The Sunrise book – Business & Professional Development Office

From Right to Left: Dr. Saideh Farahmand a USFMD from Iran, Ms. Sarah Huchel – Chief Consultant of The Sacramento Governor Office of Business and Professional Development, and me Katherine Miller. I met with Sarah Huchel and Dr. Saideh F in Mid October 2015 to hand her my preparation as the Sunrise book of answers for the questionnaire she gave me two weeks ago, which I copy and paste below.

SUNRISE QUESTIONNAIRE

SENATE COMMITTEE ON BUSINESS PROFESSIONS

AND ECONOMIC DEVELOPMENT

REGULATORY REQUEST QUESTIONNAIRE

SUNRISE QUESTIONNAIRE

ANSWERS by KATHERINE THUY MILLER, US-FMD

September – 2015

SENATE COMMITTEE ON BUSINESS PROFESSIONS

AND ECONOMIC DEVELOPMENT

REGULATORY REQUEST QUESTIONNAIRE

Instructions for completing this questionnaire

  • Responses to this questionnaire should be typed and dated. Each question should be answered within a single main document, which is limited to 50 pages. Supporting evidence for your responses may be included as an Appendix, but all essential information should be included within the main document.

  • Each question from the questionnaire should be stated in upper case (capital) letters. The response should follow in lower case letters.

  • Each part of every question must be addressed. If there is no information available to answer the question, state this as your response and describe what you did to attempt to find information that would answer the question. If you think the question is not applicable, state this and explain your response.

  • When supporting documentation is appropriate, include it as an Appendix. Appendices would be labeled as follows: Each document appended should be lettered in alphabetical order. Pages within each appendix should be numbered sequentially. For example, the third page of the first appendix will be labeled A3, and the fifth page of the second appendix will be labeled B5. References within the main document to information contained in Appendices should use these page labels.

  • Please read the entire questionnaire before answering any questions so that you will understand what information is being requested and how questions relate to each other.

Section A: Applicant Group Identification

This section of the questionnaire is designed to help identify the group seeking regulation and to determine if the applicant group adequately represents the occupation.

What occupational group is seeking regulation? Identify by name, address and associational affiliation the individuals who should be contacted when communicating with this group regarding this application.

Answers:

Thursday August 20th 2015 Responded by MILLER, KATHERINE T, USFMD

Senate Committee On Business,

Regulatory Request Questionnaire

Professions & Economic Development

Page 2

a- What occupational group is seeking regulation?

Medical doctors who are US citizens, Green Card holders, also known as US-FMDs, US citizen Foreign trained Doctors with ECFMG certifications. Please read appendix WHO ARE USFMDs and question 5

These are the foreign- trained Doctors who have passed USMLE step 1, step 2 CK, step 2 CS and successfully verified their medical school transcripts officially from their foreign trained medical schools to ECFMG. And the ECFMG issue the ECFMG certificates. (ECFMG = Educational Commission for Foreign Medical Graduates)

More details would be explained in the upcoming questions

b- Identify by name, address and associational affiliation the individuals who should be contacted when communicating with this group regarding this application.

Miller, Katherine Thuy, US-FMD, ECFMG enhancement

1208 Elgin Street

San Leandro, CA 94578

Phone: 510-331-5453

Email: kmt1791@gmail.com

c- There has not been an official organization for this group of US-FMDs. The reason for this is a protracted complicating issue that needs to be explained in details in the upcoming questions.

More details would be explained in the upcoming questions

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SENATE COMMITTEE ON BUSINESS PROFESSIONS

AND ECONOMIC DEVELOPMENT

REGULATORY REQUEST QUESTIONNAIRE

Section A: Applicant Group Identification

This section of the questionnaire is designed to help identify the group seeking regulation and to determine if the applicant group adequately represents the occupation.

List all titles currently used by California practitioners of this occupation. Estimate the total number of practitioners now in California and the number using each title.

Answers:

Thursday August 20th 2015, responded by MILLER, KATHERINE T, USFMD This occupation is a brand-new idea and so never has there been any current title.

However, there are currently in practice a few similar levels of expertise professionals as listed below:

a- Physician Assistant- PA: national wide professionals that has been in practice at least since 1960s; there are around 85,000 PA

b- Nurse Practitioner – NP: national wide professionals that has been in practice at least since 1960s 110,000 NP

c- Assistant Physicians – AP: a new title for new professionals, who are new medical graduates from MD medical schools who are granted licenses to practice in Missouri. This new bill was signed by Governor Jerry Nixon in 2014 and the new bill is still under serious consideration of how to put these new Assistant physicians into practice as a rescue solution for the severe shortage of MDs in Missouri- The number has not yet established. (Please see attachment of the Missouri Bill)

Please see below chart:

Estimated number of nurse practitioners and physician assistants practicing primary care in the United States, 2010

Senate Committee On Business,

Regulatory Request Questionnaire

Professions & Economic Development

Page 2

Provider type

Total

Percent primary

Practicing primary

care

care

Nurse

106,073

52.0%

55,625

practitioners

Physician

70,383

43.4%

30,402

assistants

This is one in a series being produced by the Agency for Healthcare Research and Quality’s (AHRQ) Center for Primary Care, Prevention, and Clinical Partnerships to further inform policy discussions around the U.S. primary care workforce. Information is based on a comprehensive primary care workforce analysis conducted by the Robert Graham Center for AHRQ. Please visit http://www.ahrq.gov/research/pcworkforce.htm for more in the Primary Care Workforce Facts and Stats series.

Reference

The Registered Nurse Population: Findings from the 2008 National Sample Survey of Registered Nurses. Table 45, Appendix A.

http://www.thefutureofnursing.org/sites/default/files/RN%20Nurse%20Population.pdf

Page last reviewed October 2014

Internet Citation: The Number of Nurse Practitioners and Physician Assistants Practicing Primary Care in the United States: Primary Care Workforce Facts and Stats No. 2. October 2014. Agency for Healthcare Research and Quality, Rockville, MD. http://www.ahrq.gov/research/findings/factsheets/primary/pcwork2/index.html

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SENATE COMMITTEE ON BUSINESS PROFESSIONS

AND ECONOMIC DEVELOPMENT

REGULATORY REQUEST QUESTIONNAIRE

Section A: Applicant Group Identification

This section of the questionnaire is designed to help identify the group seeking regulation and to determine if the applicant group adequately represents the occupation.

Identify each occupational association or similar organization representing current practitioners in California, and estimate its membership. For each, list the name of any associated national group.

Answers:

Thursday August 20th 2015, responded by MILLER, KATHERINE T, USFMD

a- The brand new title has not yet any association for some good reasons. There will be explanations in next coming questions to avoid repetitive information.

b- For Physician Assistant and Nurse Practitioner associations: there are many associations to advocate for PAs and NP and a board of licensing for Physician Assistants and a board for licensing for nurse practitioners. They are all separate associations and working independently to one another.

c- List some of the current organizations / associations for the similar titles:

Physician Assistants:

Below is some of many PA associations and organizations

Nurse Practitioners:

Senate Committee On Business,

Regulatory Request Questionnaire

Professions & Economic Development

Page 2

– American Academy of Nurse

8515 Georgia Avenue, Suite 400

Practitioners (AANP)

Silver Spring, MD 20910-3492

P. O. Box 12846; Austin, TX 78711

Phone: 800.284.2378

Phone: 512-442-4262

Web address:

email: admin@aanp.org

http://www.nursecredentialing.org

Web address: http://www.aanp.org

– Gerontological Advanced Practice

–

American Association of Critical-

Nurses Association (GAPNA)

Care Nurses (AACN)

East Holly Avenue Box 56

101 Columbia

Pitman, NJ 08071-0056

Aliso Viejo, CA 92656-4109

Phone: 866-355-1392

Phone: 800-899-AACN (2226)

Web address: http://www.gapna.org

Web address: http://www.aacn.org

– International Council of Nurses

3, Place Jean Marteau

– American College of Nurse

Practitioners (ACNP)

1201 – Geneva Switzerland

225 Reinekers Lane, Suite 525

Phone +41-22-908-01-00

Alexandria, VA 22314

Web address: http://www.icn.ch

Phone: 703-740-2529

– National Association of Pediatric

Web address:

Nurse Practitioners (NAPNAP)

http://www.acnpweb.org

20 Brace Road, Suite 200; Cherry

–

American Nurses Credentialing

Hill, NJ 08034

Center

Phone: 856-857-9700

(Subsidiary of the American Nurses

email: info@napnap.org

Association)

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Senate Committee On Business,

Regulatory Request Questionnaire

Professions & Economic Development

Page 3

Web address:

Gaithersburg, MD 20877-4152

http://www.napnap.org/index.aspx

Phone: (301) 330-2921 or 888-641-

–

National Certification Corporation

2767 (tollfree)

142 E. Ontario Street, Suite 1700,

Web address: http://www.pncb.org

Chicago, IL 60611

– etc.

Phone: 312-951-0207

Web address:

http://www.nccwebsite.org

– National Council of State Boards of

Nursing (NCSBN)

111 East Wacker Drive, Suite 2900

Chicago, IL 60601-4277

Phone: 312-525-3600

Web address:

https://www.ncsbn.org/index.htm

– Nurse Practitioners in Women’s

Health

505 C Street, Northeast

Washington, DC 20002

Phone: 202-543-9693

Web address: http://www.npwh.org

–

Oncology Nursing Certification

Corporation (ONCC)

125 Enterprise Drive

Pittsburgh, PA 15275

Phone: 412-859-6104

Web address: http://www.oncc.org

– Pediatric Nursing Certification Board

800 South Frederick Avenue, Suite 204

SENATE COMMITTEE ON BUSINESS PROFESSIONS

AND ECONOMIC DEVELOPMENT

REGULATORY REQUEST QUESTIONNAIRE

Section A: Applicant Group Identification

This section of the questionnaire is designed to help identify the group seeking regulation and to determine if the applicant group adequately represents the occupation.

Estimate the percentage of practitioners who support this request for regulation. Document the source of this estimate.

Answers:

Thursday August 20th 2015, responded by MILLER, KATHERINE T, USFMD

There have not yet been an established number of practitioners who support this request of regulation. Please review the upcoming questions for the detailed explanations to avoid repeating information.

More details would be explained in the upcoming questions especially in Section C Part 1C.

SENATE COMMITTEE ON BUSINESS PROFESSIONS

AND ECONOMIC DEVELOPMENT

REGULATORY REQUEST QUESTIONNAIRE

Section A: Applicant Group Identification

This section of the questionnaire is designed to help identify the group seeking regulation and to determine if the applicant group adequately represents the occupation.

