification quality improvements that they have claimed.
Board certification is not required for medical licensure in any state.

Signed,
Patrick James Baggot MD

 
Comment 22:
Comments on Interstate Medical Licensure Commission Proposed Administrative Rule Chapter 5, “Expedited Licensure.”

To: Commissioner Mark Bowden, Interstate Medical Licensure Compact Commission, Bylaws and Rules Committee Chair and Committee Members

Dear Commissioner Bowden,
The Interstate Medical Licensure Compact requires a physician to license in each and every state at substantial cost. The Interstate Medical Licensure Compact along with the proposed rule does not meaningfully reduce the costs for multi-state physician licensure.
2) The requirement in section 5.4(1)d of the rule, mandating certification exclusively by ABMS- or AOA-approved boards, should be removed and the related provision in the Compact should also be stricken as:
a) The American Board of Medical Specialties (ABMS) & AOA (American Osteopathic Association) have been subjected to significant criticism regarding anti-competitive practices, financial impropriety, and misrepresentations about quality improvement due to certification and maintenance of certification. By the ABIM’s own admission "they got it wrong" and have repeatedly changed their recertification requirements. The Commission must ask if they will ever "get it right"?

b) Other certification boards exist in the USA and multiple exist internationally. It is notable that the Compact and Commission fail to allow physicians certified by these entities access to Compact licensure, especially given the fact that there is no indication the certificates matter at all in any way to quality or improvements in care. We believe that the omission of these alternatives, in light of the close ties of the FSMB and ABMS, calls for an investigation into the occurrence of any inappropriate and potentially illegal collusion of the various entities involved in writing the Compact and its rules and those benefiting financially from the implementation of the Compact.

Wm. MacMillan Rodney MD
Professor Family Medicine and Obstetrics
Chair, Medicos para la Familia
Memphis, Maracaibo, Mississippi

 
Comment 23:
Dear Commissioner Bowden

Thank you for the opportunity to submit comments on the interstate licensure compact for medical professionals. I have researched and been involved nationally with this issue for the past few years that it has been conceived and debated. It is my considered opinion that the compact does not add value, decrease costs, decreased administration or aid physicians in their licensure in the way that it was intended and sold. Too much power is concentrated at the top with no accountability. Further, it usurps states rights to license. Furthermore it usurps physicians freedom if they have an issue in one state and want to move to another state and would be retarded in this effort. My comments and concerns are similar to those of my colleagues below at AAPS. Please consider them again and your deliberation.

Best wishes for good health,
Craig M. Wax, DO
Family Physician
National Physicians Council on Healthcare Policy member
Host of Your Health Matters
Rowan Radio 89.7 WGLS FM

 
Comment 24:
I am in agreement with the Association of American Physicians and Surgeons regarding board certification. If a physician chooses to become board certified, that is his or her right, but board certification should never under any circumstances be a requirement for licensure, reimbursement, employment, or privileges to practice medicine in any clinic or hospital (including the Veterans Administration).

Board certification may have started with good intentions but it has become a for-profit scheme run by mostly non-medically trained people at the ABMS. Board certification does not guarantee that a physician or surgeon is as fit, or more fit, to practice medicine than any other physician. Most malpractice suits are filed against board certified physicians and I have seen many diagnoses missed and many patients not optimally treated by board certified physicians.

Sincerely,
Daniel B. Bennett, M.D.
Jonesboro, Arkansas

 
Comment 25:
To: Commissioner Mark Bowden, Interstate Medical Licensure Compact Commission, Bylaws and Rules Committee Chair and Committee Members


Dear Commissioner Bowden,


Thank you for the opportunity to provide comments on the Proposed Administrative Rule on Expedited Licensure.


We would like to raise a number of concerns about the proposed rule for the committee to address.


