Everything You Need to Know About Continuing Medical Education – Part 2

Everything You Need to Know About Continuing Medical Education – Part 2

This article is part 2 of a two-part series regarding the CME requirements for chiropractic physicians in the State of Illinois.  Part 1 of this series pertains to Illinois mandated education for physicians. You can find part 1 of the series here.

As an Illinois licensed doctor of chiropractic, you enjoy full status as a physician under the Medical Practice Act. With this status comes the responsibility to meet the same continuing medical education (CME) requirements as all physicians under the Act and the rules.  This article provides a comprehensive view of CME that physicians must complete to keep their licenses active.

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HOW DO I CERTIFY COMPLETION OF CME TO THE DEPARTMENT OF FINANCIAL AND PROFESSIONAL REGULATION?

Once you have completed all your hours, you should maintain all of your certificates in a safely-kept file. On your renewal application, the Department asks that you check a box to indicate that you have fully complied with the CME requirements for the 3-year period immediately preceding that renewal. Full compliance indicates that you have not only met the total number of hours, but that you have also completed the mandated courses.  If you renew timely, you will not have to submit your CME certificates and the IDFPR will rely solely on your certification; however, applicants who renew after the July 31 deadline are required to submit paper copies of all CME certificates.

Depending on your answer to the certification question, there are a number of possible outcomes, as follows:

  • If you answer “yes,” indicating you have completed the appropriate CME, and if you have no other impediments to renewal (for example, incomplete online physician profile), your renewal license will be issued.
  • If you answer “no” and do not request a waiver, your license will be placed in non-renewed (non-disciplinary) status, and you may not practice unless and until you complete CME and restore your license. This status is public information, but it is not recorded as a discipline and is not reported to any data bank.  You may also check an option here to place your license in inactive status.  This has the same effect as non-renewed status; the only difference is that fees to reinstate the license are less for an inactive license than for a non-renewed.
  • If you answer “no” and request a waiver of CME (not recommended; only available in extremely limited, specific situations – see explanation below), your license will be renewed pending the IDFPR’s consideration of your waiver request. If your request is denied, your license will then be placed in non-renewed status and will remain so until you complete CME. If it is granted, your license will remain renewed until the next renewal, at which time you are again subject to the usual CME requirements.
  • If you answer “yes” and you have NOT completed the appropriate CME, including the mandated classes, you are risking discipline and other charges (see section below regarding audits and disciplinary proceedings).

REQUESTS FOR WAIVER OF CME REQUIREMENTS

DPR receives a number of requests for waiver of CME during each renewal, but they are rarely granted. The rules allow the Medical Licensing Board to waive CME requirements in cases of hardship, defined as full-time military service or a temporary incapacitating illness.

Requesting a waiver can be tricky, because if the applicant argues that he or she is under a serious, chronic disability preventing completion of CME, DPR may commence a licensure investigation into the applicant’s competency to practice. Additionally, CME is easily completed on line today.  In most of the rare instances where waivers have been granted (for reasons other than military service), the applicants were under a temporary disability for a significant portion of the 3-year renewal cycle, followed by full resolution of the disability. Very few licensees actually meet this description. 

The Medical Licensing Board carefully considers all requests, but the Department’s decided preference is to encourage completion of CME, and the wide availability of electronic courses factors heavily into their tendency to deny requests. All requests for waivers must be made prior to renewal; DPR will not consider any made after July 31 of the renewal year. Applicants who do not complete CME risk having their licenses placed in non-renewed status and having to discontinue practice.  Therefore, the ICS strongly recommends completing the required CME rather than relying on obtaining a waiver, unless the applicant’s situation is a rare case that can truly qualify for a waiver.

Finally, applicants occasionally request excusal from CME and ask to maintain their licenses solely to treat or write prescriptions for their families. The rules contain no provision for waiver of CME or for renewal of a license for this reason, and these requests are therefore denied.

CME AUDITS, DISCIPLINARY PROCEEDINGS AND RETENTION OF CERTIFICATES

Completing CME is considered a condition of renewal, so failure to complete CME by itself is not treated as a disciplinary matter. HOWEVER, licensees launch themselves into potential disciplinary proceedings when they falsely answer “yes” to the CME question on the renewal application.

The Rules for the Medical Practice Act charges the IDFPR to conduct random CME audits to verify compliance with CME requirements.   Although a very small number of physicians have been audited, all should be prepared for the possibility.  Under the Medical Practice Act, each licensee is responsible to maintain records of completion of continuing education and to be prepared to produce the records when requested by the Department.

Licensees under audit must produce their certificates and other evidence, such as the informal CME log, to document 150 hours, as well as completion of the mandated courses. If the licensees cannot produce proper documentation, they are called into IDFPR for disciplinary conferences, and they can be prosecuted for violating the Medical Practice Act for misrepresentation on the renewal application. The statute of limitations for Medical Practice Act violations can be as long as 10 years, so the ICS recommends retaining certificates through at least 4 renewal cycles in case of audit. The usual sanction for false verification of CME is a reprimand and fine – formal, public discipline that will remain on your record indefinitely.

KEEP IT SIMPLE AND STRESS-FREE

The easiest approach to CME can be boiled down to this: take your required formal hours from approved sponsors, make certain you obtain certificates, and keep them safely in a file. Make certain that you complete mandated courses as part of your CME, and stay abreast of upcoming additional required course areas by keeping current with the ICS’ The Edge or other reliable source.  Create a simple log for informal CME and make entries as you go along, each time you read a journal article, confer with colleagues, etc.  If you are audited, it will be a simple matter of submitting your documentation. Assessing your CME progress as you go along for the next renewal, locating your certificates and properly documenting other CME activities will lessen last-minute stress when renewal applications are issued.

And even if you aren’t audited, you will know that you are ready to demonstrate your compliance with the continuing education standards expected of those who hold the title of “physician” in Illinois. You may download one of our own CME Tracking Forms as well.

CME Tracking Forms Cat I – August 1, 2020 – July 31, 2023
CME Tracking Forms Cat II – August 1, 2020 – July 31, 2023

Access part 1 of the article series here.

Editor’s note: The ICS is an approved CME sponsor and presents a variety of courses throughout each renewal cycle. Completing CME through the ICS is an easy way to be assured you are receiving excellent course material that is approved for Illinois CME.

(To view the Medical Practice Act, 225 ILCS 60/20, click here)

To view the physician CME rules, click here.  To view additional health care provider CME rules (which include physician requirements), https://www.ilga.gov/commission/jcar/admincode/068/068011300E04000R.html

https://www.ilga.gov/commission/jcar/admincode/068/068011300E05000R.html

About Author

Adrienne Hersh, JD, ICS Legal Counsel

Adrienne has worked as the Illinois Chiropractic Society's General Counsel since 2003. She represents the Society as in-house counsel and advises the organization on a wide range of legal issues affecting chiropractic physicians, including licensing laws and rules, scope of practice, insurance and reimbursement, business structuring, labor and employment, contracts and litigation. Adrienne previously served for 8 years as general counsel to the Illinois Department of Professional Regulation (now the Division of Professional Regulation, Department of Financial and Professional Regulation), where she was chief legal counsel responsible for overseeing all legal issues and advising the 50+ licensing and disciplinary boards, including the Medical Disciplinary Board and the Medical Licensing Board. She is a member of the Illinois State Bar Association Health Care Section, the Illinois Association of Healthcare Attorneys, and the National Association of Chiropractic Attorneys.

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