Name the applicant group representing the practitioners in this effort to seek regulation. How was this group selected to represent practitioners?

Answers: (also answer for question 1)

Friday August 21st 2015, responded by MILLER, KATHERINE T, USFMD

There is a group, but they are not yet well established. The name of the group is Residency Ready Physician on Face book. This group has tried to find a way for them to return to practice medicine as a conventional pathway of licensing for medical doctor. However, the new professional title is Physician Associate, acronym as PhA, is trying to establish a new and alternative direction toward licensing for PhA to work similarly to PA and NP and after a period of time, they will move toward licensing for Medical doctor.

More details would be explained in the upcoming questions especially in Section C Part 1C and the appendix about International medical graduates.

WHO ARE USFMDs: (USFMDs/USFMGs versus IMDs/IMGs)

Acronym expansions:

USFMDs: United States Foreign Medical Doctors

USFMGs: United States Foreign Medical Graduates

IMDs: International Medical Doctors

IMGs: International Medical Graduates

Please see the appendix of the flow chart the current medical licensing and the proposals and Lobbying for PhA-eAML of section C.

To actually understand the insightful depth of the core problem of the American medical licensing, we should understand the cultures of US-FMDs; how they do in their new homeland, we get to the mentality of this proposal.

The American public has a vague idea about the whereabouts of their physicians. There are domestic trained MDs yet US citizens and a small percentage is domestic trained yet non-US citizens as foreigners apply into US medical schools. This group is of a very small percentage, but they do exist.

However, the larger portion of foreign trained medical doctors much more complicated because even the same concept as foreign trained physician, there are different groups with slightly different characteristics yet critical for us to understand the slightly differences to be able to address the issue more accurately.

There are foreign trained yet they are born in the US, grow up in the US, and graduate their undergraduate and graduate degrees in the US before applying into medical schools. Then, they choose to go to medical schools in foreign countries; the main reason is to reduce the load of student loans as a domestic trained MD’s burden on graduation, no less than at least 250,000 dollars! This type of US-FMDs usually goes to medical school in the Caribbean since these schools are somewhat close to homes, but they can go to any school on anywhere of the world as long as the schools are approved by the IMED list (International medical education directory) so that they can return to practice in the US.

Another type of US-FMDs, who are born, grow up, and actually had their medical school trained in their foreign countries. These doctors immigrated to the US via permanent immigrant visas. A lot of situations are family reunions with different kinds of permanent immigration visas; but, importantly, they work on their own without any help from medical licensing system for obtaining their permanent visas to enter the US legally. These doctors, of course, want to become MDs and be able to practice in the new homeland. That is actually windfall benefits for the American people. However, these doctors who came to the US in the permanent immigration pathway are not very well informed about the licensing system and so they usually take longer time to figure out what and how they have to work on to get their licenses. This is actually not their mistakes for the ignorance and unawareness of the new country information especially the intricate medical licensing of the US. It is the country responsible unable to help them adequately. These permanent legal immigrant doctors obtain their legal American resident status as of green card holders and eventually become US-citizens. They struggle to settle down their lives in America. They work all kinds of jobs and do their citizen duty, paying tax and attending other duties in communities alongside with striving through the licensing process on their own. Purchasing commercial medical licensing examination materials available on the market for their reviews, unlike domestic trained or other IMGs still in medical schools and with plenty of help from professors prepare “dinners” ready for them. Yet, the social-economic structures have not been designed to support their returns to medicine to use their skill set and knowledge to help community at their levels of expertise. This is why I believe this group of doctors should be called a distinctive name as US-FMDs to be recognized. It can be grouped together no matter where they are native-born in the US or foreign-born-naturalized citizens because as an immigrant based country, there is no discrimination between a native-born versus a naturalized citizen.

Civilized versus uncivilized (jungle) freedom

These US-FMDs, the naturalized citizen groups, are of more challenging in the licensing process to compare with all groups of MDs. This is because they are literally on their own, do-it-yourself. They have the least information and least supportive circles. They do not come to the US with the main and foremost purpose of gaining medical doctor career for themselves like the international medical doctors as described below. However, medicine is like a religion at heart, they would of course want to return to practice medicine in the US one way or another. This is why they usually get behind the other groups of MDs; that is not their mistakes for their innocence, honesty and responsible to their new lives in the new country. They usually graduate from medical school at least over five years and especially have worked in their previous countries and the time line for preparing a permanent visas takes longer than visiting visas. Many of them takes over two to five to even ten years (in case of siblings sponsorship) to get permanent immigrant visas. Many of these USFMDs with permanent immigrant visas seek immigration for the purposes of pursuing personal freedom and liberty choices following their ancestor legacies in America. They actually respect American Constitution and their premier declarations of all men are created equal and have the rights to pursue freedom, liberty and happiness. This is exactly my own life saga and the purpose of my immigration to the United State fifteen years ago. In other words, they do not only think or do not put it as the priority that coming to the US to become a MD with privileges like the later groups I will describe more in details. American freedom is the kind of civilized freedom in comparison to the uncivilized (jungle) ones.

What is civilized freedom? To simplify the definition, an example is to get in line and wait for our turn to get the services since so many people who come before and after us also need the same service. That is the civilized behavior that human beings respect each other and not behave like animals to jump into the crowd using the salvaged rule of the stronger will always wins and rule the world, the jungle freedom, the rule of the forest!

These USFMDs are generally a more neutral and innocent group of MDs with less aggressive behaviors toward medical licensing. However, to put onto a scale of justice to measure for their endeavors, we should candidly admit that this group of US-FMDs is the best. They do everything by the DYI fashion (Do-It-Yourself) from trying to learn about the very intricate procedure of licensing, credentialing their medical school transcripts from their previous countries, purchased expensive commercial USMLE review materials and enroll into commercial USMLE review services to work on their own for sitting for their USMLEs and can pass those high-proficiency examinations. That prove their knowledges and talents never faint over the years struggling with adversities in the new country. However, they are the ones who are treated the worst. They are age and origins discriminated and are cut in front of their lines in the licensing process by the group of international medical graduates IMGs/ international medical doctors.

They are like the hidden diamond treasure that the American public has not been aware of for so long. They need to be polished to shine. This PhA-eAML project is trying to do exactly this mission! It is time we should restore justices for society and make a better life for all of us.

Why this has been for over six decades since the ECFMG established in 1956 USFMDs of this group have still been mistreated and still staying out of sight, unaware of by the American public? For the natures and characteristics of this groups, it must be the government to step in to help this group of USFMDs or they will continue to be mistreated and social unfair unjust indefinitely.

Understand the problem, I have initiated this project, working as a sole volunteer since 2010 when I passed the USMLE step 1 and working on my USMLE step 2 CK. Many other individual USFMDs also initiate their own campaigns. I have tried to do my part of contribution to bring justice and fairness to this group of USFMDs so they can return to practice medicine and help communities to relieve the problem of MD shortage. However, I have encountered much of deterrence and unconcern from many organizations, individuals that are either directly or indirectly involve in the process of licensing I have tried to reach out for help. One of them is the ECFMG. They ignore our hardship. They state that the ECFMG certificates, such a realistic and practical certificate for mid-level providers, are only use for one sole purpose is to apply into medical residencies. ECFMG certainly reports annually after each NRMP match day that more than half of these USFMDs do not get matched. Where have been these USFMDs going on with their lives? If we could find out, there must be a lot of heartbroken stories to tell. Please read the appendix of USFMDs stories.

Many individual USFMDs who have initiated or will initiate campaigns would get my supports. However, since this is such a heterogeneous group of people who come from all corners of the world and life so naturally they are very different in opinions. Although they are all oppressed and mistreated, still hard for them to become a very strong group to fight back with the injustice monopoly licensing system. This is why the government that represents the American people should realize a hidden treasure and free gifts for the American people and they should be used properly their expertise level of medical doctors. This has been for too long overdue since 1956. This is also why I believe it is my citizen duty to be one of the whistle-blowers to ring the bell and make the government realize the intricate issue and step in to help us.

Other USFMDs also tried to contact with ECFMG for help and was rejected. Many other doctors contacted ECFMG complaining they have invested a lot of all and everything for this certificate and now it is useless. ECFMG replied them that this is their own problems! Which means if a USFMD could not get matched; it is because they are incompetent to be admitted into the program! The problem of USFMDs mistreated terrible and real, thousands of them for over six decades have never be able to return to medicine! ECFMG makes the report annually and they know more than anyone else that annually over 50% of USFMDs do not get matched, called unmatched and have to go into SOAP (Supplemental Offer and Acceptance Program) which really does not help at all for getting any slot left after the main match.

It is rather wrong that ECFMG has stirred up a pessimistic, inferior complex, shamefulness on individual USFMDs who cannot get a residency slot in the national matching program NRMP annually. These mistreated USFMDs only go frustrated but would stay silent from speaking up the truth. ECFMG wants that these USFMDs believe they are rejected because of their own under-qualified status, not the faults of residency and licensing. ECFMG invented a program named ECHO, which stands for ECFMG Certificate Holder Office, the idea is to help those USFMDs/IMGs to improve better chances to get matched. However, the ECHO program actually does not help any USFMDs get a real position but wasting time to get online to listen to ECHO sponsored seminars and talks. This is only a superficial program that does not change the bad situations. ECHO said USFMDs must improve their profiles by doing volunteering and unpaid clinical work, resumes, personal statements, letters of recommendations, to try to get involved into prestigious organizations as memberships (e.g. the Alpha Omega Alpha, the Gold Humanism Honor Society), etc. Actually, these elements do not actually help the wrong system and even push USFMDs further into being exploited by wrongdoings. ECFMG know this. ECFMG avoid to admit of USFMDs are mistreated. Please read appendix my emails to Emanuel Cassimatis the CEO of ECFMG. The ECHO said USFMDs should not mention political issue even these closely attach to their life experiences that has made up the individual characters. On the other hands, ECFMG has been issued too many visas for non-immigrant visitor MDs from foreign countries and this has added into the disturbing immigration problem of America violating American Constitution of ripping off the rights of USFMDs as outsourcing jobs right at home!

