Everything You Need to Know About Continuing Medical Education – Part 1

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

OVERVIEW OF PHYSICIAN CME REQUIREMENTS IN ILLINOIS

The Medical Practice Act requires licensees to complete a total of 150 hours of CME per three-year license cycle and allows the Illinois Department of Financial and Professional Regulation (IDFPR) to further define the requirement by rule.  The total of 150 hours may be completed at any time during the 3 years and is to be comprised of 60 hours of “formal” or Category I hours, and 90 hours of “informal” or Category II.  (The only exception is that applicants for their first license renewals are exempt from some CME.  See below.) The formal hours must include certain mandatory courses, as described in the section on Mandated Education.

Under their authority, the IDFPR requires licensees to certify at renewal time that they have completed all required CME during the preceding 3 years as a condition to renewing the license for the upcoming 3 years.    Physicians must complete a few courses in certain subject areas (Mandated Education, below).  These hours may each be counted once toward the 90 formal CME hours (out of 150 total hours) in a 3-year physician license cycle, so long as the courses are given by approved sponsors who present required content for the specified amount of time.   Physicians may select course topics for the remainder of the required hours.  When licensees check the application box certifying completion of all required CME, the IDFPR assumes that they have familiarized themselves with the requirements and have successfully completed all of them. A false or fraudulent answer to the certification check-box could result in license discipline, including suspension or revocation, and a fine. 

The IDFPR now sends renewal forms only by email to the last known e-mail address, so licensees certify on the electronic renewal application that they have completed their CME. The burden is on the licensee to complete CME to renew the license, regardless of whether the licensee received actual notice.

WHAT IS FORMAL CME?

Formal CME was described in the past as “contact hours,” because it consisted only of live, in-person classes that physicians had to attend in person.  With current technology, however, many approved CME courses are available online and in other electronic formats, and may be provided as live, recorded, or a hybrid of the two.  Current rules even allow physicians to complete all required CME online.

The Department approves sponsors rather than courses.  Generally, formal CME includes programs conducted by hospitals, specialty societies, chiropractic, osteopathic and medical colleges, and approved professional trade associations, including the Illinois Chiropractic Society. 

CME sponsors are responsible for ensuring that their programs “contribute to the advancement, extension and enhancement of the professional skills and scientific knowledge of the licensee; foster the enhancement of general or specialized practice and values…”; be developed and presented by persons knowledgeable in the subject matter; and meet other requirements, such as verification of attendance.  In addition to traditional lectures, the types of materials that may be used for formal CME include CD-ROMs, printed educational materials, audiotapes, video cassettes, films, slides and computer-assisted instruction; journal club activities; self-assessment activities; and journal-based CME.  (For example, the ICS provides a home study CME Quiz Program.  For information, click here.)

The rules permit chiropractic physicians to obtain CME credits by attending approved programs for medical and osteopathic physicians, and M.D.s and D.O.s may similarly get credit by attending approved chiropractic programs.  The rules also recognize certain teaching activities as formal CME, including teaching in education programs that prepare individuals for licensure under the Medical Practice Act or for postgraduate training. However, licensees should obtain independent documentation of those activities, such as a letter from the education director, attesting to the substance and the hours of the teaching during the pre-renewal period.

All courses given by approved sponsors are accepted toward CME, and, of course, credit is only counted for classes from approved sponsors. The ICS and certain other organizations, hospitals, and specialty societies are automatically approved. Other entities may apply for Department approval, but attendees should make certain any presenters other than those listed as automatic sponsors have obtained approval. Unfortunately, some licensees discover too late that their CME was not approved when they have long since paid for and taken the course and they are called in by the Department for an audit.

All CME sponsors are required to issue certificates to attendees whose participation has been verified. Do not send your certificates to the Department unless they are specifically requested; instead, put them in a place of safekeeping in the event of a future audit by the Department.

(To view Medical Practice Act Rules on formal CME, see subsections (b)(2) and (c) click here.)

WHAT CAN I COUNT AS INFORMAL CME?

Informal CME includes a broad range of professional activities, such as consultation with peers and experts concerning patients; use of electronic databases in patient care; small group discussions, teaching health professionals; medical writing; teleconferences; preceptorships; participating in formal peer review and quality assurance activities; preparation of educational exhibits; and journal reading. The ICS recommends that doctors keep a simple informal CME log containing the date, a brief description of the activity, and the time expended for each entry. This is your documentation of informal CME that can be presented to the Department if you are later audited for CME compliance.

(To view Medical Practice Act Rules on informal CME, see subsection (b)(3) click here. )

MANDATED EDUCATION

As part of 2023 license renewal, physicians must have completed formal CME in four specific content areas: 

• Sexual harassment prevention training (ICS On-demand Course Available);
• Child abuse mandated reporter training (DCFS On-demand Course Available);
• Implicit bias awareness training (ICS On-demand Course Available); and
• Alzheimer’s and other dementias (ICS On-demand Course Available). 

Classes are now available in all of these subject areas, as detailed below.    The IDFPR accepts the remainder of the required 60 hours of formal CME in any other content areas, so long as the sponsors are approved.

SEXUAL HARASSMENT PREVENTION TRAINING FOR PHYSICIAN LICENSEES  

The State of Illinois requires licensed professionals, including physicians licensed under the Medical Practice Act, to complete at least one hour of continuing education in sexual harassment prevention training.  The Illinois Department of Financial and Professional Regulation has adopted rules to implement the provision here.

The law addresses sexual harassment in the work environment by preventing hostile, intimidating or offensive conduct among colleagues and staff.  (This law refers to employment-related conduct, a different topic than a breach of sexual boundaries between clinician and patient, which is addressed specifically for licensed physicians in the Medical Practice Act and Rules.)

