Can Optometrists Sell Over-the-Counter Vitamins



SUMMARY OF MAIN POINTS: 1. “Value based health care” is a trend in health care that centers around the notion that quality and efficient health care saves money. It assumes that providers of health care can be rated in terms of the quality of care they provide. A method by which third-party payers typically evaluate providers for continued competence is through board certification by an American Board of Medical Specialties (ABMS) approved board. As CMS (Medicare) looked for a quality measure for providers, predictably, it looked to maintenance of certification (MOC) as that standard. Recognizing that not all health care providers are MDs, CMS (Medicare) called for a standard that was either a maintenance of certification program approved by the ABMS or its equivalent. 2. American Board of Optometry (ABO) board certification provides a pathway for doctors of optometry, who find it helpful, to demonstrate a credential for provider quality standards. The ABO has been recognized as equivalent to an ABMS board to provide certification as an indicator of ongoing competence. 3. The critical element in ABO board certification is its legitimacy as recognized by CMS. CMS agrees that the ABO MOC program is equivalent to MD board certification MOC programs; this recognition differentiates ABO (from any other currently available offering) as the only certification for doctors of optometry that meets the CMS criteria. 4. It is anticipated that as third-parties continue to try to establish competence and ongoing competence, they will - as has CMS - look to ABO for that standard in optometry as they have looked to ABMS boards within medicine.ABOUT CMS: 1. For the last several years, CMS has been establishing quality standards for providers, procedures and facilities. Much of this initiative is known as the Physician Quality Reporting System (PQRS). 2. The ABO is the only board certification and maintenance of certification (MOC) pathway for optometric doctors determined by CMS to be equivalent to an MD Board Certification (ABMS).3. CMS recognition is required for doctors to become eligible for enhanced Medicare reimbursement, e.g., PQRS Maintenance of Certification bonus payment. 4. CMS recognition often becomes the model for other payers. QUALITY STANDARDS AND THE TOOL OF BOARD CERTIFICATION: 1. When Congress, federal agencies, the public, and public and private payers look at board certification as an indicator of quality and ongoing professional competence, they will base programs, requirements and expectations on the standards of the ABMS certifying boards - just as they did for the PQRS MOC bonus - and demand non-ABMS boards to be ”equivalent” to the ABMS boards. 2. The board certification tool for optometry must be equivalent to ABMS boards. This requires ABO to have requirements that are legitimately comparable to ABMS board certification requirements. ABO must look like and act like ABMS boards in order for ABO to suffice for doctors of optometry who want this tool to be accepted by the public, Congress, federal agencies, and public and private payers.IMPORTANT ABO TIMELINE:Certification Registration by April 30, 2013Doctors of optometry may use their experience points and points granted for residencies to qualify them for taking the test during the initial phase-in period that ends in January 2014. In order to have the test completed by December 31, 2013, doctors must apply for certification by April 30, 2013. In addition to Category 1 and 2 education, the below timetable sets forth the availability of ABO phase-in rules for professional designations and education that can be used toward the 150 points of post-graduate requirements needed to qualify to sit for the certification exam:?? Must apply to be an active candidate for certification by April 30, 2013? ACOE Accredited Residency - 150 points (regardless of date of completion)? Fellow, American Academy of Optometry - 50 points completed by June 30, 2013? Fellow, College of Optometrists in Vision Development - 50 points completed by June 30, 2013? Experience in Active Clinical Practice - 5 points per year of active clinical practice? Complete the examination by January 2014Certification Registration after April 30, 2013In addition to Category 1 and 2 education, the requirements for obtaining ABO certification for doctors who register after April 30, 2013, are:? ACOE Accredited Residency - 150 points if competed less than 3 years ago, or 100 points if completed 3-10 years ago. No points if completed more than 10 years ago.? Fellow, American Academy of Optometry - 50 points if completed within 10 years. No points if completed more than 10 years ago.? Fellow, College of Optometrists in Vision Development - No longer accepted.? Experience in Active Clinical Practice - No longer accepted.For addition information, see the ABO website.FREQUENTLY ASKED QUESTIONSWhy is a separate certification test necessary?There is a statutory requirement in the Social Security Act, as amended by the Affordable Care Act, i.e., health care reform, that an MOC program must be an ABMS board or equivalent. Furthermore, note that the program must include an examination. See Section 1848(m)(7)(C), and (C)(i)(III) in particular.Please note that the National Board of Examiners in Optometry (NBEO) has stated that its examination is not designed to meet CMS criteria for board certification.2. Why can’t the deadline for using experience points be extended? No other ABMS programs allow long-term credit for experience points. Consistency with other ABMS programs is an essential element of CMS recognition. The limited window in which experience points are accepted is consistent with other ABMS board programs and it is not possible to deviate from this. 3. What is Maintenance of Certification?According to CMS, the term “Maintenance of Certification Program” means a continuous assessment program, such as a qualified American Board of Medical Specialties Maintenance of Certification program or an equivalent program , that advances quality and the lifelong learning and self-assessment[378] of board certified specialty physicians by focusing on the competencies of patient care, medical knowledge, practice-based learning, interpersonal and communication skills and professionalism. Such a program shall include the following: (I) The program requires the physician to maintain a valid, unrestricted medical license in the United States. (II) The program requires a physician to participate in educational and self-assessment programs that require an assessment of what was learned. (III) The program requires a physician to demonstrate through a formalized, secure examination, that the physician has the fundamental diagnostic skills, medical knowledge and clinical judgment to provide quality care in their respective specialty.4. What is the difference between the ABO program and others being marketed to optometrists at this time? Only ABO board certification is recognized by CMS. This recognition is the only way to qualify for bonus payments through CMS, e.g., PQRS. Only ABO provides doctors of optometry with the pathway to qualify for the Maintenance of Certification (MOC) as required by CMS and outlined above. ###Note: The above information is provided for informational purposes only. It is not intended to replace the professional advice of legal counsel. ................
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