ECFMG has ERAS-ECFMG supporting ERAS-AAMC. ERAS is short for Electronic Residency Application Services. AAMC is Association of American Medical College. ERAS-ECFMG helps applicants (USFMDs are call independent candidates) to upload their documents (letters of recommendations, medical school transcripts, USMLE score reports, etc.) onto the ERAS-AAMC. ERAS-AAMC lately was revealed wrongdoings by a group of USFMDs. It violates privacy as it automatically screens all applications without notices and no consents from the applicants. It screens for and withheld any applications that do not meet its own criteria from reaching the residency programs the applicant pay for applying! The criteria are year of graduation, year of birth, country of medical schools, and many other elements and if these applicants do not meet their hidden criteria. As an internal source leaked out of this serious problem, it proves no evidence. Their applications are automatically rejected without notice to programs or applicants since the applications never reach the programs! Even these applicants pay for each program with their steadily increasing fee annually! It is fraudulence!

Many USFMDs end up to live in homeless shelters and their families have to look for government helps to apply for food stamps and their kids are living in a very low standard of life. Other USFMDs who went to medical schools in the Caribbean still have big student loans that they cannot start to pay back and the banks have put liens on their properties that make them to claim bankrupted; their situations got even worse. They have a hard time to look for even simple labor jobs. There are a small percentage of domestic trained MDs, about five percent, also cannot get matched and fall into exactly the same situations since domestic trained MDs with much heavier student loans.

USFMDs are from different origins and cultures rendered it hard to unite in their opinion. But, they still deserve justice for their contribution and hard work, instead they have been mistreated.

Besides, there are external bad strategies to deter the progress of USFMD movements. I did inititiate my campaign on an online website. After a short while, I discovered this company website violates infringement, intellectual property law and terms of uses. I withdraw in silence. They asked me to access into my closed account to put their words for the reason why I closed my campaign. I refused since that was a malignant reaction to cause misunderstanding and confusion on me by readers since people would never know that was the reason by the company, not mine. I withdrew in peace and did not leave a bad reputation on their company. I let them think of their own bad policy to phish for intellectual property on their website users’ pains. It is indeed an immoral practice. I have found out some other USFMDs’ campaigns also did the same. I refuse to name those online websites for campaigns since many of them are prestigious ones that are popular to the public currently. I believe I behaved civilized and courteous against these website owners and company corporate greed. I wonder, maybe it is the capitalistic and self-serving culture that causes the bad situations for USFMDs as a small phenomenon inside the big panorama of social unjust and unfair causing by corporation greed.

I figure, for the natures and characteristics of this groups, it must be the government to step in to help this group of USFMDs or they will continue to be mistreated and social unfair unjust indefinitely. This has been over six decades and can be indefinite, who knows.

The other group of foreign-trained MDs is similar to the group that immigrates to the US with legal permanent visas. However, this group of MDs does not immigrate with legal permanent visas. They have the clear purpose to come to the US for personal medical doctor development purposes yet they promise to return to their countries upon finishing their residencies, yet they never do their promises. They are, on the other hand, very well-informed about licensing in the US, since they usually are still right in medical schools and are prepared all their didactic USMLE materials by their medical school professors. They tried to obtain any kinds of visas just for the purpose of entering the US. They get a lot of help from the current organizations (ECFMG, and many residency programs sponsor visas) that are directly involved in the medical licensing systems: ECFMG (The Educational Commission for Foreign Medical Graduates) usually offers those foreign MDs J1/H1 visas as called exchanged visitor visa program. The big profit for this program is that those applicants for exchange visas are all FREE for services; there is NO charges for their visa services while all other permanent visas are paid (which are the MDs with legal permanent visas have to pay all their expenses and all the fees when they apply for their permanent visas to immigrate to America. (Please see appendix about exchange visa program free of charge). These non-US-FMDs get even more benefits from cutting in front of the line USFMDs have been waiting for so long. It is estimated that the general funding for residency program to train one PGY1 and up is around 200,000 dollars per year. This funding comes from Medicare, which comes from tax-payers, US-FMDs are citizens who do their duties paying taxes and these residency programs give the jobs to foreigners. It is called outsourcing jobs right at home! (Please read appendix about the expenses for training MDs in medical residencies.)

This is one of the unfair treatments that cause unjust toward US citizen FMDs because the non-immigrant types

of visa MDs are more beneficial in many ways. They are often fresh graduates from medical schools from

foreign countries. The residency programs often love to get fresh graduates, and that is also age discrimination

against USFMDs. Besides ECFMG sponsors J1/H1 visas for those foreign MDs, residency programs also offer

to sponsor visas for foreign MDs who they like their applications while US citizen FMDs usually graduate from

medical schools longer since the time lost in their immigrant process. Those visiting visas MDs are fresh, and

they apparently know to take advantages on their own privileges to get in front of the line, which they should

indeed stand in line like US citizen FMDs. (Please see appendix: It is NOT OK to ruin our Democracy by greed

and wrongdoing!) This group should be called IMDs/IMG as international medical doctors or international

medical graduates to distinguish from USFMDs/USFMGs as US citizen foreign medical doctors or US citizen

foreign medical graduates as the two separate groups.

Extract from American Constitution:

AMENDMENT XIV

Passed by Congress June 13, 1866. Ratified July 9, 1868.

Note: Article I, section 2, of the Constitution was modified by section 2 of the 14th amendment.

Section 1.

All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they reside. No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws.

It is overdue the time we should start to protect our invisible borders for our healthy employment environment and domestic economy. This is also the protection of social security and moral code of communities. It is also a duplicate policy for foreign diplomacy that we do not have the bad reputation to take away foreign doctors from the people of foreign countries.

This is in a long run also to fight international healthcare disparity since it is apparently US medical doctors are not always be able to get a MD job at some foreign countries especially the countries that has the largest numbers of foreign MDs who come to the US with visiting visas (India is the leading country with visiting visa MDs to the US.) then these visiting visas MDs try to use politics to turn their illegal into legal status, cut the line. That is indeed a kind of fraud against moral code for being a MD, an honorable profession. (Please see appendix WHO MD supply shortages and more)

A typical and real anecdote as my own experience I would like to relate into this point to give more insightful about the ugly, inefficient, rather wasteful and unnecessary competition for getting a medical residency slot. I knew an Indian MD who has gone through exactly the pathway I explained above that she originally came to the US via visiting a guest visa. She got into a residency program in Fresno since she graduated 4 years earlier than me and has very good social and family support and consultant from her home India about the US licensing system so she knew clearly what to do when she came here. She now became US citizen from her visiting visa and currently practices family medicine in a suburban city of the Bay Area, taking over the practice from one of my friend physicians who passed away.

She kept protecting this residency system since she could get her license for practicing family medicine saying that the residency is good and all doctors even from foreign countries must go through it. I argued against her reasoning that the residency did the right thing:

“I hope you change your mind and think out of the box about the residency thing. You can see my resume; I have over 7 years practice in Saigon, Vietnam. But residency systems do not care; of course you said they are different! That is origin discrimination! Medicine is the sciences for human; the differences are not that big for a medical doctor from Vietnam become incompetent to America, or a doctor from India incompetent in America or vice versa. I just came back Saigon and I treated my father who has tuberculosis and COPD, the same knowledge! So you do not need to do false reasoning. You can see my resume with many years in Vietnam practice, yet when I came to the US, I also volunteer at many private practice and I have learned a great deal of clinical experiences. So you do not think I do not have clinical experiences in America as you said you help me to build clinical experiences. But, what you mean is only clinical experiences from Stanford is counted? That is really the false reasoning to protect the corporate greed. Indeed you have worked hard to keep their names, but the work is from you. Exactly the same as I volunteer at private practice and I have learned a lot, YES A LOT, but these physicians are not known as the BRAND NAME!? THAT IS REALLY A PHONY and ARROGANT LICENSING SYSTEM for an honest profession as medicine!

I just want to give you the important point that, my resume shows that I am absolutely competent as a very good physician, but I do not like Stanford brand-names, and so you think my resume is not competitive enough, that is PHONY AND UNJUST SYSTEM. VIOLATION HUMAN RIGHTS and AMERICAN CONSTITUTION! You have time to look at my resume or not, it is up to you, but it is here for you to have a look with my thick experiences in both medicine and life experiences and a very compassionate human being as a physician. You know, Dr. RS, I can see this corporation greed has been sabotaging our system; it is not only about this medical licensing. This is only a small portion of the panorama picture out there. You do not want to pay attention to the outside world, but I just want to give you a warning: the system is destroying our healthy environment. You surely know climate changes; California has been in the long drought for four years!

But, since I need to make it very clear to you who I am and how I can see the current licensing system has been damaging environment INVISIBLY and TRAMPLING on HUMAN RIGHTS! I really worry for the future generations! That is what I want to leave in your memory about me!”

In sumary:

MDs have three routes of their whereabouts: currently, a lot of misnomers have been using within the medical licensing system (this proves the system confusion and awkwardness): all the doctors who already earn their medical degree are only called medical graduates, only when they have their licenses then they will be called medical doctors. This is indeed a very wrong misnomer and concept and also a demeanor to our highly educated people.

My suggestion for correction follows my argument:

Licensing is purely the means to ensure licensed MDs to literally be safe to the public while they are on independent practice via the generalized and acceptable criteria of medical licensing procedure designed by the representatives of the American public, usually by state medical boards and federation of states medical boards.

Licensing does not actually a thorough means to be able to measure or to build up the depth of knowledge and the volume of medical education for individual MDs who have achieved and earned through their entire whole education period of at least ten years as to the American medical education system since they enter undergraduates then pre-med schools until they are handed their MD degree on graduation days. It is accurate to call all medical graduates as MDs at the time they graduate from medical schools. The same concepts apply for foreign medical doctors even their length of medical education is somehow shorter than the Americans. This is because those foreign medical schools have been seriously and meticulously scrutinized and evaluated their quality of medical education and training by the IMED (International Medical Education Directory soon will be changed into WMSD World Medical School Directory) and the NCFMEA (National Committee on Foreign Medical Education and Accreditation). Another supportive argument is, to look around into other educational systems, when law students get their degrees, they are called lawyers/attorneys; when PhDs earns their degrees they are also called doctors of their degrees, same as BS, BA, etc. This should equally apply for medical doctors.

This misnomer is not only found in America, but also in other countries. The misnomer does not justify itself for we adopt it from foreign countries or they adopt it from us. The accurate terminology is any and all medical graduates who have earned their MD degrees should be called medical doctors.

THERE ARE THREE DISTINTIVE GROUPS OF MDs IN THE UNITED STATES:

1- Domestic trained: US citizens or foreigners who graduate medical schools inside American soil

2- US-FMDs/US-FMGs: US citizens (native-born or naturalized) who graduate medical school outside American soil, immigrated with permanent legal immigrant visa, become US citizens by mainstream routes, not use political power. Trying to return to medicine, but are terribly oppressed since 1956.

