1. ABPS’s Position on LSBME Proposed Rule on Board Certification

2. 2 ABPS applauds the efforts of LSMBE in realizing the need to protect patients of Louisiana by proposing a rule on board certification. ABPS shares the Board’s belief that board certification must stand for quality medical care. This is essential for protecting patients’ health. ABPS believes that board certification goes far beyond regulating advertising; it affects hospital credentialing and hospital privileges for physicians, along with reimbursement rates for managed care organizations, which in turn impacts patient access.

3. 3 Our concern with the proposed rule change is the potential for an adverse impact on patients who need access to healthcare the most by removing qualified, experienced and knowledgeable physicians from hospitals. The proposed standard should establish criteria that will allow for experienced, knowledgeable, and competent board certified physicians to offer their services to the public. As proposed, we believe that the rule provision is unnecessarily and unfairly restrictive.

4. 4 To our knowledge, section Ab.5(b) would be only the provision of its kind in the U.S. & Territories. The opinion based criteria of section Ab.5 (b) “that sponsors ACGME or AOA accredited training in the area of certification in which the physician is seeking training” will adversely affect the public health in Louisiana for patients, hospitals, and physicians. This standard, if applied to everyone, would inhibit some ABPS certified specialists and half of the ABMS boards’ certified specialists. If ABMS was not grandfathered in section Aa., 50% of its boards would not be recognized because those boards have alternative pathways similar to ABPS’s pathway in Emergency Medicine.

5. 5 ABPS believes that the training requirements for certification should be broad enough to permit physicians trained in closely related or overlapping specialties to seek and obtain certification in additional specialties by fulfilling acceptable practice requirements and sitting for an appropriate examination, without having to complete additional training. ABPS currently meets all the fact based standards proposed in the LSBME rule except in emergency medicine where a residency in Emergency Medicine may be replaced by the following standard: completion of an ACGME residency in a primary care specialty; completion of five years of full-time work, encompassing at least 7000 hours, in Emergency Medicine; passing both a written and oral examination in Emergency Medicine. This practice mirrors the exact approach taken by the ABMS/ABEM prior to 1988 with regards to Board Certification in Emergency Medicine and is similar to many pathways that ABMS is currently providing today.

6. 6 To date, no published data exists demonstrating that any course of training and/or experience leading into the practice of emergency medicine is better than any other. Therefore, any suggestion that experience is not and should not be an alternative to education is based strictly on opinion, not fact. Any belief that all of ABEM or AOBEM physicians who are board certified are residency trained in emergency medicine is not accurate. Approximately one half of all ABEM and AOBEM certified emergency physicians have not actually completed an emergency medicine residency. Thus, residency training in emergency medicine alone would not appear to be the only standard in the United States for board certification in Emergency Medicine.

7. 7 In reality, there are a limited number of ACGME Emergency Medicine residency programs and positions, thus creating a shortage of available experienced and well qualified Emergency Medicine physicians. Over the last two decades, in order to fill the need, ABPS has successfully provided an established and bona fide pathway to board certification in Emergency Medicine. Patients and hospitals deserve physicians who are experienced, knowledgeable, and competent.

8. 8 Of the 39,061 emergency medicine specialists currently in practice in the United States only 54.6% are residency trained in emergency medicine 1. Manpower studies from leading research institutions, such as Harvard, state that it is highly unlikely that there will be sufficient numbers of EM residency trained physicians to staff all US EDs at least until 2038, or possibly, ever. They state that “the need for Emergency services is large and growing; even if existing programs graduated more physicians there is little reason to think more of these graduates would move to rural areas. 2  1. Ginde AA, Sullivan AF, Camargo CA. National Study of the Emergency Physician Workforce, 2008 Ann Emerg Med. 2009;54:3490359. 2. Camargo CA, Ginde AA, Siger AH, et al. Assessment of emergency workforce needs in the US 2005. Acad Emerg Med 2008 15(12):1317-20.`

9. 9 We understand and respect the Board’s efforts to protect the public. We share the Board’s concern. To this end, we respectfully request that ABPS be recognized by the Board and listed as a named organization in paragraph Aa of the proposed rule. Alternatively, we would respectfully request that the language of Ab.5 be clarified so that it is clear that ABPS satisfies the Board’s requirements for board certification as we believe to be the case.

10. 10 Thank you for your time and consideration