June 2012
Feature Story

What is the status of MOC reporting, and what are the consequences of not meeting reporting deadlines? Just two of the many questions asked of the American Board of Pathology about its Maintenance of Certification program. CAP TODAY publishes some of the questions and the ABP’s answers from time to time.

Send your own questions to ABP executive vice president Betsy D. Bennett, MD, PhD, at questions@abpath.org.

What is the status of the voluntary recertification program offered by the American Board of Pathology? What is the process?

Voluntary recertification is available to ABP diplomates who hold non-time-limited certificates in one of the primary disciplines of pathology (AP/CP, AP, or CP). Voluntary recertification in pathology subspecialties is not available. Applicants who successfully complete the voluntary recertification process receive a time-limited certificate that documents recertification for a period that begins on Jan. 1 of the year following completion of the process and ends 10 years later. The ABP will accept applications for voluntary recertification through July 1, 2013. After July 1, 2013, diplomates who wish to recertify can do so through the ABP’s Maintenance of Certification (MOC) program.

Once an application for voluntary recertification has been filed, the entire process must be completed within the same calendar year. The requirements for voluntary recertification, in addition to the non-time-limited certificate issued by the ABP in a primary pathology discipline, are as follows:

• The applicant must have a current, valid, full, and unrestricted license to practice medicine or osteopathy in at least one jurisdiction of the U.S., U.S. territories, or Canada. If more than one license is held, all must be current, valid, full, and unrestricted.
• 150 continuing medical education credits during the three years prior to the recertification application must be documented. Of the 150 credits, 100 must satisfy the criteria for category 1 of the AMA’s Physician Recognition Award. At least 80 of the 100 category 1 CME credits must be directly related to the applicant’s practice.
• An applicant must document the accreditation status of his or her laboratory. The accrediting agency must be appropriate for the diplomate’s scope of practice (for example, CMS, Joint Commission, CAP, AABB, National Association of Medical Examiners).
• Documentation of medical staff membership in good standing at the primary health care facility in which the applicant’s practice is located and the scope of health care organization privileges must be provided. A written statement from the applicant regarding medical staff status is required along with a reference from the chief of medical staff at the primary health care facility. An applicant who is not a medical staff member at a health care facility must submit a description of his or her practice.
• An applicant must demonstrate that his or her practice satisfies the standards of care as established by the institution, the medical staff, the departmental section, and the department. A comprehensive reference from the department head or section chief serves as documentation of satisfactory quality of practice on the part of the applicant. Evidence of membership in good standing in appropriate professional organizations is also required; a listing of memberships is sufficient documentation.
• Applicants for voluntary recertification are not required to take an examination with the following exception: If an applicant’s credentials do not fully satisfy the requirements for voluntary recertification but there is evidence of an appropriate level of professionalism and competence, the successful passing of a secure examination can be used as a supplement to his or her credentials to achieve voluntary recertification. In addition, a secure examination will be available for those applicants who are required to pass such an examination to obtain or maintain licensure in a particular state.

What is the current status of Maintenance of Certification reporting, and what are the consequences of failing to meet the reporting deadlines?

As of Jan. 1, 2006, all primary and subspecialty certificates issued by the American Board of Pathology are time-limited and expire on Dec. 31 of the 10th year after issue. During the 10-year cycle of a time-limited certificate, multiple reports must be filed with the ABP to maintain the certificate. A candidate must be up to date with all required reports to be allowed to sit for the MOC examination. Failure to meet the reporting deadlines will result in a warning followed by early expiration of the certificate(s). The process of early expiration is as follows:

• A certified letter is sent to the diplomate’s last known address saying that the certificate(s) will expire unless the diplomate contacts the ABP and begins the reporting process within the next 60 days.
• After 60 days, if no response is received, a second certified letter will be sent informing the diplomate that the certificate has expired because of failure to meet MOC requirements.

Each of these letters will indicate how the diplomates can regain certification. These letters were sent out to non-complying 2006 diplomates in 2011. A similar process will occur this year for 2007 diplomates. After 2012 the ABP anticipates that the early expiration process will begin progressively earlier and will eventually be instituted after failure to submit the initial two-year report. After the process is completed, the ABP will ask its cooperating societies to publish the number of certificates in the various specialty and subspecialty areas that expired.

If an individual has multiple time-limited certificates from ABP, how would he or she do the MOC reporting?

MOC reporting of activities for all time-limited certificates that a diplomate may obtain will occur on a two-year cycle beginning with the date of the earliest time-limited certificate. As additional certificates are obtained, they will be included in the two-year reports. For example, for a diplomate who is initially certified in AP/CP in 2012 and cytopathology in 2013, the reporting system will indicate that the 2014 report will cover both certificates. If that diplomate obtains a molecular genetic pathology certificate in 2015, the 2016 report will indicate that it covers the primary certificate and both subspecialty certificates. Diplomates may use the same CME and SAMs for all certificates; the requirement is 70 CME credits (including 20 SAM credits) per two-year cycle. The MOC examinations will stay on the same 10-year cycle as the date of the individual certificates (in the above example, the AP/CP MOC exam must be completed by 2022, the cytopathology exam by 2023, and the MGP exam by 2025).

What is the status of MOC for diplomates with non-time-limited certificates?

The ABP does not require diplomates with non-time-limited certificates to participate in MOC, but such participation is strongly encouraged and will not put the original certificate in jeopardy. MOC reporting for diplomates with non-time-limited certificates became available in March 2012. There is a $100 fee to initiate MOC participation, and the 10-year cycle begins as soon as the ABP receives payment. That means a diplomate with a non-time-limited certificate who enrolls in MOC in 2012, for example, will have the same MOC cycle as a candidate who is initially certified in 2012. The subsequent fee schedule is $100 every two years due at the time of MOC report form submission. Initially, a diplomate with multiple non-time-limited certificates will be considered to be participating in MOC for all certificates and the same CME and SAMs credits may be applied to all certificates. If a diplomate decides to participate in MOC for only one of his or her certificates, all MOC activities may be reported in the chosen specialty and the diplomate can register for the MOC examination in that discipline only. At the end of the 10-year MOC cycle, a diplomate will receive a new time-limited certificate in the area(s) in which MOC was successfully completed. All original non-time-limited certificates remain valid.

A diplomate with a non-time-limited certificate may withdraw from MOC at any time. If a diplomate with a non-time-limited certificate begins the MOC process, then withdraws, and later wishes to re-enter the MOC program, all MOC reporting since the initial entry into MOC must be brought up to date in order to be considered a successful participant. Diplomates with non-time-limited certificates are not allowed to start a 10-year cycle, withdraw, and then initiate another 10-year cycle at a later date.