3- IMDs/IMGs: non-US citizens who graduate medical school outside American soil and purposefully attempt to get medical doctor career in the United States via visiting visas. Getting residency slots over USFMDs, majorities do not return to their countries after residencies and try to turn their visiting status into citizens by politics. This group takes advantages on USFMDs by the help of ECFMG and residency programs.

Please do further reading below:

https://en.wikipedia.org/wiki/International_medical_graduate

International medical graduate

From Wikipedia, the free encyclopedia

An international medical graduate (IMG ), earlier known as a foreign medical graduate (FMG), is a physician who has graduated from a medical school outside of the country where he or she intends to practice. Generally, the medical school of graduation is one listed in the International Medical Education Directory (IMED) as accredited by the Foundation for Advancement of International Medical Education and Research or the World Health Organization.

Medical schools around the world vary in education standards, curricula, and evaluation methods. Reason why many countries have their own certification program, equivalent to the ECFMG in the United States. The purpose of ECFMG Certification is to assess the readiness of international medical graduates to enter clinical specialty training programs as resident physicians and fellowship programs in the United States.

Contents

o 1.2 Canada

o 1.3 United States

License requirements by country

The requirements to obtain a license to practice varies by country and often by state or province.

Australia

IMGs who wish to be licensed in Australia must apply to the Australian Medical Council (AMC) to arrange an appropriate assessment pathway.[1] The standard pathway involves an IMG sitting a series of assessments, including AMC MCQ Exam and AMC clinical exam.[2] AMC MCQ Exam consists of 150 MCQs organized through computer adaptive scoring.

For AMC clinical exam, a candidate is required to pass 12 out of 16 cases including one compulsory case in each of Gyne and pediatrics.

Those IMGs who have passed the necessary exams and obtained AMC certification can then apply to an Australian specialty training positions.[1][dead link]

Australia is in the process of establishing a national registration process for all the doctors under Medical Board of Australia.

In 2010 the Minister for Health and Ageing (Australia) launched an Inquiry process into registration and accreditation processes for international medical graduates which reported in 2012.[3]

Canada

Several organizations have put pressure on the government such as the Association For Access to Health Care Services, and Association of International Physicians and Surgeons of Ontario. Bill 97, Increasing Access to Qualified Health Professionals for Ontarians Act, was passed in 2008, requiring the College of Physicians and Surgeons to provide adequate numbers of doctors by issuing transitional licenses. However, the college has not complied with the law.

In addition to undergoing the regular licencing process as required of all Canadian medical school graduates, IMGs must pass the LMCC Evaluating Examination. IMGs in Canada also have a harder time getting into residency programs compared to Canadian graduates — only ten percent of IMG applicants get a position.[4]

Graduates of United States M.D. programs are not considered IMGs and are thus exempt from the Evaluating Examination; graduates of U.S. osteopathic medical schools are considered IMGs.[5]

United States

Graduates of Canadian M.D. programs are not considered IMGs in the United States.[6]

Pathway

The main pathway for IMGs who wish to be licensed as physicians in the United States is to complete a U.S. residency hospital program. The general method to apply for residency programs is through the National Resident Matching Program (abbreviated NRMP, also called “the Match”). To participate in the NRMP, an IMG is required to have an ECFMG certification[7] by the “rank order list certification deadline” time (usually in February of the year of the match).[8] To acquire an ECFMG certification, the main requirements are:[9]

In comparison, regular graduates from medical schools in the United States and Canada need to complete USMLE Steps 1 and 2 as well, but can participate in the NRMP while still doing their final year of medical school before acquiring their medical diplomas.[10] In effect, taking regular administrative delays into account, and with residency programs starting around July, there is a gap of at least half a year for IMGs between graduation from medical school and beginning of a residency program.

Those IMGs who have passed the necessary USMLE exams and obtained the ECFMG certification can then apply to U.S. residency positions via the NRMP and ERAS.

One study came to the result that almost half of IMGs were unsuccessful in their first attempts in the pursuit of a U.S. residency position, and three-quarters began a residency after five years.[11] It also indicated that IMGs were considerably older when they first applied for a residency position than are most U.S. medical graduates,

with mean age of IMGs when the ECFMG certificate was issued being 31.3 years, with a standard deviation of 5.6 years.[11]

All applicants to residency programs in California need a Postgraduate Training Authorization Letter (PTAL), colloquially called a “California Letter”.[12] Obtainment of a PTAL requires graduation from a medical school listed by the Medical Board of California, which is more stringent than the International Medical Education Directory.[13] It also requires a having a Social Security number.[14]

Origin by country

12

Country of medical schoolPercentage of IMGsTotal number (2007)

India

19.9%

47,581

Philippines

8.7%

20,861

Mexico

5.8%

13,929

Pakistan

4.8%

11,330

Dominican Republic

3.3%

7,892

Former USSR

2.5%

6,039

Grenada

2.4%

5,708

Egypt

2.2%

5,202

Korea

2.1%

4,982

Italy

2.1%

4,978

China

2.1%

4,834

Iran

2.0%

4,741

Spain

1.9%

4,570

Dominica

1.9%

4,501

Germany

1.9%

4,457

Syria

1.5%

3,676

Colombia

1.8%

3,335

Israel

1.4%

3,260

United Kingdom

1.4%

3,245

Montserrat

1.3%

3,111

Source: 2007 AMA Masterfile[15]

Quality of care

One study examining quality of care by international medical graduates is noted as follows. “One-quarter of practicing physicians in the United States are graduates of international medical schools. The quality of care provided by doctors educated abroad has been the subject of ongoing concern. Our analysis of 244,153 hospitalizations in Pennsylvania found that patients of doctors who graduated from international medical schools and were not U.S. citizens at the time they entered medical school had significantly lower mortality rates than patients cared for by doctors who graduated from U.S. medical schools or who were U.S. citizens and received their degrees abroad. The patient population consisted of those with congestive heart failure or acute myocardial infarction. We found no significant mortality difference when comparing all international medical graduates with all U.S. medical school graduates”..[16]

References

Senate Committee On Business,

Regulatory Request Questionnaire

Professions & Economic Development

Page 14

“IMG guides: Applying to the Australian Medical Council”. Australian Medical Council. 27 February 2012. Retrieved 7 June 2014.

“Assessments & examinations: Standard pathway”. Australian Medical Council. 27 February 2012. Retrieved 7 June 2014.

“Inquiry into Registration Processes and Support for Overseas Trained Doctors”. Parliament of Australia. Retrieved 2 June 2014.

readersdigest.ca – Why Is Canada Shutting Out Doctors?: “In 2003, 625 international graduates competed. Only 67—about ten percent—found a position”

“Evaluating Examination: Apply”. Medical Council of Canada. Retrieved 2010-04-16.

“Frequently Asked Questions: 1. What Is ECFMG Certification?”. 2010 ECFMG Information Booklet. Educational Commission for Foreign Medical Graduates. Retrieved 2010-04-16. Medical schools outside the United States and Canada vary in their educational standards and curricula. The purpose of ECFMG Certification is to assess whether graduates of these schools are ready to enter U.S. residency and fellowship programs that are accredited by the Accreditation Council for Graduate Medical Education (ACGME).

External links

Categories:

• Medical education in the United States

  • This page was last modified on 19 July 2015, at 00:41.

14

SENATE COMMITTEE ON BUSINESS PROFESSIONS

AND ECONOMIC DEVELOPMENT

REGULATORY REQUEST QUESTIONNAIRE

Section A: Applicant Group Identification

This section of the questionnaire is designed to help identify the group seeking regulation and to determine if the applicant group adequately represents the occupation.

6- Are all practitioner groups listed in response to question 2 represented in the organization seeking regulation? If not, why not?

Answers:

Friday August 21st  2015, responded by MILLER, KATHERINE T, USFMD

Yes, all and every practitioners in physician assistant and nurse practitioner groups have been strictly regulated by state of California medical board.

However, since this new title of Physician Associate PhA has not yet been established so there have not yet been any regulations enacted so far. Once the new legislation is enacted, the regulations would follow as a result for this new professional to start practicing in communities in primary care.

More details would be explained in the upcoming questions especially in Section C

Section B: Consumer Group Identification

This section of the questionnaire is designed to identify consumers who typically seek practitioner services and to identify nonapplicant groups with an interest in the proposed regulation.

Do practitioners typically deal with a specific consumer population? Are clients generally individuals or organizations? Document.

Senate Committee On Business,

Regulatory Request Questionnaire

Professions & Economic Development

 

Answers:

Friday August 21st 2015, responded by MILLER, KATHERINE T, USFMD

Generally, mid-level medical practitioners such as physician assistants or Nurse practitioners share similar pool of consumers as those of medical doctors. The consumers are indeed their patients and the communities they serve. These practitioners serve all without discrimination ages, sexes, races, languages and sub-cultures.

The new title of mid-level Physician Associates PhA also serve the same population; indeed the current population is outgrowing the number of current practitioners; this is one of the sharpest advocacy for this new mid-level title to be establish with licensing system.

More details would be explained in the upcoming questions

Please see the chart below for the estimation of the shortage of MDs by AAMC report 2013

SENATE COMMITTEE ON BUSINESS PROFESSIONS

AND ECONOMIC DEVELOPMENT

REGULATORY REQUEST QUESTIONNAIRE

Section B: Consumer Group Identification

This section of the questionnaire is designed to identify consumers who typically seek practitioner services and to identify non-applicant groups with an interest in the proposed regulation.

Identify any advocacy groups representing California consumers of this service. List also the name of applicable national advocacy groups.

Answers:

Friday August 21st 2015, responded by MILLER, KATHERINE T, USFMD

There has not yet any California or a national advocate group for this new title of mid – level professionals Physician Associate PhA. The only group is still a small group RRP on Face book.

More details would be explained in the upcoming questions

SENATE COMMITTEE ON BUSINESS PROFESSIONS

AND ECONOMIC DEVELOPMENT

REGULATORY REQUEST QUESTIONNAIRE

Section B: Consumer Group Identification

This section of the questionnaire is designed to identify consumers who typically seek practitioner services and to identify non-applicant groups with an interest in the proposed regulation.

Identify any consumer populations not now using practitioner services likely to do so if regulation is approved.

Answers:

Friday August 21st 2015, responded by MILLER, KATHERINE T, USFMD

Realistically, once this new title mid-level practitioner is put into work, any and all population would be benefit from this new supplement of healthcare provider enforcement. Anyone, any citizens and legal immigrants can use this new practitioner services exactly the same as any current practitioners in charge, e.g. medical doctors or Physician, physician assistants, and nurse practitioner.