1) The model proposed for expedited licensure is unnecessarily complex and bureaucratic. Consider that the nursing licensure compact allows for licensing of nurses in all member states with ONLY one license while the Interstate Medical Licensure Compact requires a physician to license in each and every state at substantial cost. The Interstate Medical Licensure Compact along with the proposed rule does not meaningfully reduce the costs for multi-state physician licensure.


In addition, nurses are now increasingly practicing medicine and the structure and rules of the Interstate Medical Licensure Compact creates selective disadvantages to physicians in competition with NPs.


Congress has also introduced legislation, H.R.3081 - TELE-MED Act of 2015, to allow Medicare patients to receive care from a Medicare-enrolled physician licensed in any state. Similar reciprocity is granted to U.S. military and VA physicians, thus demonstrating the cost-effectiveness and safety of allowing cross-state medical practice, without the need for the complexities added by the Commission under development. Legislation granting reciprocity to physicians serving athletic organizations has been passed or is under consideration in numerous states and the U.S. Senate just this month introduced HR 921, the Sports Medicine Licensure Clarity Act of 2016, to institute such reciprocity on a federal level.


2) The requirement in section 5.4(1)d of the rule, mandating certification exclusively by ABMS- or AOA-approved boards, should be removed and the related provision in the Compact should also be stricken as:


a) No single medical board in the United States requires such certification as a licensing requirement.


b) This creates a discriminatory process for physicians with time-limited certification.


b) The American Board of Medical Specialties (ABMS) & AOA (American Osteopathic Association) have been subjected to significant criticism regarding anti-competitive practices, financial impropriety, and misrepresentations about quality improvement due to certification and maintenance of certification. By the ABIM’s own admission "they got it wrong" and have repeatedly changed their recertification requirements. The Commission must ask if they will ever "get it right"?


c) Two other certification boards, NBPAS and ABPSUS, exist in the USA and multiple exist internationally. It is notable that the Compact and Commission fail to allow physicians certified by these entities access to Compact licensure, especially given the fact that there is no indication the certificates matter at all in any way to quality or improvements in care. We believe that the omission of these alternatives, in light of the close ties of the FSMB and ABMS, calls for an investigation into the occurrence of any inappropriate and potentially illegal collusion of the various entities involved in writing the Compact and its rules and those benefiting financially from the implementation of the Compact.


3) “Primary Source Verification” is defined in item “dd” of the proposed rule’s definitions and the definition includes reference to the FSMB’s FCVS. However the term “Primary Source Verification” is not otherwise mentioned in in the proposed rule text. Our concern is that the definition signals the possibility that the additional purchase FSMB-controlled services, like the FCVS, might be required for Compact participation. A need to register with the FSMB's FCVS would represent an additional overcharge as the rule already proposes a current "letter of qualification" from the medical board in the state of primary licensure. This letter should satisfy any and all need for primary verification of any and all documents. Presumably all have been already primary verified by the home state licensing board. This possibility suggests the inefficiency and blatant and primary attempt of FSMB to increase revenues unnecessarily to their organization.


4). Section 5.6(1)b of the proposed rule states that a “letter of qualification is valid for 365 days from its date of issuance to request expedited licensure in a member state. There shall be no waiver of this time limit."


It is unclear what demands are to be set to allow issuance of such "letter of qualification" after the first 365 days have passed. If a physician seeks Compact licensure in an additional state after the expiration of the letter presumably the physician will be required to apply again with his principal state of license to obtain another letter of qualification. Would this mean that the physician’s ABMS- or AOA-approved certification would have to be current when seeking a new letter? Despite the provision in 5.4(1)d that current certification is only required on the initial determination of eligibility, the 365-day rule creates ambiguity that begs clarification.


And most if not all states have licensing requirements lasting periods of 2 years-much longer than 365 days. How does this 365-day rule impact physicians with existing multi-state licenses at the time of their initial Compact eligibility? If such physicians plan to seek future “expedited” licensure via the Compact in these states, and the relevant renewal dates are more than 365 days in the future, will they again need to obtain a letter of qualification?


