MOC POLICIES and PROCEDURES

The following policies are specific to MOC :

Appeals

Canadian MOC Program Relationship to ABR-MOC
Grace Period
Late Fee
Licensure Outside US and Canada
Participation
Participation Proviso
Professional Standing
Random Audits
Regaining Certification

Appeals Policy

The American Board of Radiology has established the Appeals Policy to resolve concerns with decisions made by the Board relative to the following five areas:

• Training requirements
• Admissibility to examinations
• Examination process
• Requests for examination accommodations under the Americans with Disabilities Act (ADA) ( see ADA policy )
• Non-renewal of MOC certificates

The policy provides for three avenues of resolution for concerns:

1. Inquiries and requests as to status or requirements
2. Requests for reconsideration by the Board
3. Appeals hearings (informal and formal)

All appeals MUST be made in writing, submitted via email or certified letter, and received at the ABR office no more than 45 days from the date of the initial written notification of the Board decision. Appeals must be addressed to the Executive Director, and appropriate documentation should accompany written concerns.

Categories of Concerns

• TRAINING REQUIREMENTS:
  Concerns regardial denial of approval of training
• ADMISSIBILITY TO EXAMINATION
  Concerns regarding the denial of admissibility to an examination for any other reason.
• EXAMINATION PROCESS
  -Concerns regarding the process (including form or administration, e.g., computer malfunction) of the Maintenance of Certification examinations.
  -Examination results may not be appealed.*
  -Hand scoring of Maintenance of Certification computer-based exams is available in these areas:

  Diagnostic radiology
  Radiation oncology
  Medical physics
  Neuroradiology
  Nuclear radiology
  Pediatric radiology
  Vascular and interventional radiology

  -Appropriate documentation should accompany written concerns.

• REQUESTS UNDER THE AMERICANS WITH DISABILITIES ACT (ADA):
  Concerns regarding the denial of a request for examination accommodations under the ADA
• NON-RENEWAL OF MOC CERTIFICATES:
  Concerns regarding notice of non-renewal of an ABR time-limited certificate (based on failure to meet MOC requirements)

*All examination results are subject to extensive quality assurance procedures before release.

This policy is subject to amendment. Candidates and Diplomates are advised to check the ABR website periodically for the most current version.

Canadian MOC Program Relationship to ABR-MOC
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Policy:
ABR diplomates who are participating in the Canadian Continuous Professional Development Program (see description below under Canadian MOC Program to ABR Program eqivalence section) may fulfill the four MOC components in the following ways:

1. Professional Standing: continuous possession of a current and unrestricted medical license in a Canadian province(s) (or U.S. state).
2. Lifelong Learning: documentation of satisfactory participation in the Canadian Continuing Professional Development program.
3. Cognitive Expertise: successful examination through the ABR MOC exam in the last three years of his/her MOC cycle.
4. Evaluation of Performance in Practice: documentation of satisfactory participation in the Canadian Continuing Professional Development program.

Fees:
Diplomates maintaining an ABR certificate expiring ≥ 2019 and maintaining Canadian certification through the processes listed in this policy will be offered a reduced ABR MOC participation fee. Fees will include:

1. MOC exam fee of the year charged at the time of exam registration
2. Administrative fee of $200 due at the time of exam registration

Canadian MOC Program to ABR Program equivalence

1. Canadian Program title: Continuing Professional Development (CPD)
2. Canadian Program Sponsor: Royal College of Physicians and Surgeons of Canada
3. Canadian Program activity categories:
   
   1. Secton 1: Accredited group learning activities - national and international group CME activities (examples: workshops, meetings, courses, conferences and distance-education conferences approved by an RCPSC accredited provider; grand/M&M rounds, journal clubs, tumour boards self-accredited by chair of planning committee) -- approximates Category 1 CME
   2. Section 2: Other learning activities - learning activities that are not affilitated with or approved by an accredited provider (examples: non-accredited meetings, journal clubs, tumour boards, Internet CME, audio and videotapes; reading journals and texts, MEDLINE-type searches) -- approximates Category 2 CME
   3. Section 3: Self-assessment programs - programs designed to assist the specialist in identifying his/her educational needs (examples: self-assessment programs developed or sponsored by national specialty societies, universities and medical colleges, training simulators - approved by RCPSC accredited provider) -- approximates SAMs
   4. Section 4: Structured learning projects - personal learning projects (PLPs), courses or traineeships that are planned and the outcome is recorded and evaluated (examples: keeping a learning portfolio, activity generated out of participating in another CPD activity, masters and PhD studies) -- approximates Category 2 CME
   5. Section 5: Practice review and appraisal - activities that assist specialists to review their personal practice for assessing and identifying areas of potential improvement in delivered care or practice delivery (examples: practice and institution audits, utilization studies, patient surveys, incident reports) -- approximates Practice Performance
   6. Section 6: Teaching, research, standard setting -- activities that involve setting standards for practice and that expand the specialists' expertise or enhance their ability to practice (definition: publications, preparing presentations or teaching sessions, developing examination questions, research, setting standards) -- approximates Category 2 CME