The new professionals may gain better consumer markets for their diversities in cultures and languages and background, especially they will be more organized into programs of primary care for their purpose of training and employment combinations in the eAML ecosave Attainable Medical Licensing system. This will be very creative system.

We do not want to talk big into something still at its very early budding project; however, we are sure the prospect of this new career is very good in both short and long term plans.

More details would be explained in the upcoming questions

SENATE COMMITTEE ON BUSINESS PROFESSIONS

AND ECONOMIC DEVELOPMENT

REGULATORY REQUEST QUESTIONNAIRE

Section B: Consumer Group Identification

This section of the questionnaire is designed to identify consumers who typically seek practitioner services and to identify nonapplicant groups with an interest in the proposed regulation.

Does the applicant group include consumer advocate representation? If so, document. If not, why not?

Answers:

Friday August 21st 2015, responded by MILLER, KATHERINE T, USFMD

Yes, the applicant group also contains the consumer advocate representation since once it is established, the new organization for Physician Associate PhA would have different department to take care of smaller specialized issues; for such reason, a consumer advocate representative would be appointed accordingly. There is not yet any document available for this item.

More details would be explained in the upcoming questions

SENATE COMMITTEE ON BUSINESS PROFESSIONS

AND ECONOMIC DEVELOPMENT

REGULATORY REQUEST QUESTIONNAIRE

Section B: Consumer Group Identification

This section of the questionnaire is designed to identify consumers who typically seek practitioner services and to identify non-applicant groups with an interest in the proposed regulation.

Name any non-applicant groups opposed to or with an interest in the proposed regulation. If none, indicate efforts made to identify them.

Answers:

Friday August 21st 2015, responded by MILLER, KATHERINE T, USFMD

There has been non advocate group yet for this proposed regulation. There has been many individual US citizen-foreign-trained MDs attempted to establish an organization to advocate the rights of US-FMDs but failed. This phenomenon has been going on since 1950s. There is, however, a small group called RRP residency ready physician group on Facebook. This group is also trying to work on bringing USFMDs back to healthcare industry with many activities, but so far has not yet gained any significant rights.

More details would be explained in the upcoming questions especially chapter VIII of section C.

Part C1 – Sunrise Criteria and Questions

The following questions have been designed to allow presentation of data in support of application for regulation. Provide concise and accurate information in the form indicated in the Instructions portion of this questionnaire.

UNREGULATED PRACTICE OF THIS OCCUPATION WILL HARM OR ENDANGER THE PUBLIC HEALTH SAFETY AND WELFAR

 

Is there or has there been significant public demand for a regulatory standard? Document. If not, what is the basis for this application?

Answers:

Friday August 21st 2015, responded by MILLER, KATHERINE T, USFMD

No, there has not been significant public demand for a regulatory standard for this new title of mid-level practitioner, PhA Physician Associate. The reason is easy to understand. It is because the American public has not actually realized there is such a hidden resource of qualified medical doctors who are US citizens and green card holders able to take the task of medical doctors and even at a mid-level title.

The American people are not aware of those USFMDs existence or they only have a vague idea how these US-FMDs have evolved in their new homeland America for decades since 1950s. They assume all the doctors out there in the markets are from the same routes and are treated equally respectfully, fair and just; yet the truth is very discouraging and yet the American public do not know about this for a long time.

Although USFMDs are not from the same ground of domestic medical education locations, their qualifications as being at least high quality mid -level PhA physician associate is guaranteed of satisfied especially with the proper care from the government and associations that will be initiated accordingly.

USFMDs can be accurately as the raw diamond materials from underneath ore that need to be polished to be shined gloriously in the display guestroom at jewelry shops.

Please review the below information as the basis for this application:

Senate Committee On Business,

Regulatory Request Questionnaire

Professions & Economic Development

 

Petitioning Congress and President of the United States, Supreme Court, California State Capital office of the Governor and Senates:

  • Sanction for USFMDs with ECFMG certificate able to be hired LEGALLY by all employers, recruiters in healthcare industry with the title of mid-level provider PhA- Physician Associate.

Summary of petition:

Basically, medical licensing is about making sure that an independent practicing medical doctor does not at least do any harm to a patient before they can do any good. However, the current heavy requirement, abusing medical licensing has come into a crisis. That is the final step of licensing any medical doctor must have is residency (license is granted after finishing residency), yet the crisis of shortage of residency jobs due to poor management, exhausting funding, especially thousands of residency jobs have been outsourcing to foreign doctors who are neither US citizen nor green cards (OUTSOURCING JOBS RIGHT AT HOME!) This poor management, more frankly spoken, somehow a hidden greedy corruption has pushed thousands and thousands of US-citizen/green-card medical doctors (domestic trained MDs counts for 5% to 10%, and more than 50% US citizen foreign medical doctors) onto the margin of their lives with unemployed conditions, wasting all their training, skills, etc. Many of them have heavy student loans that go bankrupt and live in homeless shelters and food-stamps. Contradictorily, we are all the time crying out of shortage of medical doctors! Please help our doctors to get back to medical practice the same as helping yourself, your family, and your communities. We are the direct victims while you are the indirect victims if healthcare too high cost due to shortage of MDs, even not enough doctors to take care of communities. This petition is trying to bring justice back for the direct and indirect victims! This petition is trying to find a way shunting for this congestion and crisis. PLEASE SIGN THE PETITION!

That is the summary of the current crisis of licensing and residency; however, that does not explain all the details of the complicating problem we are trying to solve to its roots. If you really want to know more of the full panorama of this crisis, please read more details of the main letter I have tried to explain very detailed of what have been going on for decades since 1940s!

 

 

The main letter of petition:

Expansions of ACRONYMS in this letter:

  • USFMDs = United State foreign medical doctors, which mean US-citizen (green card, other permanent visa immigrant types that will eventually official green card holder) foreign medical doctors who graduate medical schools outside the US.

  • USFMGs = United Stated foreign medical graduates, graduates from medical schools outside the US.

  • IMGs = International Medical graduates: medical doctors/ graduates who are not US citizens or any of official permanent immigrants, they enter the US mainly on visiting visa or exchange visas

  • AMGs = American Medical Graduates, graduates from medical schools inside the US aka domestic trained medical graduates/ medical doctors – there are two pathways: allopathic and osteopathic.

  • USMLE = United State Medical Licensing Examination, hosted by FSMB www.usmle.org, those examinations are identical to the three steps examinations from NBME, but only different names to distinguish between USMLEs are examination for foreign trained MDs (USFMD, USFMG, IMG) while NBME are examinations for

  • ECFMG = the Educational Commission for Foreign Medical Graduates, www.ecfmg.org

  • ACGME = Accredited Council for graduate medical education, www.acgme.org

  • AAMC = American Association of Medical College, www.aamc.org

  • FSMB = Federal State Medical Board: hosting USMLE step 3, and all the process of MD licensing at federal level, and hosting maintenance license after certain period of practicing of licensed MDs

 

 

  • NBME = National Board of Medical Examination organization: this organization hosts the three-step examinations exactly identical to USMLEs, but only use this name for domestic trained MDs and Dos

  • ERAS = Electronic Residency Application System, belonged to AAMC and ECFMG

  • IMED= International Medical Education Directory https://imed.faimer.org (soon in 2015 changed into world directory of medical schools by World Federal of Medical Education www.wdme.org )

  • NCFMEA = National Committee on Foreign Medical Education and Accreditation

http://www.accredmed.org/ and http://www2.ed.gov/about/bdscomm/list/ncfmea.html

  • SOAP = Supplemental Offers and Acceptance Program (inside NRMP program)

  • EEOC = Equal Employment Opportunity Commission, www.eeoc.org

  • MD = Medical Doctor

  • DO = Doctor of Osteopathic

  • CME = Continuous Medical education

  • CCS = one of the 5 components in the USMLE series composed of 3 examinations and 5 components, CCS = clinical case simulation on computerized examinations

Annually, besides the residency application process, there are about a few thousands of USFMDs/USFMGs with ECFMG certificate enhancement apply for the USMLE step 3, the final step to be eligible for independent practice as primary care doctors. In this few thousands (ranging from 5,000 to 8,000 USFMDs), about a third (1/3) to a half (33.3% to 50%) do not pass the USMLE step 3. This does not, however, disqualify them for a mid-level career rather than wasting all their hard work on the ECFMG certificate they achieve. Besides, ECFMG, State Medical Boards of fifty states and Federal Medical Board have strict regulations especially restricted time frame and number of attempts for passing step 3 plus a lot of requirements, e.g. medical school credentials, US work, etc. around the expensive and

grueling licensing process; (it’s important to report that all foreign medical schools are on the IMED list approved their standards of medical education quality by WHO and the US medical board (federal/states) and NCFMEA, representing the American people so that USFMDs/USFMGs, who graduate from those schools are eligible to take the USMLEs and credentialing their personalized profiles of the foreign medical schools they graduated from). Passing a USMLE is never easy, especially for independent candidates, passing USMLE step 3 is much harder than other steps because the CCS is the trickiest part that people have no idea how they will be scored. This does not disqualify, again, for USFMDs to be able to work as a mid-level PhA, physician associate, under supervision of licensed MDs. If they fail step 3, and/or have trouble with the licensing process, they can still have an alternative pathway to go on for their lives settled down. Furthermore, this new PhA profession is a step-up to an alternative residency system to become licensed besides the present traditional one as I explain in more details of this project at the bottom of this letter. Additionally, this project is not restricted to USFMDs, domestic trained doctors from allopathic or osteopathic pathways as MD/DO can also use this pathway if they are in need of urgent help as a shelter for their progress.