We have additional concerns, beyond the scope of this particular proposed rule, that raise questions about the solvency of the Compact.
We will name just two of many: 1) the FBI questioning the authority of the investigatory powers delegated to the non-government regulatory entity, the Interstate Medical Licensure Commission. 2) concerns about the appearance of pay-for-play created by FSMB-lobbying of Congress and federal agencies and subsequent federal taxpayer-funded grants received by FSMB for Compact operational funding.


In conclusion, as the Compact preserves the existing requirement to purchase multiple licenses in every state of practice, with the addition of additional service fees, and the enormous costs associated with the board certification mandate, not to mention the possibility of requiring the purchase of other services like FCVS, the entire Compact as structured is not a meaningful solution to the problem it seeks to solve.




Without a significant reworking of the Compact concept, perhaps using the more efficient nursing compact as a guide, physicians may very well find it more cost effective, and even faster, to bypass the Compact and continue to license directly with each state of practice.


Thank you for taking our comments into consideration. We look forward to the Committee’s response to our concerns.


Sincerely,

--
Paul Zyglewski

Office Administrator

Neurology Consults, P.C.

300 Stonecrest Blvd, Suite 260

Smyrna, TN 37167

 
Comment 26:
When the draft version struck the language defining “state of principal licensure” as:

SECTION 4. DESIGNATION OF STATE OF PRINCIPAL LICENSE 16
(a) A physician shall designate a member state as the state of principal license for 17 purposes of registration for expedited licensure through the Compact if the physician possesses a 18 full and unrestricted license to practice medicine in that state, and the state is: 19
(1) the state of primary residence for the physician, or 20
(2) the state where at least 25% of the practice of medicine occurs, or 21
(3) the location of the physician's employer, or 22
(4) if no state qualifies under subsection (1), subsection (2), or subsection (3), the


And moved to:
“State of principal license” means a member state where a physician holds a license to practice medicine and which has been designated as such by the physician for purposes of registration and participation in the Compact.

That meant that a physician could have a license in a participating state OR get a license in a participating state and designate it as their SPL, correct? No requirements for residence or practice or employment?

Kofi


Kofi Jones
Vice President of Government Affairs
American Well
617-204-3506 (direct

 
Comment 27:
Date: September 19, 2016

To: Commissioner Mark Bowden, IMLC

Via: Email mark.bowden@iowa.gov and fax (515) 242-5908

Re: IMLC Chapter 5, "Expedited Licensure" Proposed Wording

Dear Sir:

I am contacting the IMLC Commission to voice my objection to the current proposed wording for expedited licensure requirements.

I respectfully request that the Commission consider the following: (1) re-wording the proposal to allow other alternative certification and recertification boards such as the National Board of Physicians and Surgeons (NBPAS) to meet the requirement(s); and/or (2) reinstate the previously considered language allowing past certification to meet the requirement(s).

Given the ongoing controversy regarding MOC/recertification through the private entity American Board of Medical Specialties (ABMS) and the potential antitrust issues that are evolving, it is my opinion that additional considerations must be given. Your prompt attention and wholehearted deliberation of my request is greatly appreciated.

Regards,

Spyrie D Mays, MD, FACS
3401 North Boulevard, Ste 340
Baton Rouge, LA 70806

 
Comment 28:
Since board certification is required at the time of initial determination of eligibility, physicians not participating in onerous recertification schemes when applying for a compact license may find their ability to obtain a license via the compact in jeopardy.

I am against adding an additional layer of bureaucratic involvement into what is already a difficult and time-consuming process. Licensure should not be tied to the whims of organizations controlled by the American Board of Medical Specialties (ABMS). In other fields not related to medicine, this might be called an anti-competitive practice. I would hate to see it become the law of the land.

