Addressing the Issue of Nuisance CME in Radiology

I was a physician for over a decade before I held more than one state license at a time. Professional life was simple. I worked for a single hospital system or rad group, and my job didn’t involve crossing any borders. It boggled my mind to think about complicating things beyond that.

That situation did not last. In 2011, I dove headfirst into the waters of teleradiology, and the first order of business was to get multiple other licenses. I don’t recall precisely how many. It fluctuated over the subsequent seven years. I probably never had fewer than a dozen at a time.

One of the things you learn when holding multiple licenses is that every state does things differently. On some level you probably knew it beforehand. However, actually getting and maintaining those credentials means personally going through the motions to appease each jurisdiction.

They don’t all make sense, especially when you compare them against one another. Why does state #28 require me to do this whereas none of the other ones do? That goes for getting the licenses in the first place as well as keeping them in good standing.

If you have to do such things, it is good to have savvy people tracking your various requirements because you could easily forget things on your own. Even if you had a good system for remembering to periodically repeat what you have had to do before, new stuff enters the picture all the time, and it would be really easy not to hear about something crucial.

The telerad company I worked for was the biggest and had people who specifically took care of things like this, including tracking rads’ CME. Even if all states were identical, keeping tallies of CME credits would still be useful to keep everyone current with their maintenance of board certification. One wouldn’t want to find oneself facing an audit with a deficit of 100 CME hours for the past couple of years.

To belabor the point, states are not identical. I haven’t bothered to check, but it wouldn’t surprise me to hear that they each require a different annual number of credits to remain in good standing. Fortunately, keeping the American Board of Radiology’s (ABR) Maintenance of Certification (MOC) program happy has been more than enough for any state license I have held.

The states’ demands stand out more like a sore thumb when it comes to specific areas of CME that they each want and, frequently, these have little if anything to do with any given physician’s routine practice. This goes especially for radiologists given that most of us don’t actually see patients. Such creds got nicknamed “nuisance CME” by the telerad company and the name fit very well.

For instance, I have done more than a few rounds of CME about recognizing and reporting child abuse/neglect. I know how to look for signs of non-accidental trauma on imaging, but that’s not what this CME is about. It talks about interviewing the kids and their family members, what a mandated reporter is, when to alert police or other state agencies, etc. None of these mandated courses has ever contained a single radiological image.

I also had the non-joy of several rounds of mandated CME about prescribing opioids and other potential drugs of abuse. Although a lot of rads have to keep DEA numbers for their jobs, most of us don’t prescribe anything. We aren’t likely to stick our necks out by ordering anything more addictive than a Z-Pak.

There have been a few required credits focusing on “waste, fraud, and abuse” in the Medicare/Medicaid world. That is potentially closer to home, but most of us working rads are pretty far from the billing end of things. There are non-doc bean counters who take care of that. If anything, our transgressions are usually on the side of not claiming enough. Most of our billing-related addenda are because we didn’t say some magical word that justifies proper payment.

The lion’s share of this non-radiological nuisance CME seems to come from regulators who can’t be bothered to draw distinctions between different types of docs. From their perspective, it is easier to just assume that anybody with a medical license could theoretically wake up tomorrow and do anything medical at all. Accordingly, they figure they might as well paint all their requirements with a single, broad brush. So what if a few docs in this specialty wind up having to waste their time and money on irrelevant courses?

A problem with that is that each regulator who imposes his or her pet cause CME requirement has no pressure to consider the sum total of regulatory burden he or she is adding to. Each one can just shrug and think, “I’m only mandating an hour or two out of each of these docs’ years.” Add them up, however, and you create some seriously wasted time.

In addition, it is reasonable to expect that there is only so much CME any given doc is going to do. If you require me to spend a dozen hours on stuff that adds zero value to me as a radiologist, chances are excellent that I am going to spend a dozen hours less on courses that actually have something to do with radiology.

I think a fix could be pretty simple. Let any requirement for specific CME subjects include an “opt out” clause. That is, if I see an opioid-related CME mandate, I could submit a digital form stating that I don’t prescribe anything, let alone controlled substances, and it is therefore in nobody’s interest for me to spend time on the matter. If the regulators want to deny my request, they should have to put some compelling reason in writing.

If they want to squawk about how that will take up more of their precious time and trouble, good. Let them see how it feels for a change.