Everything You Need to Know About Continuing Medical Education
As an Illinois licensed doctor of chiropractic, you enjoy full status as a physician under the Medical Practice Act. With that status comes the responsibility to meet the same continuing medical education (CME) requirements as all physicians under the Act and the rules. The Division of Professional Regulation of the Department of Financial and Professional Regulation (IDFPR) requires licensees to certify at renewal time that they have completed CME during the preceding 3 years as a condition to renewing the license for the upcoming 3 years.
Typically, the current license cycle would end on July 31, 2020. However, in response to the COVID-19 pandemic, the 2020 license renewal cycle has been extended to September 30, 2020. Therefore, you will need to complete CME by September 30, 2020, and each three-year cycle thereafter (ending July 31), to renew your license. It is not complicated to comply, but failure to comply can complicate your professional life considerably. You can read more about this change in the article Coronavirus (COVID-19) In The Chiropractic Physician Office.
Note the IDFPR now accepts only electronic applications for physician renewal and requires each licensee to keep the agency notified of current address, email address, and phone number. However, this change does not lessen CME requirements in any way. The IDFPR will no longer send paper renewal forms but will e-mail them to the last known e-mail address, and licensees will have to certify CME completion on the electronic form. The burden is on the licensee to complete CME and renew the license, regardless of whether the licensee received actual notice.
The CME rules can be found in Section 1285.110 of the Rules for the Administration of the Medical Practice Act (68 Illinois Administrative Code 1285.110), which can be viewed on the Division of Professional Regulation website at http://www.idfpr.state.il.us/. Physicians are required to complete 150 hours of CME per 3-year pre-renewal period, or by July 31, 2020 (Now extended to September 30, 2020, for this cycle). The rules allow completion of the hours at any time during the 3 years. The total of 150 hours is to be comprised of 60 hours of “formal” or Category I hours, and 90 hours of “informal” or Category II.
What is Formal CME?
Formal CME was previously described in terms of “contact hours,” because it consisted only of actual classes that one had to physically attend. In the current age of technology, however, many approved CME courses are available online and in other electronic formats. The Department approves sponsors rather than approving individual courses. 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. Incidentally, medical doctors and osteopaths may receive credit for formal CME courses given by approved chiropractic presenters, as DCs may similarly receive credit for formal CME presented by approved medical or osteopathic organizations.
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.
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.
How Do I Certify Completion of CME to the Department of Financial and Professional Regulation?
Once you have completed all your hours, you will, of course, have 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 completed CME for the 3-year period immediately preceding that renewal. Depending on your answer, 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 as of August 1, 2020, 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.
- 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 Division’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, 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. 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 (Now extended to September 30, 2020). Because applicants who do not complete CME risk having their licenses placed in non-renewed status and having to discontinue practice, the ICS and I strongly recommend you complete your required CME and not rely on obtaining a waiver.
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. This is because a certain number of licensees are randomly audited after each renewal, and those licensees must produce their certificates and other evidence such as the informal CME log to document 150 hours. If they cannot produce proper documentation, these licensees are called into DPR for a disciplinary conference, 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 was recently increased to up to 10 years, so I recommend that you retain your certificates through at least 4 renewal cycles in case you are audited. The usual sanction for false verification of CME is a reprimand and fine – formal, public discipline that will remain on your record indefinitely.
The Simple Solution
If this is all too much information, it can be boiled down to this: take your required formal hours from an approved sponsor, make certain you obtain certificates and keep them safely in a file. 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. 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.
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.