I have been living in the US, California for 12 years. I have observed much of the problems about USFMDs who have been wasting their life-saving skills since the ECFMG established around the 1940s. There are thousands and thousands of them who have already proved their competency by passing all the hard US medical board examinations and credentialing their foreign medical school transcripts and medical school clinical work, and most of these FMDs had been working in their previous countries for years before immigrating to the US so they definitely bring their “chests of gold” with them to this immigrant-based country and the American people do not have to pay any penny for their foreign medical training. (Medicare funding and the giant student loan systems from tax payers subsidize a great deal for the present US medical education system, counting from day 1 a student in pre-med until they are released into practices as licensed MDs for no less than 8 to 10 years; this is why averagely, a US domestic medical student loan is no less than $200,000) while these USFMDs went to medical schools in their previous countries paid their own tuitions and expenses, worked to serve the people there for some time; their lives turned the corner as they immigrated to the US, again, on their own visas and expenses without any aid from the US medical licensing system and then continued the sagas struggling for the new lives in this country, becoming legal residents and citizens complying with citizenship responsibilities. Their stories sound solid! Upon completing all the requirements, they are granted the ECFMG certificates, but they complain that even after all that hard work and investment to get the ECFMG certificates, they cannot work just yet, but have to continue other high-mountains, residency,

Senate Committee On Business,

Regulatory Request Questionnaire

Professions & Economic Development

Page 7

board certification, recertification, CME, this, that, the other, and the other, etc. The list never ends! Furthermore, the current residency selection system has shown proofs of age and origin discrimination against those USFMDs; the massive roadblock, for which the deep-rooted chronic causes are built up multiple and intricate, is neither their mistakes to stop them from advancing further nor disqualifying their evident qualifications as medical professionals in the US. They deserve justice!

This is very much reflecting the “Supersize Me, America” culture! I have observed not only about professional opportunities so I can steer my wheels, but also general life. You know, there is nothing concept as retailed buyers can shop in bulk in Vietnam (where houses are smaller and less spaces, same as many other countries); there are no store brands like Costco, FoodMaxx, Wholesale Foods, and many kinds of wholesale for clothing, household and business utilities, goods, freights, etc. American people can buy in bulk with lower prices, in such a way of saving, that is the advantage; however, this deep-rooted concept controls the way people think; I see this culture reflects in everyday life, every fields e.g. communities, socio-economy, politics, businesses, etc. especially our healthcare industry is not an exception! “Supersize Me, America!” culture kills in other ways! Yes, it does! When people have fewer choices, fewer ways to go, they get stuck, that is when many pathological mechanisms happen! People go bankrupt; people become depressed, psychological problems, etc. Think about all those things that can fail social welfare, security/quality of life, community well-being, economy bursting, etc.

Our reverent Ex-President Abraham Lincoln’s famous quote: “America will never be destroyed from the outsides; if we falter and lose our freedom, it is because we destroy ourselves!”

This project I wish to do is to find a way to give a relief for this stress that is actually getting too much tense to explode, a way of protecting our freedom for professional development!

People get tired, different people may have different perspectives in their live goals and so easily become dejected if a very long and tiring process like our licensing process for MDs; that is very normal human nature; insulting words like “laziness”, “procrastination” without scrutinizing of the deep causes would only further traumatizing our own well-beings and putting negative drawbacks on people’s healthy development one way or another. If there is some kind of a “break” for their tough journeys that would be pretty much helpful while they are working tirelessly on their goals without necessarily compromising their life quality.

Senate Committee On Business,

Regulatory Request Questionnaire

Professions & Economic Development

Page 8

Also, it is wise to figure that traumatizing our doctors is not a smart way to make them give good quality of care to communities! It is realistic.

Besides, with the current high-cost healthcare industry and medical training expenses, we try to put USFMDs with ECFMG enhancement into PhA physician associate positions seems to be a good solution to bring the cost down somehow while those USFMDs still be able to work their skills and knowledge and experiences helping communities.

I only wish my little contribution to make a better life for the people and take care of community well-beings.

KATHERINE MILLER, USFMD, ECFMG Enhancement

The steps we need to achieve building this project:

PhA- eAML project- Physician Associate–Attainable Medical Licensing project

Logo for the project: (please see appendix for explanations of logo)

Senate Committee On Business,

Regulatory Request Questionnaire

Professions & Economic Development

Page 9

  • Sanction for USFMD with ECFMG certificate enhancement to be able to work LEGALLY and accepted by all employers, recruiters in healthcare industry with the new title as a mid-level provider PhA-Physician Associate, enact a new license for PhA Physician Associate once they complete all the USMLE step 1, step 2 CS, step 2 CK and step 2 CS and credentialing their official medical school transcripts from the foreign countries they graduate medical schools from.

  • Implementing transparency procedures into USMLEs, e.g. test-takers can request to compare their examination performances with the answers and explanations of their real examination delivered on examination dates. This is a democracy promotion.

  • Re-evaluation, reconsideration most essential and/or overlapping of USMLE step 2 CK and USMLE step 3 that contain two separate examinations. This would reduce expenses, time, and energy for both test-takers and personnel’s at USMLE/ FSMB as well as NBME organizations. All the MDs who pass the exams and working as PhAs would attend serious and quality CMEs as the essential activities to enhance their knowledge and skills all the times so those USMLEs should not exaggerate their standings in the licensing systems.

  • Create programs at work to help PhAs complying with specific working protocols of diagnoses, treatments, patient education, and clinical with or without managerial activities under MDs’ supervision at their workplaces aimed towards primary care besides other subspecialties. By reaching this, creating bids among different medical facilities without restrictions of sizes and types (can be teaching or nonteaching, hospitals, clinics, even private MD offices), any MDs who have good will/good wish to take part in employment and education for PhAs, they are free to participate with their specific proposals comporting to guidelines from state medical board/ federal medical boards with professional inputs, the bids will come to a number of PhAs who will be filled into those facilities.

The philosophy is teaching is not all about knowledge; the enthusiastic hearts of the educators play an important role. Furthermore, according to reliable resources, some scientific studies validate that teaching

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itself is an effective method of learning and reinforcement. So we should spread out this great scientific-proof method of teaching and learning and nurturing our educational system, especially medical education rather than enclosed it inside the boundaries of the present facilities. Besides, AAMC reported lately that the US has about 400 teaching facilities and about 128,000 attending physicians nationally. These numbers do not seem to fit proportionately with American population of 318,292,000 as of June 2014 census! It seems the present GME (graduate medical education) system is too overloaded; particularly, the primary care section is in deep shortage. Lately, President Obama planned to increase the number of residency slots as an emergency aid for the residency selection crisis, but this would not solve the long-term problem. I believe all current practicing licensed MDs have at least some capability to teach; it does not matter where they practice, as long as they have the enthusiastic spirit plus clinical experiences, they can participate in the bids with their approved qualified proposals, they can take some numbers of PhAs from the pool, the same methods for hospitals, clinics, facilities, recruiter companies that have specialist consultants. To solve this intricate, multifaceted and chronic conundrum, we need to build a more sophisticated large-scaled designed system.

  • For USFMDs/AMGs/MD/DO unable to get residency training slots in the traditional pathway, if they agree to commit working as PhAs for three to four years and want to continue to become licensed and have passed the USMLE step 3, they only need this new pathway of ONE-YEAR program, which will be designed accordingly, to become licensed while other PhAs who do not want to continue and/or who do not pass USMLE step 3 can still work at the mid-level position PhAs with CME programs supportively for their works.

  • Stop issue visas for foreign medical doctors as specifically for medical residency training visa; this is one of the top professional jobs and should be preserved for US citizens/ green-cards before the guests. Embark a moratorium on current residency programs that sponsor non-immigrant visas and interns and residents who are not on immigrant visas, not US citizens and green card holders. This is against the Constitution to take away American jobs from American citizens’ right on American soil. The investment to train each interns and residents in a residency program is estimated around 200 grand dollars ($200,000) per year, and the major fund for this financial supply is from Medicare and Medicaid, which are from public and national resources from tax payers. This wrongdoing about sponsoring visas and outsourcing jobs right at home is apparently both morally and economically damaged to American public social security and well beings and USFMDs. (Please see appendix for the article about this) http://www.healthaffairs.org/healthpolicybriefs/brief.php?brief_id=73

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  • Sanction for EEOC eligible to investigate and enforce ACGME, ECFMG, federal medical board, state medical boards to support this project to bring USFMDs back to healthcare industry. LEAVE NO USFMDs BEHIND! Currently, EEOC does not have jurisdiction to investigate ACGME. This is unfair and unjust policy!

  • Make a connection with the immigration department to approach new medical doctors who immigrate to the US legally on other types of visas (NOT J1/H1 for medical residency training) to orient their medical careers in America once they become legal resident moving toward US citizens, if they are willing to return to medicine.

Activities from RRP group: Leader of the group: Doctor Neviana Dimova

Petitioning Representative Grace Meng and 6 others

Do not outsource American jobs when Americans qualify for them

https://www.change.org/p/robert-m-wah-md-do-not-outsource-american-jobs-when-americans-qualify-for-them

Neviana Dimova Louisville, KYCreate similar to Senate Bill 716 MO for every state without limitation on graduation date and time since passing USMLE exams. Increase the number of GME Residency Slots for US Citizen & Resident IMGs (International Medical Graduates). http://www.senate.mo.gov/14info/pdf-bill/tat/SB716.pdf

Implement a version of the Canadian model (Manitoba) for individual assessment of the clinical, diagnostic and management skills of physicians that have already trained in residency programs or practiced outside of the USA, and if adequate, prepare IMGs to work under supervision or directly in underserved areas (under sponsors). These physicians could be granted year limited restricted license (sponsored by an institution or practicing physician). That license could be extended on an annual basis as needed. After 5 years practicing under such circumstances the physician in question should be evaluated for eligibility to apply for a full unrestricted state license for the scope of practice that he has been engaged in, considering he has fully satisfied his examination requirements of passing USMLE Step 1, 2 and 3

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http://umanitoba.ca/faculties/medicine/education/imgp/index.html, https://www.cpsnl.ca/default.asp?com=Pages&id=117&m=319 http://www.health.gov.on.ca/english/providers/project/img/img_mn.html, http://www.cehpea.ca/

Place a moratorium on all J1 visas for residency training for 3 years (or use a mandatory tier system: I. US medical students II. US and permanent residents who are international medical graduates (IMGs) II. IMGs, non-us citizens, unless governments of their countries of origin are sponsoring their visas and paying for their tuition and living expenses during residency. For example: http://www.sacm.org/MedicalUnit/PDF/Acceptance2013.PDF http://www.sacm.org/MedicalUnit/PDF/Acceptance2014.PDF Studying the international experience of countries like Spain, Canada, Great Britain in the matter of preferentially matching candidates who are citizens of the country in question http://www.curso-mir.com/Informacion-para-medicos-extranjeros/movimientos-migratorios.html; http://www.carms.ca/en/residency/r-1/eligibility-criteria/ , http://www.foundationprogramme.nhs.uk/pages/home/how-to-apply/FP2015-Eligibility-Information.

  1. Provide targeted training for IMGs who have graduated their respective schools outside USA but have not entered or completed residency training, following the example of California Business code 855: http://law.onecle.com/california/business/855.html These pilot programs could provide adequate training to prepare these doctors to serve as primary care physicians under the supervision of a fully licensed doctor in underserved areas.