Martha Grout

Martha M Grout, MD, MD(H)
Medical Director
Arizona Center for Advanced Medicine
10200 N 92nd St, Suite 120
Scottsdale, AZ 85258

 
Comment 29:
Dear Commissioner Bowden,

I am writing to encourage eliminating the very specific board certification requirements (ABMS and AOA) now part of the proposed language for Compact Licensure. First, there should be no monopoly on board certification validity as the ABMS and AOA try to assert and maintain for themselves. Patient care and patient access should not be politicized or controlled by the few. Second, there are a large number of rural regions (especially the central U.S.) that are served by foreign medical graduates who have no board certification, or have other board certifications outside the ABMS and AOA. As a physician and medical practice CEO, I can provide firsthand experience related to the challenge it is to place specialty care in rural regions of the Midwest. Given that difficulty, I believe that adopting such restrictive language in the Interstate Compact Rule can have an adverse negative impact upon the access patients have to medical services, especially specialty care, in those regions.

Respectfully,




Richard A. Kube II, MD, FACSS, FAAOS
CEO, Founder, Prairie Spine & Pain Institute
Treasurer, American Board of Spine Surgery
Clinical Assistant Professor, UICOMP
Dept. of Surgery, Section of Orthopaedics

 
Comment 30:
Dear Commisioner Bowden,

Re: Interstate Medical Licensure Compact

Please tell the Commission that:
1. They should work to remove the Certification requirement entirely.
2. Until they can remove the requirement they should a) allow other alternative certification and recertification boards like ABPS and NBPAS to meet the requirement and b) reinstate previously considered language allowing past certification to meet the requirement: “Currently holds, or has previously obtained specialty certification."

No single medical board in the United States requires such certification as a licensing requirement and the current wording creates a discriminatory process for physicians with time-limited certification. Not to mention, the existing nursing compact and model APRN compact require only one state license for practice in other compact states while the FSMB physician compact requires licenses in each individual state, along with payment of each individual license fee, thus limiting physician competitiveness with NPs who often make just as much for care.

Licensure should not be tied to the whims of organizations controlled by the American Board of Medical Specialties (ABMS). Such entities have been subjected to significant criticism regarding anti-competitive practices, financial impropriety, and misrepresentations about quality improvement due to certification and maintenance of certification. By the ABIM’s own admission "they got it wrong" and have repeatedly changed their recertification requirements.


Sincerely,

Robert Knox, MD
1534 11th St.
Portsmouth, OH 45662

 
Comment 31:
Commissioner Bowden,

Thank you for the opportunity to provide comments on IMLC Commission Rule 5 concerning Expedited Licensure under the Interstate Medical Licensure Compact. The comments of the Wisconsin Hospital Association are attached. If you have any questions, please feel free to contact me.

Sincerely,
Matthew

Matthew Stanford
General Counsel
Wisconsin Hospital Association, Inc.

Comment Attachment

 
Comment 32:
This entity is unnecessary, especially any reference to certification re-certification or maintenance of certification. Every state in the union requires CME for re-licensure. There is no proof that any more requirement for demonstration of knowledge – now easily obtainable from several sources such as Up To Date on the internet- improves care by increasing quality, decreasing cost or improving access. (It does clearly make do-gooders and money grabbing regulators feel better.) If it is believed that national licensure is beneficial, then let the Congress of the USA – which has no qualms about sticking its nose into health care – pass legislation establishing national physician licensure.

The only criterion for this entity should be possession of a valid license in any state.

Physicians have stated emphatically and very clearly that we will not pay for nonsense such as maintenance of certification.

I vote NO on the interstate licensure compact


Robert A Peraino, MD
PO Box 844
Franconia, NH03580

 
Comment 33:
Mr. Bowden,

I am a primary care physician trained in family medicine and practicing in Ohio.
I am writing to comment on the proposed rule on certification requirement for the Interstate Medical Licensure Compact.

I agree with the AAPS position on this rule. It is unnecessarily complex and bureaucratic and ties physician licensure to the certification requirements of a single organization, the ABMS which has been widely recognized for anti-competitive and financially improper activities which do not achieve the certification quality improvements that they have claimed.


