ABPS’s Position on LSBME Proposed Rule on
Board Certification
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.
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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.
3
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.
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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.
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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.
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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.
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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

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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.`
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.
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Thank you for
your time and
consideration
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