As it stands now: The State Department regulations 22 CFR 62.22(f)(2)(v) require that approved

J-1 trainee or intern visa sponsors do not “displace” US workers or “fill a labor need.”

Sponsoring training hospitals routinely issue a Form DS-2019 to the alien physician.

62.22(b)(1)(ii) Exchange Visitor Program training and internship programs must not be used as substitutes for ordinary employment or work purposes; nor may they be used under any circumstances to displace American workers. The requirements in these regulations for trainees are designed to distinguish between bona fide training, which is permitted, and merely gaining additional work experience, which is not permitted. The requirements in these regulations for interns are designed to distinguish between a period of work-based learning in the intern’s academic field, which is permitted (and which requires a substantial academic framework in the participant’s field), and unskilled labor, which is not.

I am a US Citizen myself and a fully trained physician from Bulgaria. I myself and the members of my organization, Residency Ready Physicians are ECFMG certified and completed all required licensing exams, but cannot practice in the US because we cannot complete a required residency. There are thousands of us, International Medical Graduates (IMG’s), living in the great country, who want to help people and alleviate the physician shortage, but two things keep us out of the system: not enough residencies and thousands of visiting residents on J1 and H1B visas taking these taxpayer funded positions. No matter how much education we have, we cannot practice without this last step. These Medicare funded position are given to thousands of doctors from abroad who have not paid taxes in the US or have any commitment to this country, while thousands of US citizens and permanent residents are left wasting their education and talents.

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In 2014, 3613 of the 26,678 available residency positions went to NON US International Medical graduates while 975 American graduates (each with approximately 200,000 dollars in student loans) and 4882 International Medical Graduates who are US Citizens and permanent residents who have passed the required licensing exams and who applied, were unable to find a position. Additionally 611 DO (Doctor of Osteopathy) US citizens did not match. At the same time 6,335 IMGs non-US citizens matched. This is a significant number representing 24.7 percent of all NRMP matches and 22.9 percent of all NRMP and AOA year matches combined and well above the percent of foreign-educated individuals in most other health professions, like nursing and pharmacy, which runs generally in the 5 to 10 percent range.

The above numbers by the way only count the IMGs that applied to the match. It costs an IMG about $1500 or more to apply so most only try two or three times before giving up. That is after taking the required exams, which cost about $800 for each step (there are 3 steps). We do not get student loans for these expenses.

The cost of physician shortage is a major problem. Not enough doctors means that hospitals and practices must compete for those available, offering higher pay and benefits. My organization, Residency Ready Physicians, has several recommendations for using the estimated 6000 International Medical Graduates who are currently underemployed. IMGs mainly from India and Pakistan make the major numbers of J1 visa applicants for medical residency. While they are supposed to go back to their home countries after their training, they actually never do and find ways to immigrate to USA because of the better pay compared to their countries of origin. Therefore is also unethical to admit doctors on J1 visas and “close our eyes” knowing that majority of them will never go back and drain the medical taskforce of their countries of origin. In addition (see papers attached) the numbers of J1 visas issued closely approximates the numbers of US IMGs applying for residency but being unmatched.

So far I have been personally lucky not to have to go into too much debt, taking student loans for my medical education. However we have many members who are Caribbean or American Medical graduates with an average of $200,000 in student loans. Unfortunately, as they are denied residency positions and subsequently medical license several of our members after years of applying to the residency Match and not being matched have defaulted on their student loans and went into bankruptcy and their families are currently living on “food stamps”.

We do not want special treatment, but just the opportunity to join the system and help those most in need. I would willingly serve in the poorest Appalachian town, the inner-city, or wherever my talents are needed. I trained all my life to serve as a doctor, to heal. All I am asking; all our group is asking for, is for the opportunity to serve. Please consider our requests.

Sincerely

Neviana Dimova

Letter to

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Representative Grace Meng

Representative Thomas Emmer

mediarelations@jama-archives.org

and 4 others

AMA president Steven.Stack@ama-assn.org

President Barack Obama

Senator Bernie Sanders

Sylvia Burwell

I just signed the following petition addressed to: Congress.

—————-

Do not outsource American jobs when Americans qualify for them

Read more

Updates

1. 3 months ago

Petition update

Gofundme update

Congratulations to all supporters. In 6 days we received $113 in donations for the creations and lobbying of our own organization to protect and work for the rights of US IMGs and AMGs to get residency…

3 months ago

Petition update

Gofund me account created for funding of our own non-profit organization.

Money will be used for lobbing, advertising and perhaps going to Washington DC. Link:

http://www.gofundme.com/u7aefs

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2.

gofundme.com

5 months ago

Petition update

“Private” information…

Dear supporters, just wanted to drop a note and let you know that certain people seems to have complained against exposing “private” information in the petition and there are links that have been…

6 months ago

Petition update

Congratulations to all supporters reaching 1000 votes goal just before the Match

Updated the petition what exactly we want to be done: 1. Create similar to Senate Bill 716 MO for every state without limitation on graduation date and time since passing USMLE exams. Increase the number of…

7 months ago

1,000 supporters

3 years ago

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Neviana Dimova started this petition

SENATE COMMITTEE ON BUSINESS PROFESSIONS

AND ECONOMIC DEVELOPMENT

REGULATORY REQUEST QUESTIONNAIRE

Section C: Sunrise Criteria

This part of the questionnaire is intended to provide a uniform method for obtaining information regarding the merits of a request for governmental regulation of an occupation. The information you provide will be used to rate arguments in favor of imposing new regulations (such as educational standards, experience requirements, or examinations) to assure occupational competence.

Part C1 – Sunrise Criteria and Questions

The following questions have been designed to allow presentation of data in support of application for regulation. Provide concise and accurate information in the form indicated in the Instructions portion of this questionnaire.

UNREGULATED PRACTICE OF THIS OCCUPATION WILL HARM OR ENDANGER THE PUBLIC HEALTH SAFETY AND WELFARE

What is the nature and severity of the harm? Document the physical, social, intellectual, financial or other consequences to the consumer resulting from incompetent practice.

Thursday August 27th 2015, responded by MILLER, KATHERINE T, USFMD

Since this new proposals have not yet implemented into the public consumerism, there has not yet been established any of harm in any ways of nature and severity.

However, it is predictable to extrapolate the nature of the possible harm incurred by this new practitioner PhAs of this proposal will be similar to yet less in quantity than any of the current professional practitioners: licensed MDs, PAs and NPs for the natures of the project for PhAs is to minimize harms from occuring. One of the construction to build this project for PhAs to be able to practice with low incidence of harm occurring is that there will be a strict and extensive supervising and supportive network system for PhAs to work on and constantly communicating with this control center to get feedbacks.

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One other reason may reduce harms for PhA practice is that this new practitioners will work in a much more organized programs with much more focuses and the project is designed in the fashion that PhAs would be much better connections with patients in every way: better communication in conversations, their behaviors in practices, their attitudes toward expectation and duties in their careers since they are actually MD level of medical education and willing to work as a mid -level career; their messages are clear with a dedication and devotion attitude more than seeking privileges. With better transparency pictures, healthcare costs reduce together with quality improvement. Also, this new career promises many better changes: e.g. shortage of primary care MDs since PhAs focus on primary care, family practice, healthcare accessible for minority ethnic groups especially disparity communities that are in language and culture differences would be mitigated.

Current practitioners with the current issues:

Please see the appendices of 2015 review of medical malpractice for MDs and the one for PAs, NPs.

MD medical malpractice paid for any kinds of harms incurred:

Quotes:

https://www.trustedchoice.com/professional-liability-insurance/medical-malpractice/

Medical Malpractice Facts

  • Anywhere from 44,000 to 98,000 people die each year due to a preventable medical error.

  • Medical errors that occur in hospitals cost between $17 billion and $29 billion annually.

  • In 2000, $6.4 billion was spent on medical malpractice insurance.

  • 1 in 8 preventable medical errors results in a medical malpractice claim.

  • Damages are rarely awarded in medical malpractice claims.

  • Medical malpractice insurance costs physician’s 3.2% of their revenue.

  • 5% of doctors carry 54% of all medical malpractice claims.

The cost of medical malpractice insurance varies depending on your practice and where it’s located, in addition to several other factors. A heart surgeon runs a greater risk of a malpractice versus an RN responsible for taking blood. One area that tends to have a high rate of litigation is obstetrics, but today no areas of specialty are immune to lawsuits.

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Costs tend to vary among states. For example, malpractice costs in Minnesota could cost anywhere from $4,000 to $17,000 per year, depending on your specialty. But in California, a surgeon can expect to pay anywhere from $22,000 to $34,000 per year.

PA/NP medical malpractice:

http://expertpages.com/news/Physician_Assistant_Malpractice_History.htm

Malpractice Amount

PA average and median payments were less than that of physicians and APNs. The average and median APN payments were the highest at $350,540 and $190,898. The average and median physician payments were $301,150 and $150,821 while the average and median PA payments were $173,128 and $80,003. The physician adjusted mean payment was 1.74 times higher than PAs but only 0.86 that of APNs. The physician adjusted median payments were 1.89 times that of PAs but only 0.79 that of APNs. It is speculated that APN mean and median payments are higher than that of physicians and PAs because the proportion of APNs who work in the high risk specialties of anesthesia and obstetrics is higher. The proportion of malpractice payments for nurse anesthetists (47%) and nurse midwives (25%) was 72% of total APN payments.

Malpractice Incidence Rate

The rate of malpractice incidence is increasing for PAs and APNs but flat for physicians. This has been attributed to the major increase in number of PA and APN providers but relatively minor (14%) increase in physician workforce between 1991 and 2007. The rate of increased incidence was not greater than the increase in provider workforce.

Amount of Malpractice Payment

In adjusted 2008 dollars, average physician payments were 1.74 times higher than PA payments, and median payments were 1.89 times higher.

Reasons for Disciplinary Action

The most common reason for disciplinary action by state and federal monitoring bodies was the same for all three provider types. The most common disciplinary action was a licensing action by licensing authorities and the most common reasons for the licensing action were for unethical conduct and alcohol/substance abuse.

Reasons for Malpractice Claim

The most common reasons for APN malpractice claims were for obstetric and anesthesia errors. This is due to the disproportionate number of APNs who practice in these specialties compared to physicians and PAs. If these are excluded, the top ranking reasons for malpractice payments were the same for PAs and APNs: in order they are errors in diagnosis, treatment, medication

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and surgery. For physicians they were in order errors in diagnosis, surgery, treatment, obstetrics and medication.