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Grace Period Policy
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As stated in the Policy for MOC Participation, diplomate progress ratings are as follows:

• Fully Compliant - making continuous progress toward meeting all cycle requirements at an approximate rate of 10% of the requirement each year.
• Noncompliant - too far behind to catch up within current cycle (based on continuous progress operational definition)
• Partially Compliant - progress between "fully compliant" and "noncompliant"

Under certain conditions and circumstances, an uncertified grace period of up to three years is available to the MOC participant who fails to complete all requirements during his or her MOC cycle, causing the certificate to lapse. During this time, the participant is not considered certified in the specialty or subspecialty area of the certificate that has lapsed. (And during this time any verifications performed through the ABR or the American Board of Medical Specialties will show uncertified status for the certificate that has lapsed.)

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Late Fee Policy, approved February 2008
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Policy history:
Approved by the MOC Coordinating and Budget and Finance Committees at the February 2008 meeting of the Board of Trustees. Revised by MOC Coordinating and Budget and Finance Committees at the October 2009 meeting of the Board of Trustees.

Policy:

• Diplomates will be subject to late fees if the following occur:
  • Untimely agreement into the MOC process. Agreement must occur prior to February 28th of the year following initial certification or entrance into subsequent MOC cycles.
  • Invoice for annual fee not paid by due date.
• For 2008 only, each MOC diplomate will be given a one-time opportunity to pay past due amounts without assessment of the late fee. Payments must be received by the ABR by December 31, 2008. Any payment received after December 31, 2008 will be considered late and the $100.00 late fee will apply.
• Lifetime certificiate holders will not be subject to a late fee for voluntary participation in MOC.

Staff procedures

• Finance will be responsible for communicating, handling and collecting late fees. All inquiries will be handled by the AR Specialist and collection procedures will be consistently performed.
• Authority to waive a late fee can be given by the executive director, associate executive director or MOC division chair. To waive a late fee, the diplomate must have demonstrated a consistent annual pay history (to be considered consistent, previous fees must have been paid in the year billed or by the specified due date) and no prior late payments (first time offense).
• No late fees will be refunded.

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Policy on Professional Standing (Licensure) Requirements for Diplomates Practicing Outside the United States. and Canada
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A. Policy overview

The ABR recognizes that some of its diplomates may practice outside the United States and Canada, but wish to maintain ABR certification. For those diplomates practicing outside the U.S. and Canada, the professional standing component will be recognized if the diplomate holds and submits documentation of unrestricted licensure in the country in which he or she is practicing.

B. Policy details

• Documentation of unrestricted licensure must be submitted in the fifth and tenth year of each MOC cycle.
• As with U.S. and Canadian practitioners, diplomates practicing outside the U.S. and Canada are required to report any license restrictions to the ABR within 60 days of their imposition.
• This policy applies to all physician diplomates, and to medical physicist diplomates practicing in any country that licenses medical physicists.

C. Requirements for international diplomates who also hold licensure in the U.S. and/or Canada

• The ABR will continually monitor licensure actions reported through DANS, (Disciplinary Action Notification Service) based upon the Federation of State Medical Boards' database.
• If U.S. or Canadian licensure is revoked or suspended (or surrendered in lieu of investigation/action), the ABR will pursue withdrawal of the certificate according to its due process policy (even if there is continued unrestricted licensure in the diplomate's country of practice).
• The Board may also pursue withdrawal of the certificate if the diplomate's license has been placed on probation (unexpired) or put under special conditions/requirements and if, upon review according to Board policy, the Board deems the restriction is of such nature and extent as to preclude continued certification during the time of the restrictions.
• Reinstatement will be considered when the license is returned to current and unrestricted status.

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Policy for Participation, approved June 2007
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A. Continuous progress is expected

Each time-limited certified diplomate must participate annually in the components and competencies of MOC at a pace that accomplishes steady progress toward the fulfillment of the ten-year requirements by the cycle end.

COMPONENT 1
Continuous current and unrestricted state licensure or (for radiologic physicists not required to be licensed) attestations twice during cycle.

COMPONENT 2
Annual participation in lifelong learning activities and periodic self-evaluation (CME and SAMs).

COMPONENT 3
Successful examination within the last three years of ten-year (governing) cycle, unless an earlier examination is required for state licensure purposes or other extenuating circumstances exist.

