September 5, 2014
Timothy I. Morganthaler, MD
President
American Academy of Sleep Medicine
2510 North Frontage Road
Darien, IL 60561-1511
Dear Dr. Morgenthaler,
Thank you for your letter of August 7, 2014 sharing the concerns of the American Academy of Sleep
Medicine (AASM) regarding the American Board of Internal Medicine (ABIM) Maintenance of
Certification (MOC) program. We are glad the AASM was among the 26 medical societies who sent
representatives to the July 15 Summit to share their thoughts regarding MOC. Some of the issues
you raised were addressed in our July 28 response to the internal medicine community (enclosed),
which you should have received. But, given that some of your concerns are specific to the AASM,
we felt that it was important to respond directly to each of the concerns outlined in your August 7
letter.
While we are open to reviewing our requirements and improving the program, our Board of
Directors is committed to an ongoing continuous MOC program that includes both formative and
summative assessments. In a specialty such as Sleep Medicine, where patient care standards rapidly
change, the MOC program can assure the public that sleep specialists participating in MOC are
staying abreast of the latest changes in the field.
That being said, ABIM has committed to make a number of changes to the MOC program in direct
response to many of the issues raised by the Sleep Medicine and Internal Medicine communities.
Changes we have already made and/or committed to making are summarized in our July 10 and July
28 letters.
Below, we address each of the AASM’s specific concerns:
MOC costs. ABIM is very careful in establishing fees, and our MOC fees are comparable with those
of the other member boards of the American Board of Medical Specialties (ABMS). ABIM
diplomates who maintain certification in more than one area receive a multi-certification rate, which
is 100% of the higher-cost certificate and 50% of the lower-cost certificate(s). The cost to maintain
certification in both Sleep Medicine and Internal Medicine is currently $353 per year, which is
consistent with or less than the fees of the other ABMS Boards offering Sleep Medicine
certification. Additionally, ABIM diplomates who are certified by another ABMS board are eligible
for a 30% discount on all MOC fees. ABIM has also introduced fee waivers and/or fee credits for
diplomates in fellowship training and those newly certified in internal medicine, and we will be
lowering first-time MOC retake fees from $775 to $400 beginning in 2015. We will also explore
pricing options whereby diplomates, over their 10-year exam cycle, can opt in or opt out of access to
ABIM products and, if they opt out, get a discount on their MOC fee.
Educational redundancy. ABIM is committed to reducing redundancy for diplomates by expanding
options to earn MOC credit for other high-value activities physicians may choose to do or are
already doing. ABIM will begin accepting for MOC credit a wider array of activities accredited by
the Accreditation Council for Continuing Medical Education (ACCME). ACCME-accredited
product providers will be able to register with us to have their products count in our program and
will then be able to designate which of their products meet our standards. ABIM product standards
will also be aligned with AMA PRA Category 1 credit standards for enduring materials, journalbased CME, test item writing and Internet point-of-care learning. Detailed program policies and
requirements will be released in mid-September, when we will begin accepting registrations and
products from organizations with a proven track record of producing quality self-assessment
requirements will be released in mid-September, when we will begin accepting registrations and products from
organizations with a proven track record of producing quality self-assessment products. A full-scale launch of the
revised medical knowledge approval program will take place later in 2014. ABIM will continue to produce and offer
medical knowledge modules and practice assessment options to ensure that all ABIM Board Certified physicians have
access to specialty-relevant products.
Requirement for maintaining multiple certifications. You raise important questions about the requirement that
diplomates maintaining certification in Sleep Medicine also maintain certification in Internal Medicine or another
subspecialty. For context, Sleep Medicine certification began as a certificate of added qualification (CAQ) to
underlying Internal Medicine certification. In 2006, ABIM developed a report on New and Emerging Disciplines in
Internal Medicine (NEDIM-2) to outline the guiding principles for recognition of a discipline as a subspecialty of
Internal Medicine. The report eliminated the term “CAQ,” but stated that certain subspecialties on a case-by-case basis
would continue to require MOC in the “parent” discipline, based on how closely the training in the subspecialty builds
on prior specialty or subspecialty training. An example given in the report is interventional cardiology, which follows
cardiovascular disease training and should therefore be closely linked to the "parent" subspecialty of cardiology. Thus
all diplomates maintaining certification in interventional cardiology are currently required to maintain an underlying
cardiology certificate. The NEDIM-2 report is enclosed and available at http://www.abim.org/pdf/nedim-2-report.pdf.
As you are aware, the Sleep Medicine Certification Program is jointly developed by the American Board of Internal
Medicine (ABIM) and the American Board of Family Medicine (ABFM), the American Board of Pediatrics (ABP), the
American Board of Psychiatry and Neurology (ABPN), the American Board of Otolaryngology (ABOto), and the
American Board of Anesthesiology (ABA). Of the six boards associated with this certification, the ABA is the only
board that does not require diplomates to maintain their underlying certification, although it strongly encourages them
to do so.
