Response from APA Medical Director and CEO James H. Scully Jr., M.D.

Thank you for sending your concerns about the Maintenance of Certification (MOC) program. You have raised a number of important issues regarding the process. APA has been and will continue to be in regular contact with the ABPN to ensure that these concerns are addressed.

As you know, APA is dedicated to assisting psychiatrists to provide the best clinical care for our patients. To that end, we will continue to provide a broad array of educational materials and activities designed to enhance psychiatrists' clinical competence and promote continuous quality improvement and lifelong learning.

The American Board of Medical Specialties (ABMS) is the organization that establishes principles for MOC that must be followed by all specialty boards including the ABPN. The ABPN has raised some of the same concerns with the ABMS and has advocated for MOC requirements that are not only evidence based, but also appropriate and useful for board-certified psychiatrists.

The ABPN requires all candidates for certification to have an unrestricted license to practice medicine. Further, if a board-certified psychiatrist has a restriction placed on his/her license, the board certification becomes invalid. More specifically, each state medical board sets the requirements for medical licensure in that state, both for initial licensure and for reregistration and relicensure, which may include content examinations, continuing medical education, or other methods that demonstrate physicians' continued competence. The ABMS, specialty boards such as the ABPN, and specialty organizations such as APA have no role in that process.

The Federation of State Medical Boards is undertaking a process of Maintenance of Licensure (MOL) that will be different from MOC. No state requires board certification for licensure. APA and other specialty organizations have requested that if a physician participates in MOC, it should be sufficient for MOL so that multiple requirements can be eliminated, but not that MOC be required for MOL. Perhaps this has led to some confusion. The state boards are planning for an independent MOL process because many practicing physicians do not have specialty board certification.

The requirements for patient and peer feedback are part of the proposed ABMS requirements for all board-certified physicians in the United States. It is my understanding that the ABPN has argued vigorously with the ABMS to make these requirements as useful and nonburdensome as possible. The ABPN has stead-fastly opposed the ABMS recommendation that the results of the patient feedback surveys also be used in Part 1 of MOC as a measure of a diplomate's professional standing. The ABPN has stated that the only measure of MOC Part 1 should continue to be the requirement to have an unrestricted medical license.

Many psychiatrists, particularly those who are in solo practice, have voiced concerns about the proposed patient/peer feedback process. Patient surveys are already being done by many psychiatric hospitals, clinics, and training programs. In addition, patient assessment of physician care is required under the new CMS implementation rules of the health care reform legislation. While we all recognize that there are specific issues that must be addressed regarding care of our patients, some form of practice review will be mandated for reimbursement as well as MOC.

The ABPN has voiced its commitment to keeping the costs of MOC as reasonable as possible and has encouraged the ABMS to allow it to accept existing diplomates' activities that are similar to MOC requirements. The ABPN has stated that it intends to provide sample peer and patient feedback forms to diplomates at no charge, as a way to contain individual costs.

APA is committed to assisting our members in meeting these requirements through the least cumbersome, intrusive, and costly means. We intend to provide our members reasonably priced self-assessment, CME, and practice-assessment materials and activities approved by the ABPN and the ABMS that will enable them to participate effectively in MOC.

APA will continue to monitor the MOC process and will share our recommendations and concerns with the ABPN with the goal of having the most balanced and appropriate MOC program for psychiatrists.