How To Survive A CME Audit
by Linda L. Zange, DC, Lic. Acup., FICC, DABCO, DABFP
The Medical Practice Act (MPA] and Rules require everyone licensed under the MPA — DCs, MDs, and DOs — to obtain 150 hours of Continuing Medical Education [CME] for the 36 months preceding July 31 in the year of renewal. All 150 hours may be obtained in formal “Category I” hours or may be divided into two categories, 60 hours of formal education and 90 hours of informal. Formal Category I hours are hours obtained in a classroom, convention, webinars, seminars, or journal-based CME, to name a few. They are verifiable hours provided by recognized sponsors who issue CME certificates. The Illinois Chiropractic Society is named in the rules as a sponsor whose classes are accepted by the State of Illinois for credit toward formal CME.
The remaining are Informal “Category II” hours, at a maximum of 90 out of the required 150 hours. Category II hours are consults regarding patients, electronic database utilization for patient care, small group discussions, teaching health care professionals, medical writing, teleconferences, formal peer review, preparing educational exhibits and journal reading. The easiest is reading various journals and publications. You must document your Category II hours by a log or list and include the date read, name of publication or article or a brief description of the activity. Usually, you should only take 1 hour per publication. The greater the number of the formal hours obtained, the fewer informal hours are needed to reach the golden number of 150.
These are the basic rules of the road to navigate CME. At the end of the 3-year license renewal period, the State of Illinois, Department of Financial and Professional Regulation, requires a license renewal fee and a license renewal form which asks the question: “Did you complete your 150 hours of CME including mandated sexual harassment prevention training? YES or NO.”
If you answer NO, you will be audited for compliance with CME requirements. Get an attorney.
If you answer YES, you still may be randomly audited by the Department to verify your compliance. No attorney needed.
Although you do not routinely need to submit your formal CME certificates or log of informal CME for license renewal, it is important that you retain them in the event of an audit. How does an audit occur? The Department will email you a request for your CME hours. What should you do when you see this email? RESPOND! Do not ignore this email.
If you do not have 60 Category I hours and a log of your 90 Category II hours, hire an attorney! Remember that when you incorrectly check “Yes,” indicating completion of CME, you have not only failed to comply with CME; you have also falsified your renewal application. How will the Department handle the issue? There will be a hearing with you and your attorney. It will determine what will happen next. You will be required to obtain your missing CME hours, you will be fined and disciplined, usually a reprimand, although you could be given probation, up to suspension or revocation of your license to practice. You may also be audited for the next license renewal cycle. This discipline will remain on your license for the rest of your career. Each time a patient or prospective patient looks you up online, the discipline will be listed.
SO GET YOUR CME! Don’t think you will not be audited. If you are an ICS general member, the cost of your CME hours is included in your membership fees BUT requires your participation in the formal Category I activities.
If you have the required hours CME hours, without duplication, the procedure for responding to an audit is simple. You make copies of the CME forms received at various events and from various sponsors, arrange them chronologically for the formal Category I hours and include your list or log for the informal Category II activities. Mail the materials to the Department via certified mail or other forms of trackable delivery. You did a good job, so congratulate yourself.
For further information, read the MPA and Rules, which most practitioners have not done. They are found online at www.ILDFPR.com website. For information about mandated CME courses, see: Everything You Need to Know About Continuing Medical Education.