Now that the governance structure of ABIM is changing to enhance the ability to consider subspecialty-specific
certification and MOC issues, it should be possible for underlying certification for MOC to be reconsidered for
dependent subspecialties, including Sleep Medicine. This does not guarantee a change in policy, but I do think we can
anticipate consideration. Please know though that this process will take some time and that the current policies
requiring underlying certification in Internal Medicine remain in effect.
Process inefficiencies. We agree that we need to speed up and streamline the approval processes for recognizing
products produced by specialty societies and other organizations for medical knowledge MOC credit. Our Council gave
us authority to redesign the Medical Knowledge (Part 2) approval process with this in mind. We believe the new
process will be considerably less burdensome and faster and should be in place by September 2014.
Specialty representation. I understand your concerns about the timeline for implementation of the new ABIM Sleep
Medicine Specialty Board. The ABIM Specialty Board build-out has proven to be a significant undertaking. As we
discussed at the Spring, 2014 meeting of the Liaison Committee on Certification and Recertification (LCCR), we are in
the process of implementing the first eleven Specialty Boards we formed, and we limited those Boards to the ones that
are sponsored only by ABIM. Creating Specialty Boards alongside the existing Exam Committees for combined
Specialty Boards, like Sleep Medicine, will require us to coordinate with the other sponsor ABMS Boards involved.
Before we expand to the combined Specialty Boards and engage our co-sponsoring ABMS member Boards in making
this commitment, we want to gain some concrete experience/learnings that can be shared with the other sponsor Boards
and societies, including the AASM. We currently anticipate this membership development will get underway in the
second half of 2015. In the meantime, we encourage you to continue working with Kevin Caviston, Manager of
Strategic Communications, who has served as staff-level contact, and until the Board is formed we encourage the
AASM to communicate with Bradley Vaughn, Chair of the ABIM Sleep Medicine Test-Writing Committee, for
physician-level leadership dialogue.
Although you did not raise this specific concern in your letter, we’d also like to provide an update on another issue that
was discussed at the Summit. At the August meeting of the ABIM Board of Directors, the Board agreed that the current
language used for reporting whether or not ABIM Board Certified physicians are meeting requirements in ABIM’s new
MOC program is causing legitimate confusion because some physicians hold some certificates which are
grandfathered, “lifetime” certificates. ABIM is now exploring what changes to the reporting language can be made
while still adhering to the framework developed by ABMS. A statement about this decision is also enclosed.
We recognize that we have an obligation to understand and meet the varied needs of our many specialties. Our
reorganized governance structure empowers the new Specialty Boards to define, refine and set standards in
Certification and MOC in specific disciplines. Although the new Sleep Medicine Specialty Board is not yet formed, it
is important that we maintain an open dialogue with AASM, and we are committed to doing so. While awaiting the
creation of the Sleep Medicine Specialty Board, we would encourage you to raise any concerns directly with Dr.
Vaughn, the Chair of the current Sleep Medicine Test-Writing Committee. We also would encourage you to continue
to attend the LCCR. Under the leadership of Jeanne Marrazzo, MD, Chair-Elect of our Council and chair of the LCCR,
we are revamping the agenda-setting process at LCCR so that it will function more effectively to support bi-directional
communication between internal medicine societies and ABIM.
We continue to welcome constructive feedback from the internal medicine community and are committed to working
very closely with fellow physicians, through medical specialty societies, to design an MOC program that provides all of
the assurances we owe the public about competency and remains meaningful to doctors.
Thank you again for sharing your concerns, and we look forward to continuing the conversation.
Best regards,
Richard J. Baron, MD, MACP
President and CEO, ABIM
David H. Johnson, MD, FACP, FASCO
Chair, ABIM Board of Directors
Lee R. Berkowitz, MD, FACP
Chair, ABIM Council
Bradley V. Vaughn, MD, FAAN, FAASM
Chair, ABIM Sleep Medicine Test-Writing Committee
Enclosures:
July 10, 2014 ABIM letter to the Internal Medicine Community
July 28, 2014 ABIM letter to the Internal Medicine Community
August 15, 2014 statement regarding ABIM MOC status reporting
NEDIM-2 Report
cc:
Jeanne M. Marrazzo, MD, MPH – Chair-Elect, ABIM Council
Daniel J. Cole, MD – Executive Director - Professional Affairs, ABA
Larry R. Faulkner, MD – President and CEO, ABPN
Robert H. Miller, MD, MBA – Executive Director, ABOto
David G. Nichols, MD, MBA – President and CEO, ABP
Mary E. Post, MBA, CAE – Executive Director - Administrative Affairs, ABA
James C. Puffer, MD – President and CEO, ABFM