--

Brad Banko, MD, MS

 
Comment 34:
Dear Sir:

I, along with my colleagues, urge you not to support the current requirements of board certification for those physicians who choose not to participate in the very time consuming and expensive MOC program that the ABIM and others are forcing upon us. This is an unfair burden, and does not lead to a higher quality of care. I appreciate your concern in this matter.




Thank you,

Randy R. Shemer

 
Comment 35:
Dear Sir,

I am an internist recognized by the Royal College of Physicians and Surgeons of Canada. Because I did not complete a US residency I was not eligible to become Board Certified in the United States, although for many years I practiced as a specialist and Internist in the US. As the new rules would exclude me and others like me, it is appropriate to remove the certification requirement from the proposed Compact regulations.

Clive Sinoff
22200 Halburton Rd Beachwood, OH, 44122 USA

 
Comment 36:
Dear Commissioner Bowden,

To my knowledge there is no licensing board of medicine in the USA that requires MOC for licensure.

I admonish you to work and remove this certification requirement in its entirety. Until you remove this requirement you should be willing to allow other alternative certifications and recertification boards as well as reinstate previous language allowing past certification to meet the requirement: "Currently holds, or previously obtained specialty certification" should suffice for licensure.

Licensure was never intended to be controlled by the American Board of Medical Specialties. Why are you making it thus so now? It is such a convoluted and anti competitive organization which has never been an accurate judge of quality and never can be.

Thank you for your consideration in this matter. I look forward to hearing the outcome.

Sincerely,

Sylvia Horsley MD FACOG
Diplomate of the American Board of Obesity Medicine

 
Comment 37:
Dear Sir:

I am reading with great interest the proposal for the interstate medical licensure compact. I have the follow comments.

As a specialty physician who has certified and recertifed for both internal medicine and nephrology, and who disagrees with the ABIM’s current MOC requirements, I would like to see the Commission remove the certification requirement entirely. If this is not removed, then the Commission should allow alternate certification and recertification boards like NBAPS or ABPS to be used to meet the requirements. I would also to see language that allows past certifications to meet the requirement-For example “ currently holds or has previously held or obtained a specialty certification.”

The current language discriminates against those that have a time limited certificate while allows physicians who were grandfathered in to life-long certification an open door. This also goes against the current standard that allows APRN’s to have only one state license to practice in other compact states while the FSMB physician compact requires licenses in each individual state along with the payment of each individual license fees and professional state taxes. This limits physician competiveness with NPs who can make just as much for a lower level of education and a more limited scope of practice.

My thanks.

F. David Newby M.D., Ph.D.
Nephrology and Hypertension Specialists, P.C.
1506 Broadrick Dr.
Dalton, Georgia 30720

 
Comment 38:
Dear Mr Bowden:

There are some issues that I would like you to consider in drafting the final rules of the compact:

1. You should work to remove the Certification requirement entirely.
2. Until you can remove the requirement you should a) allow other alternative certification and recertification boards like ABPS and NBPAS to meet the requirement and b) reinstate previously considered language allowing past certification to meet the requirement: “Currently holds, or has previously obtained specialty certification."

No single medical board in the United States requires such certification as a licensing requirement and the current wording creates a discriminatory process for physicians with time-limited certification. Not to mention, the existing nursing compact and model APRN compact require only one state license for practice in other compact states while the FSMB physician compact requires licenses in each individual state, along with payment of each individual license fee, thus limiting physician competitiveness with NPs who often make just as much for care.

Licensure should not be tied to the whims of organizations controlled by the American Board of Medical Specialties (ABMS). Such entities have been subjected to significant criticism regarding anti-competitive practices, financial impropriety, and misrepresentations about quality improvement due to certification and maintenance of certification. By the ABIM’s own admission "they got it wrong" and have repeatedly changed their recertification requirements. The Commission must ask if they will ever "get it right"?

The certification requirement is by no means the only problem with the Compact but is one of the main issues in this particular rule under consideration.