COMPONENT 4
Participation in evaluation of performance in practice continuously as outlined for Practice Quality Improvement (PQI), with reporting according to published schedule.

The Competencies will all be addressed by each diplomate during the 10-year cycle.

B. Enforcement of continuous progress

1. To ensure continuous progress, the maximum credit toward fulfillment of MOC requirements that the ABR will recognize for a diplomate in a single year is double the usual annual progress rate published in the "requirements schedule." The intent is to avoid clustering of large numbers of credits in one portion of the cycle, with other portions showing little or no activity.
2. Progress ratings:   (See charts below )
   
   1. Fully Compliant - making continuous progress toward meeting all cycle requirements at an approximate rate of 10% of the requirement each year
   2. Noncompliant - too far behind to catch up within current cycle (based on continuous progress operational definition)
   3. Partially Compliant - progress between "fully compliant" and "noncompliant"
3. When individuals who were making continuous progress encounter problems with CME (or some other requirement) due to unforeseen circumstances, such as a prolonged illness or military duty, exceptions may be considered on a case-by-case basis. Thus, for example, in appropriate cases, an individual might be allowed to earn more than 2x credits in a given year.

C. Record of progress

The diplomate is expected to record his/her activities in his/her personal data base (PDB) on the ABR website. Based on the data recorded, the ABR will generate an annual "participation summary" that informs the diplomate of where he/she stands with respect to cycle requirements, and lays out a "roadmap" of annual MOC activities designed to fulfill all requirements by cycle end.

D. Relationship of progress to certification

1. All Component 1, 2, 3, and 4 published requirements must be 100% fulfilled by cycle end in order to qualify for maintained certification, i.e., a new 10-year certificate.
2. There is a point of noncompliance before the end of the ten years which, for diplomates with time-limited certificates, will result in a certain non-certified period at the end of the current cycle.
   See the Grace Period Policy
3. A currently valid certificate is not withdrawn during the cycle for lack of progress during the cycle - only for loss of medical license (Component 1 requirement)

LEVEL OF PROGRESS CHARTS

Part II: Lifelong Learning and Self-Assessment

Diagnostic Radiology and Medical Physics

Radiation Oncology

¹ CME requirements differ by certificate expiration year. Please refer to the MOC requirements chart specific to your certificate expiration year for details on your CME participation.

Part IV: Practice Quality Improvement (PQI)

Attestation/Reporting Points Required
for FULLY COMPLIANT Progress

Part IV: Practice Quality Improvement (PQI)

Points of NONCOMPLIANT Progress

¹ CME requirements differ by certificate expiration year. Please refer to the MOC requirements chart specific to your certificate expiration year for details on your CME requirements.

² PQI requirements differ by certificate expiration year. Please refer to the MOC requirements chart specific to your certificate expiration year for details on your PQI participation.

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Participation Proviso
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This proviso to the MOC Participation policy allows diplomates with a certificate expiring from 2009-2015 to complete triple the normal yearly MOC requirements during a calendar year starting in year seven (7) of the MOC cycle and extending into the three year grace period, if necessary.

Details of proviso:

• Is available to all Diagnostic Radiology, Radiation Oncology and Medical Physics diplomates with a certificate expiring from 2009 - 2015.
• Reporting triple the normal requirements is not available until year 7 of MOC cycle and extends through the end of the 3 year grace period, if needed.
• This proviso to the MOC Participation Policy will expire on December 31, 2018.

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Professional Standing Policy for Diplomates
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A. Required Licensure

At the time of certification by the ABR and throughout the certification and maintenance of certification processes, the physician must hold a current, full and unrestricted license to practice medicine in at least one jurisdiction in the United States, its territories or Canada, including the state(s) in which he/she currently practices, or if practicing abroad, in the country of practice (see Policy for International Licensure). Restrictions placed on a medical license must be reported to the ABR by the physician within 60 days of their imposition.

B. Potential Certificate Sanctions

The Board may at its discretion revoke or suspend a certificate for due cause as provided in the ABR bylaws:

"Any license of the person to practice is not, or ceases to be, a valid and unrestricted license to practice within the meaning set forth in the Rules and Regulations of the American Board of Radiology. In the event that a Diplomate's license to practice is suspended, revoked or restricted in any state in which the Diplomate practices, holds a license or has held a license, the Diplomate's board certification may be revoked or suspended."

Definitions of Sanctions:

1. Revocation: Diplomate ceases to be certified. Re-entry is under provisions of re-entry policy, with a new time-limited certificate requiring participation in MOC for its maintenance.
2. Suspension: Diplomate is not certified for at least the specified period of time (possibly concurrent with the licensure action). Conditions may be stipulated by the board; when met, the suspended certificate is reinstated (as a lifetime certificate, if it was originally lifetime.)
3. An alternative to certificate sanctions is "probation" in which the diplomate continues to be certified; monitoring is done, there may be restrictions on practice, periodic contacts and other requirements may be stipulated.