“Sexual harassment” means any unwelcome sexual advances or requests for sexual favors or any conduct of a sexual nature when:

• submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s employment;
• submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual; or
• such conduct has the purpose or effect of substantially interfering with an individual’s work performance or creating an intimidating, hostile, or offensive working environment.

“Working environment” is not limited to a physical location that an employee is assigned to perform his or her duties. For example, the law would apply at an out-of-town work-related meeting or dinner.  Also, it is not limited to strict employment relationships; the law applies to independent contractors as well.

For license renewal purposes, physicians must complete the minimum one hour of training for each three-year renewal cycle, and the class may be counted toward the regular minimum of 60 formal (Category I) hours.  Physician licensees must take the course from an approved continuing education sponsor, such as the Illinois Chiropractic Society.  However, the State of Illinois requires all employers to provide all employees with yearly sexual harassment prevention training that is given online by the Illinois Department of Human Rights (IDHR).  This means that physicians who are also employees will be required as part of their employment to take the IDHR class once each year.  Those physician employees who spend a full hour participating in the class may count toward license renewal one and only one hour (during the 3-year license cycle) as fulfilling the sexual harassment prevention training.  The credit is limited to one hour per 3-year cycle, even for physician employees who have taken the class multiple times during that period. 

CHILD ABUSE MANDATED REPORTER TRAINING

As ICS members know, Illinois licensed physicians are included in a list of “mandated reporters” who must notify the Department of Children and Family Services (DCFS) when the physician has reasonable cause to believe that a child may be abused or neglected.  All mandated reporters, including physicians, must complete DCFS mandated reporter training under an the Abused and Neglected Child Reporting Act, effective January 1, 2020.[i]  The training may be counted toward required continuing education hours.

Newly licensed physicians must complete an initial mandated reporter training “within 3 months of their date of engagement in a professional or official capacity as a mandated reporter.” The ICS interprets this to require (in addition to mandated training for existing licensees) that newly licensed physicians must complete training within 3 months of their licensure, because that is the date that the person becomes engaged in his/her professional capacity as a physician.

The mandated reporter training may be provided in person or online.  DCFS provides required training online free of charge here. 

Topics for the course must include, at minimum:  

• Indicators for recognizing child abuse and child neglect, as defined under the Act; 
• The process for reporting suspected child abuse and child neglect in Illinois as required by the Act and the required documentation; 
• Responding to a child in a trauma-informed manner; and 
• Understanding the response of child protective services and the role of the reporter after a call has been made.
• A section on implicit bias, meaning the attitudes or internalized stereotypes that affect people’s perceptions, actions, and decisions in an unconscious manner and that exist and often contribute to unequal treatment of people based on race, ethnicity, gender identity, sexual orientation, age, disability, and other characteristics. The implicit bias section shall provide tools to adjust automatic patterns of thinking and ultimately eliminate discriminatory behaviors.

The implicit bias section shall be in-person or web-based, and shall include, at a minimum, information on the following topics: (i) implicit bias and (ii) racial and ethnic sensitivity.  During these trainings mandated reporters shall complete the following: (1) a pretest to assess baseline implicit bias levels; (2) an implicit bias training task; and (3) a posttest to reevaluate bias levels after training.

Physicians who work with children must complete mandated reporter training at least every 6 years. Physicians must attest at each license renewal (once every 3 years) that they understand they are a mandated reporter of child abuse and neglect, that they are aware of the process for making a report, that they know how to respond to a child in a trauma-informed manner, and that they are aware of the role of child protective services and the role of a reporter after a call has been made.
    

In lieu of repeated training (after the required initial training for all physicians), physicians who do not work with children may instead attest each time at licensure renewal that they understand they are a mandated reporter of child abuse and neglect, that they are aware of the process for making a report, that they know how to respond to a child in a trauma-informed manner, and that they are aware of the role of child protective services and the role of a reporter after a call has been made.  

DCFS Rules require employee physicians and other mandated child abuse reporters to sign statements acknowledging that they are mandated to report suspected child abuse and neglect. The statement is to be made on the DCFS form, which is to be provided by the employer.  The form, entitled “ACKNOWLEDGEMENT OF MANDATED REPORTER STATUS,” also contains a list of the categories of professional licensees who are deemed to be mandated reporters and who must sign the form as employees, which includes licensed physical therapists, athletic trainers, and acupuncturists.  The form can be found here.

For more information about Child Abuse Reporter Mandatory Training, click here.

CME EXEMPTIONS FOR FIRST RENEWALS

IDFPR rules expressly exempt first time renewal applicants from “CME requirements.”  Because “CME” refers to continuing medical education, the ICS believes first time renewal applicants are not required to complete classes mandated under IDFPR rules. However, the ICS believes that first time applicants are not exempt from Child Abuse Mandated Reporter training, because these requirements are found in the Abused and Neglected Child Reporting Act, and not in IDFPR Rules.

Therefore, for the first renewal of a license, physicians who are not employees must complete Child Abuse Mandated Reporter training and are exempted from completing the following classes for the first renewal of the physician license:

1. Sexual harassment prevention training through the ICS or Department of Human Rights or similar approved course;
2. Implicit bias awareness training; and
3. Alzheimer’s and other dementias.

For the first renewal of a license, physicians who are employees must complete Child Abuse Mandated Reporter training and Sexual Harassment Prevention training and are exempt from:

1. Implicit bias awareness training; and
2. Alzheimer’s and other dementias.

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

Access part 2 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.