Sincerely,
Michael Dunn, MD

 
Comment 39:
Dear Commissioner Bowden:

Please make sure specialty board certification has absolutely nothing to do with interstate medical licensure.
There is no state that requires specialty board certification for a medical license and interstate licensure should not either.

The American Board of Medical Specialties is a corrupt organization that has been extorting physicians for profit, all under a false guise of "quality" - - do not let them make board certification into a licensure requirement!

Walter Wood, MD, FAAD

 
Comment 40:
Dear Commissioner Bowden,

While I understand the intent of the Interstate Medical Compact, I ask that you ensure it does not open the door to federal jurisdiction over medical licensure.

I am a direct pay physician. I do not participate with any insurance plans, including Medicare or Medicaid, and as a result can provide affordable care to those citizens with high deductible, high co-pay insurance. My price is about 1/3 of the cost in a participating office. True, I don't make as much money as I would in a traditional practice. But the pleasure of caring for my patients without bureaucratic interference is worth the cost, and I have -- after just 18 months -- thousands of patients grateful to have an alternative to the confusing mess that health care has become.

Free market alternatives work in every other industry. Provided competence is ensured through licensure, competition amongst various economic models for providing medical care might solve the issues that the ACA tried, and failed, to fix. If federal oversight, outside of the Medicare/Medicaid/VA systems, is permitted, these alternatives likely will evaporate. The feds will surely tie licensure to participation with government insurance and all the associated regulations.

Thank you for considering this tiny -- but important -- aspect of licensure as you craft this bill.

With thanks,

Jean M. Holland, MD
Ann Arbor, MI

 
Comment 41:
regarding the Interstate Medical Compact:

1. work to remove the Certification requirement entirely.
2. Until you can remove the requirement they should a) allow other alternative certification and recertification boards like ABPS and NBPAS to meet the requirement and b) reinstate previously considered language allowing past certification to meet the requirement: “Currently holds, or has previously obtained specialty certification."

No single medical board in the United States requires such certification as a licensing requirement and the current wording creates a discriminatory process for physicians with time-limited certification. Not to mention, the existing nursing compact and model APRN compact require only one state license for practice in other compact states while the FSMB physician compact requires licenses in each individual state, along with payment of each individual license fee, thus limiting physician competitiveness with NPs who often make just as much for care.

Licensure should not be tied to the whims of organizations controlled by the American Board of Medical Specialties (ABMS). Such entities have been subjected to significant criticism regarding anti-competitive practices, financial impropriety, and misrepresentations about quality improvement due to certification and maintenance of certification. By the ABIM’s own admission "they got it wrong" and have repeatedly changed their recertification requirements. ABMS is being sued for restriction of trade in federal court in Chicago by the American Association of Physicians and Surgeons.

The Commission must ask if they will ever "get it right"?

The certification requirement is by no means the only problem with the Compact but is one of the main issues in this particular rule under consideration.

Respectfully,
Sue Hilda, MD

 
Comment 42:
Mark,

I am a physician who held THREE board specialty certifications for over 20 years. I am now in my early 60’s and have given up that onerous recertification process imposed on physicians over the last decade or more.

I would like to say that MANY of my colleagues do not wish to be kept from moving and working in other locations because we have chosen to no longer participate.

Please be pro active about including a grandfather clause for ANY currently practicing physician who has held board certifications since 1986 when all this over regulation of hard working physicians began.

Respectfully,

Linda Wrede-Seaman, MD, FAAFP, FACEP, FAAHPM
Washington State

 
Comment 43:
Dear Mr. Bowden:

I would like to speak strongly against the IMLC. It is not necessary, will drive up considerably the cost of licensure, and will create a nightmare regarding jurisdictional issues. State medical boards will lose control and integrity, and this is precisely why many influential states, especially Missouri, Ohio, Texas, and others, have decided to NOT entertain joining the Compact.