C. Regaining or Reinstatement of Certification

1. Once a valid, unrestricted license is held in the state of current practice, a physician may contact the Board to initiate a request to regain board certification, or have his/her original certificate reinstated.
2. After suspension: When the Board reinstates a physician's board certification after it has been subject to suspension by the Board, he or she is entitled to resume use of his/her original board certification with the appropriate expiration date of that certificate. If the original board certification was not time-limited, after reinstatement the physician will continue to have a non-time-limited certificate. The Board may, however, in its sole discretion, set other conditions and terms for reinstatement that it deems appropriate considering, among other things, the underlying facts that led to the restriction, the period of time the physician has not been able to engage in the unrestricted practice of medicine, and her/his specialty.
3. After revocation: When the Board has revoked a physician's board certification, the physician is not eligible to have the original certificate reinstated. In addition to other terms and conditions, the Board may require that a physician first pass the examination(s) required for ABR certification or maintenance of certification in the specialty or subspecialty. Upon satisfactory completion of all steps required by the Board, the physician whose certificate previously was revoked shall be issued a new certificate that is time-limited, and the physician shall be required to participate in MOC for its maintenance.

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Random Audits Procedure
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The ABR will randomly select a number of diplomates annually for audit of their MOC progress. An audit is the process of requesting from the diplomate, and reviewing, documentation of records of CME, SAM, and PQI activity not conveyed to the ABR electronically from the awarding societies/organizations. The documentation will be examined by the ABR, and a determination made as to the validity of the activities with respect to each MOC component. The ABR review will result in:

1. Declaration of which claimed activities accurately reflect the data, and
2. Evaluation of the extent to which the diplomate is compliant in making continuous progress toward fulfillment of all MOC requirements within the MOC cycle

The results will be communicated only to the diplomate. If a diplomate is chosen for a random audit, he/she must achieve a compliant status before his/her certificate can be renewed.

PROCESS: A letter, and email or telephone call, notifies diplomate of selection for random audit and asks him/her to provide within sixty (60) days the following documentation:

COMPONENT ONE: PROFESSIONAL STANDING
Evidence of active, current, valid, and unrestricted licenses relevant to all locations of practice.

COMPONENT TWO: LIFELONG LEARNING
Copies of certificates from all ACCME-approved Category 1 CME & ABR-qualified SAMs for which the credit was not conveyed directly to ABR from a society/Gateway; for RP, copies of the recording forms for all SDEPs claimed. (Note that in many circumstances, additional CME credits will be those provided by one or more institutions through which ACCME-approved credits have been obtained. Click the links below for the list of available SAMs:
Diagnostic Radiology SAMs
Radiation Oncology SAMs
Medical Physics SAMs

COMPONENT FOUR: PQI
Copies of supporting documentation for each essential element completed up to the point of the audit, e.g., project title, baseline measurements, analysis, action plan, etc. If applicable, copy of PQI certificate of satisfactory completion from society.

Download diagnostic radiology (DR) audit checklist
Download radiation oncology (RO) audit checklist
Download medical physics (MP) audit checklist - years 1-5
Download Medical physics (MP) audit checklist - years 6+

Please note that a compliant audit status does not necessarily indicate that you are current in your progress toward completing your MOC requirements within the prescribed timeline. We suggest that you compare your MOC activity to the timelines and fees information for your MOC cycle.

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Policy for Regaining Certification After Lapse

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Diagnostic Radiology and Radiation Oncology

For a diplomate who fails to fulfill requirements by cycle end (or by end of grace period, if applicable), in order to become certified again, he or she must take and pass the then-current final oral certifying examination* taken by initial applicants for that certificate.

The certificate issued will be governed by the terms and conditions of the board then in effect, including but not limited to, 10-year time limitation.

* Diplomates who wish to regain their Vascular and Interventional subspecialty certificate after lapse must submit retrospective procedure logs from the last two years. (The procedure log can be found at the end of the Vascular and Interventional Radiology Subspecialty Application for Initial Certification Examination.) Procedure logs must be signed by division chief/chair and submitted to ABR as a part of the application process.

Medical Physics

Diplomates with time-limited certificates in the three disciplines of medical physics may not use an initial certifying examination in place of the required MOC examination during their certification period or uncertified MOC grace period.

For a time-limited diplomate who fails to fulfill all MOC requirements by cycle end (or by end of grace period, if applicable), in order to become certified again, he or she must apply to take the Medical Physics Part 2 exam, followed by the Medical Physics oral exam.

These poliies are subject to amendment. Candidates and diplomates are advised to check the ABR web site periodically for the most current version.