Opposition to Creation of Subspecialty Certification for Micrographic Dermatologic Surgery (MDS)

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To: Members of the ABMS Committee on Certification (COCERT)

Thank you for this opportunity to comment on the proposal by the American Board of Dermatology (ABD) to create a new subspecialty certification in Micrographic Dermatologic Surgery (MDS).

The Association of American Physicians and Surgeons (AAPS) is a non-profit membership organization of physicians and surgeons who are mostly in small, independent practices. Founded in 1943, AAPS defends and promotes the practice of private, ethical medicine. AAPS has members in virtually every specialty and State, and AAPS speaks out frequently about issues concerning patients and medical practice.

We oppose the proposal. The creation of this new subspecialty is not only unnecessary but would run counter to the best interests of patients in need of lifesaving dermatologic surgical care.

The ABD states that the reasoning for the new specialty certification, “is to assure that patients with advanced skin cancer can identify and access physicians with this subspecialty expertise.”

However the proposal of the ABD to create a new subspecialty certification would achieve the very opposite of these goals. Patients would be hindered from identifying physicians qualified to treat their disease, but who choose not to submit to even more ABMS certification requirements that are too often irrelevant and counterproductive to the practice of quality medicine. In addition, access to physicians would decrease due to ABMS certification requirements imposed by insurers, other payers, and facilities that are sure to follow the creation of any new subspecialty certification.

As you are aware, AAPS is currently suing the ABMS because of its anti-competitive, monopolistic behavior and the requirements insurers, facilities, and others have imposed on physicians apparently at the urging of ABMS. The past behavior of ABMS, and many of its member boards, validates the concerns of AAPS and others who are speaking out in opposition to this application.

In conclusion, a particularly telling comment by the ABD is this: “The subspecialty [MDS] and its training programs have been in existence for 50 years ….”

For over 50 years physicians and patients in need of this type of care have been forming healthy patient-physician relationships without the existence of a subspecialty certification. Why is it needed now? Some might conclude that the change is more about driving revenue and than about what is best for patients.

Sincerely,

Jane M. Orient M.D.
Association of American Physicians and Surgeons

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