The idea of expedited medical licensures is simply not realistic as you are claiming. Rather, Ohio's state medical board believes that obtaining licenses will take longer! Individual states can already expedite licenses if they should choose to do so. Costs will certainly escalate.

The Federation of State Medical Boards has arbitrarily decided that medical care exists at the site of the patient, rather than the physician! Not only does this definition not make any sense at all, but the FSMB has no right to define any such thing. This is strictly a matter of the individual state medical boards. As a private organization, the FSMB has no right to enforce definitions, and it also has no right to institute a Compact that many states will not join. Furthermore, I would be surprised if more than just a handful of physicians ever use the Compact. They will be much better served applying directly to and through the individual state medical boards.

If the FSMB is so concerned about the practice of medicine, it should first see that nurses (nurse practitioners) be under the jurisdiction of state medical boards. While many nurse practitioners are practicing way beyond the scope of what they are trained to do, this Compact will not affect them at all.

I strongly urge you to abandon the Interstate Compact as being unworkable, expensive, unnecessary, and a threat to the autonomy of individual state medical boards. The public does not need this and does not want it.

Thank you for your consideration. I would further like to advise you that I would like to speak at the Teleconference on September 23, 2016

Kenneth D. Christman, M.D.

 
Comment 44:
Dear Mr. Bowden:

Attached, please find the Hawaii Medical Board’s written comments on the proposed adoption of administrative rule Chapter 5, Expedited Licensure.

Should you have any questions, please let us know.

Sincerely,

Wilma Balon, Secretary
Hawaii Medical Board
Department of Commerce & Consumer Affairs
Professional & Vocational Licensing Division
P.O. Box 3469 Honolulu, HI 96801

Comment Attachment

 
Comment 45:
Dear Mr Bowden:

I am a licensed physician for over 20 years. I am commenting on the need to eliminate certification requirement for the licensure compact for several reasons (referring to the passage " Holds specialty certification or a time-unlimited specialty certificate recognized by the ABMS or the AOA’s Bureau of Osteopathic Specialists. The specialty certification or a time unlimited specialty certificate does not have to be maintained once a physician is initially determined to be eligible for expedited licensure through the Compact.")

1. Presently, medical licensure is a state by state authority and no states require certification: The compact, therefore is adding a requirement which is inappropriate and only more costly for physicians and financially beneficial to chosen private certifying board corporations.
2. The act of requiring certification precludes 20% of physicians who are noncertified but able licensed physicians to care for patients only exacerbating the already known physician shortage (you will be worsening the physician access problem for Americans).
3. Neither time unlimited certification for physicians or the ongoing ABMS proprietary program MOC (in the past 20 years during its existence) have shown medical evidence of improved patient outcomes therefore such a requirement for licensure compact is political and not policy-based and only serves to enhance the revenue for ABMS and AOA. Please note that as of 2013/2014, ABMS and its 24 sub- boards have accumulated tax-exempt net-worth portfolios (primarily in securities) of over $500 million. Why would the compact add to this largess?
4. Why would the compact require certification of physicians when nurse practitioners, who are practicing medicine without a medical license, are in direct competition with primary care physicians?

The bottom line is that if the compact is to work as desired (to enhance physician access to patients) then the inappropriate requirement for certification should be completely eliminated making it consistent with all state licensure. ANY requirement for certification be it one time or continued certification would be clear-cut political-financial boon for private corporations and anti-physician and anti-American citizen.

I look forward to seeing a new compact language devoid of any certification requirement.

Sincerely,
David J Siegler M.D.
Board Certain Pediatric Neurologist

 
Comment 46:
Mark, I am sending these suggestions and questions regarding the Compact from Credentialing staff here, anticipating that they may be more timely now. If these are more appropriately directed to someone else, please let me know.

