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  • ACOEM Comments on Revised Preventive Medicine Program Requirements

    March 4, 2010

    To:  Residency Review Committee for Preventive Medicine

    Re:  Revised Preventive Medicine Program Requirements

    The American College of Occupational and Environmental Medicine (ACOEM) appreciates your ongoing efforts to refine the requirements for the Preventive Medicine Residency Program. The College agrees with many of the suggested changes, but would like to offer some additional modifications or alternatives for your consideration.

    For several years, ACOEM has been concerned about the decreasing number of preventive medicine residents graduating each year, particularly in occupational and environmental medicine (OEM). Currently, OEM residencies in the United States graduate fewer than 100 residents per year, and the actual number of OEM residency programs has also declined – from 45 in the mid 1980s to less than 25 active residencies today. This number of residency graduates is insufficient to maintain the specialty or to fill the ranks of retiring OEM physicians. In addition, unlike other U.S. residencies, many OEM and preventive medicine residency programs do not receive Medicare funding – thus placing an additional burden on the existing programs and making funding for residents even more difficult to obtain. 

    Therefore, in order to address the decreasing number of U.S. OEM residents and residency programs, ACOEM suggests that the following modifications be made to the proposed Preventive Medicine Residency Program requirements:

    • Ensure that all of the OEM core competencies1 are appropriately covered during either the traditional didactic coursework of the program or in the additional public health-focused offerings. 
    • ACOEM does not support the requirement of two clinical years for ALL preventive medicine residents. Apparently this constraint is motivated by state licensing Board requirements, which in some states now require two (2) clinical years of training for licensure. Currently, some physicians who are already Board certified in another specialty (which would fulfill state licensing Boards’ criteria of two clinical years of training) are allowed to complete an OEM residency with only one (1) additional clinical year. To address this concern, ACOEM is proposing a Complementary Pathway option for Board certification for these individuals that would be in addition to the current ABPM Special Pathway or Alternative Pathway. 

    Complementary PathwayAs previously noted, there is presently a profound shortage of both OEM residents and residency programs. For the foreseeable future, demand for OEM physicians will have to be met by lateral movement into the field. The consequence of this movement is a loss of control over quality assurance and preparation of these practitioners. 

    Those engaged in training within OEM have long recognized the frequent occurrence of early- or mid-career physicians who wish to re-train in, or enter, OEM practice. Recognition of the attractiveness of many of these physicians as candidates for OEM training is widespread; particularly if they are certified by another specialty Board, as these physicians often bring clinical acumen and experience as well as a wide range of practice skills and life experiences not found among recent medical school or residency program graduates. The existing ABPM Alternate Pathway does allow mid-career physicians to become Board certified in OEM without completing the entire OEM residency program, but this pathway is closed to anyone who graduated from a school of medicine or osteopathic medicine after January 1984, so only a minority of physicians are still eligible for this Pathway. 

    Therefore, ACOEM has been working with ABPM to address the situation of mid-career physicians and has recommended to the Board that in addition to its Special Pathway and Alternate Pathway, the following Complementary Pathway be available to mid-career physicians: 

    The Complementary Pathway would be open to physicians (MDs or DOs) who are currently licensed to practice medicine and who are Board certified in another specialty (i.e., family practice, internal medicine, emergency medicine or other clinical fields), and who have practiced OEM for more than 20 hours a week for at least 2 years. Complementary Pathway physicians would be required to complete coursework in the five core graduate-level courses and additional coursework to ensure that the OEM core competencies are addressed, and complete one (1) year of formal OEM residency clinical training.

    In addition, ACOEM suggests the following changes/clarifications be made to the proposal: 

    • Lines 561-565: ACOEM suggests that prospective preventive medicine residents be required to complete a 12-month internship in a “clinical field,” not just in the fields specified as emergency medicine, family medicine, internal medicine, obstetrics/gynecology, pediatrics, surgery, or a traditional year. Some prospective preventive medicine residencies may have done internships in other clinical fields such as psychiatry, physical medicine and rehabilitation, or other relevant clinical specialties that are not eligible under the current suggested requirements.
    • Lines 1218-1223: ACOEM supports the need for more rigor in curriculum organization and resident experi-ence, but also feels that it is important to allow some flexibility in the individual programs. In addition, certain terms and definitions contained in the proposal are passé or unclear. The current proposal states that clinical experiences need to take place in an “ambulatory care setting,” and also mentions “industrial settings.” ACOEM suggests that the term “industrial setting” be substituted with the more accurate and descriptive term “corporate or occupational health settings.” It is also unclear if rotations at health departments, departments of labor and industry, occupational safety and health administration rotations, or corporations – all integral parts of any preventive or OEM residency – would be included in the “ambulatory care setting” definition. If not, this definition needs to be expanded to include these important clinical or population health experiences. 

    In conclusion, ACOEM again wishes to thank you for your willingness to address this issue. We look forward to and welcome any further discussion. 

    Sincerely yours,
    Pamela A. Hymel, MD, MPH, FACOEM

    1ACOEM Special Committee on Competencies. American College of Occupational and Environmental Medicine Competencies: 2008. J Occup Environ Med. 2008;50(6):712-24. Available at www.acoem.org/oem.aspx.