The suggestion is to make it similar to how NURSYS works for the nursing compact. And here’s why:

1. There is a “speed memo” function that allow states to communicate directly through the database.
2. Verifications are completed through the database.
3. Database info transfer into ICE is done in the morning routine so that changes made by us in ICE or changes made by NURSYS via other states are updated simultaneously.
a. This will be VERY important given that the compact wants to take care of renewal
b. Also VERY important if the compact license status will be tied to another states (Principal) license.
4. Reporting functions
a. NURSYS reports duplicate licenses (license holder holds a license in 2 compact states, which is not allowed per the nursing compact). Since the Med compact will require the maintenance of a principal state license in order to keep a compact license, it would be helpful to have a similar report to show action taken on principal licensure.

These are the questions that were forwarded to me:

1. Will the compact license be a different license method, seems it will need to be based upon compact requirements vs. WI requirements?
2. What about licensees who were issued licenses under old requirements that are not equivalent to the compact requirements?
a. Can they obtain a compact license?
i. Example is fingerprinting – if a WI license was obtained without fingerprinting can they meet requirements “a la carte” to obtain a compact license?
ii. Would this be done through the compact, or the principal state of licensure?
3. Will all the info provided to the principal state be available in the database for other states viewing (i.e. USMLE dates, post grad, med-ed, convictions etc.).
4. Letters of qualification?
a. How do we determine if they qualify for compact licensure? Once a compact license application has been completed and reviewed by Board staff? Will there be a compact checklist that we will be using to make “pre-determinations.”
b. Who do we send said letter to? The compact? The requesting state?
i. Can’t this be tied to the database? Complete the standard compact requirements and submit info to FSMB to be stored in the database? Then verification can be requested by all subsequent states?
c. Similar to UA – submit all “compact license requirements” (via a compact application) to FSMB and FSMB determines if they meet the initial requirements for licensure instead of relying on individual states to do so.
d. Then that data can be transferred to the compact states similar to how the UA data is transferred now – into a compact license app (for WI, through OLAS).

We may also be receiving comments and/or questions from others in state that I will forward for review and possible consideration.

Thank you.

Tom
(Thomas Ryan - DSPS)

 
Comment 47:
Commissioner Bowden,

Hope all is well with you. I am one of the new Commissioners from MS. Was reviewing the information for the Teleconference on the 24th and had a couple questions I wanted to ask you but didn’t think the conference call was the time to get this specific. Can you expound on the following for my clarity?:

Active investigation:
• What is the intent for notification, is it as soon as initiated, adjudicated?
• How does it impact renewal when under investigation?
• How do we keep the Compact from jumping ahead of the states in the investigation process or what happens when an investigation is occurring in the non-primary licensure state?

Thanks for you and your Committee’s hard and great work on this.

Claude

Claude D. Brunson, MD, MS, CPE
Professor of Anesthesiology
Senior Advisor to the Vice Chancellor for External Affairs
Director, Office of Government Affairs
Office of the Vice Chancellor
University of Mississippi Medical Center
2500 North State Street
Jackson, MS 39216-4505

 
Comment 48:
Mr. Bowden,

With regards to Section 5.5 "Expedited licensure process", particularly the following:

5.5 (1) (c). Submit to the state of principal licensure a completed fingerprint packet or other biometric data check sample approved by the state of principal licensure.

Many states already require fingerprinting and/or other biometric data in order to obtain a medical license. I am concerned about the extra time and costs to licensed physicians, the state medical boards as well as the law enforcement agencies that must verify these physicians' biometrics again.

Rather than requiring such costly redundancy, I would recommend that an applicant's previously authenticated identification be verified via notarized letter, by the president of the medical board in the state of an applicant's principal licensure.

If all state medical boards require fingerprinting and/or other biometric data for initial licensure, then nothing further need be done. I would verify this with all state Boards of Medicine, and if there are some boards that DO NOT have this as a requirement for initial licensure, I would then add that these particular applicants for an expedited license must go through the fingerprinting, etc verification. Alternatively, the IMLC could require participating states to have this verification process as a standard to their state's initial process if they want to participate in the IMLC.

Thank you.

Teresa M. Cadorette, MD
New Hampshire