Gender Differences

The study found that female health care providers make larger malpractice payments on average than their male counterparts and that female provides are slightly more likely to be successfully sued. It also suggested that more women than men bring about malpractice claims, but this could be a factor of more women than men receiving health care.

Differences in State Actions

States with the most adverse actions against physicians were not necessarily those with the most malpractice payments. Pennsylvania and New York, while ranking high in malpractice incidence, were found to have adverse action ratios that were three times lower than the average. That is, while states on average had about one adverse action for every 4.4 malpractice payments, these states had about one in thirteen. This could be an indication of their ineffectiveness at sanctioning unsafe providers.

4

SENATE COMMITTEE ON BUSINESS PROFESSIONS

AND ECONOMIC DEVELOPMENT

REGULATORY REQUEST QUESTIONNAIRE

Section C: Sunrise Criteria

This part of the questionnaire is intended to provide a uniform method for obtaining information regarding the merits of a request for governmental regulation of an occupation. The information you provide will be used to rate arguments in favor of imposing new regulations (such as educational standards, experience requirements, or examinations) to assure occupational competence.

Part C1 – Sunrise Criteria and Questions

The following questions have been designed to allow presentation of data in support of application for regulation. Provide concise and accurate information in the form indicated in the Instructions portion of this questionnaire.

UNREGULATED PRACTICE OF THIS OCCUPATION WILL HARM OR ENDANGER THE PUBLIC HEALTH SAFETY AND WELFARE

 

How likely is it that harm will occur? Cite cases or instances of consumer injury. If none, how is harm currently avoided?

Answers:

Thursday August 27th 2015, responded by MILLER, KATHERINE T, USFMD

Since this new proposals have not yet implemented into the public consumerism, there has not yet been established any of harm in any way of the nature and severity.

(Please read question # 13 for more information)

SENATE COMMITTEE ON BUSINESS PROFESSIONS

AND ECONOMIC DEVELOPMENT

REGULATORY REQUEST QUESTIONNAIRE

Section C: Sunrise Criteria

This part of the questionnaire is intended to provide a uniform method for obtaining information regarding the merits of a request for governmental regulation of an occupation. The information you provide will be used to rate arguments in favor of imposing new regulations (such as educational standards, experience requirements, or examinations) to assure occupational competence.

Part C1 – Sunrise Criteria and Questions

The following questions have been designed to allow presentation of data in support of application for regulation. Provide concise and accurate information in the form indicated in the Instructions portion of this questionnaire.

UNREGULATED PRACTICE OF THIS OCCUPATION WILL HARM OR ENDANGER THE PUBLIC HEALTH SAFETY AND WELFARE

15. What provisions of the proposed regulation would preclude consumer injury?

Answers:

Friday August 21st 2015, responded by MILLER, KATHERINE T, USFMD

We live in an imperfect world. It is both subjectively and objectively imperfect, unwittingly. So when we try to build a new establishment, even we have brainstormed and brain-drained to our utmost perfectionism, there would still be wise to leave an acceptable corridor of low percentage of exceptions and errors (ideally less than 10%).

The new medical practice trend is about quantification of quality by measurements conducted by quality measure task force. The new proposal would adopt it. There would be appointed a quality measure task force for the new practitioner to support them able to do their jobs independently under limited supervisions yet still strictly adhere to quality control and non-stop improve quality of care; patient-center care as the kernel of the proposals.

However, to say, the propose regulation would preclude consumer injury, we would like to clarify that, yes, we strive our best to put public welfare, security and safety to the

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foremost priority, yet we cannot one hundred percent (100%) guarantee the preclusion of all and any injury since the proposals are still under provision and need to implement as a testing mode that would still need regulations and modifications to comport to the reality of our imperfect conditions. Even once it is well established into consumerism, it still continues to self-improvement to all the changes and adaptability to guarantee its stands in the public welfare.

 

Part C1 – Sunrise Criteria and Questions

The following questions have been designed to allow presentation of data in support of application for regulation. Provide concise and accurate information in the form indicated in the Instructions portion of this questionnaire.

UNREGULATED PRACTICE OF THIS OCCUPATION WILL HARM OR ENDANGER THE PUBLIC HEALTH SAFETY AND WELFARE

Is there or has there been significant public demand for a regulatory standard? Document. If not, what is the basis for this application?

Answers:

Friday August 21st 2015, responded by MILLER, KATHERINE T, USFMD

No, there has not been significant public demand for a regulatory standard for this new title of mid-level practitioner, PhA Physician Associate. The reason is easy to understand. It is because the American public has not actually realized there is such a hidden resource of qualified medical doctors who are US citizens and green card holders able to take the task of medical doctors and even at a mid-level title.

The American people are not aware of those USFMDs existence or they only have a vague idea how these US-FMDs have evolved in their new homeland America for decades since 1950s. They assume all the doctors out there in the markets are from the same routes and are treated equally respectfully, fair and just; yet the truth is very discouraging and yet the American public do not know about this for a long time.

Although USFMDs are not from the same ground of domestic medical education locations, their qualifications as being at least high quality mid -level PhA physician associate is guaranteed of satisfied especially with the proper care from the government and associations that will be initiated accordingly.

USFMDs can be accurately as the raw diamond materials from underneath ore that need to be polished to be shined gloriously in the display guestroom at jewelry shops.

Please review the below information as the basis for this application:

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Petitioning Congress and President of the United States, Supreme Court, California State Capital office of the Governor and Senates:

  • Sanction for USFMDs with ECFMG certificate able to be hired LEGALLY by all employers, recruiters in healthcare industry with the title of mid-level provider PhA- Physician Associate.

Summary of petition:

Basically, medical licensing is about making sure that an independent practicing medical doctor does not at least do any harm to a patient before they can do any good. However, the current heavy requirement, abusing medical licensing has come into a crisis. That is the final step of licensing any medical doctor must have is residency (license is granted after finishing residency), yet the crisis of shortage of residency jobs due to poor management, exhausting funding, especially thousands of residency jobs have been outsourcing to foreign doctors who are neither US citizen nor green cards (OUTSOURCING JOBS RIGHT AT HOME!) This poor management, more frankly spoken, somehow a hidden greedy corruption has pushed thousands and thousands of US-citizen/green-card medical doctors (domestic trained MDs counts for 5% to 10%, and more than 50% US citizen foreign medical doctors) onto the margin of their lives with unemployed conditions, wasting all their training, skills, etc. Many of them have heavy student loans that go bankrupt and live in homeless shelters and food-stamps. Contradictorily, we are all the time crying out of shortage of medical doctors! Please help our doctors to get back to medical practice the same as helping yourself, your family, and your communities. We are the direct victims while you are the indirect victims if healthcare too high cost due to shortage of MDs, even not enough doctors to take care of communities. This petition is trying to bring justice back for the direct and indirect victims! This petition is trying to find a way shunting for this congestion and crisis. PLEASE SIGN THE PETITION!

That is the summary of the current crisis of licensing and residency; however, that does not explain all the details of the complicating problem we are trying to solve to its roots. If you really want to know more of the full panorama of this crisis, please read more details of the main letter I have tried to explain very detailed of what have been going on for decades since 1940s!

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The main letter of petition:

Expansions of ACRONYMS in this letter:

  • USFMDs = United State foreign medical doctors, which mean US-citizen (green card, other permanent visa immigrant types that will eventually official green card holder) foreign medical doctors who graduate medical schools outside the US.

  • USFMGs = United Stated foreign medical graduates, graduates from medical schools outside the US.

  • IMGs = International Medical graduates: medical doctors/ graduates who are not US citizens or any of official permanent immigrants, they enter the US mainly on visiting visa or exchange visas

  • AMGs = American Medical Graduates, graduates from medical schools inside the US aka domestic trained medical graduates/ medical doctors – there are two pathways: allopathic and osteopathic.

  • USMLE = United State Medical Licensing Examination, hosted by FSMB www.usmle.org, those examinations are identical to the three steps examinations from NBME, but only different names to distinguish between USMLEs are examination for foreign trained MDs (USFMD, USFMG, IMG) while NBME are examinations for

  • ECFMG = the Educational Commission for Foreign Medical Graduates, www.ecfmg.org

  • ACGME = Accredited Council for graduate medical education, www.acgme.org

  • AAMC = American Association of Medical College, www.aamc.org

  • FSMB = Federal State Medical Board: hosting USMLE step 3, and all the process of MD licensing at federal level, and hosting maintenance license after certain period of practicing of licensed MDs

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  • NBME = National Board of Medical Examination organization: this organization hosts the three-step examinations exactly identical to USMLEs, but only use this name for domestic trained MDs and Dos

  • ERAS = Electronic Residency Application System, belonged to AAMC and ECFMG

  • IMED= International Medical Education Directory https://imed.faimer.org (soon in 2015 changed into world directory of medical schools by World Federal of Medical Education www.wdme.org )

  • NCFMEA = National Committee on Foreign Medical Education and Accreditation

http://www.accredmed.org/ and http://www2.ed.gov/about/bdscomm/list/ncfmea.html

  • SOAP = Supplemental Offers and Acceptance Program (inside NRMP program)

  • EEOC = Equal Employment Opportunity Commission, www.eeoc.org

  • MD = Medical Doctor

  • DO = Doctor of Osteopathic

  • CME = Continuous Medical education

  • CCS = one of the 5 components in the USMLE series composed of 3 examinations and 5 components, CCS = clinical case simulation on computerized examinations

Annually, besides the residency application process, there are about a few thousands of USFMDs/USFMGs with ECFMG certificate enhancement apply for the USMLE step 3, the final step to be eligible for independent practice as primary care doctors. In this few thousands (ranging from 5,000 to 8,000 USFMDs), about a third (1/3) to a half (33.3% to 50%) do not pass the USMLE step 3. This does not, however, disqualify them for a mid-level career rather than wasting all their hard work on the ECFMG certificate they achieve. Besides, ECFMG, State Medical Boards of fifty states and Federal Medical Board have strict regulations especially restricted time frame and number of attempts for passing step 3 plus a lot of requirements, e.g. medical school credentials, US work, etc. around the expensive and

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grueling licensing process; (it’s important to report that all foreign medical schools are on the IMED list approved their standards of medical education quality by WHO and the US medical board (federal/states) and NCFMEA, representing the American people so that USFMDs/USFMGs, who graduate from those schools are eligible to take the USMLEs and credentialing their personalized profiles of the foreign medical schools they graduated from). Passing a USMLE is never easy, especially for independent candidates, passing USMLE step 3 is much harder than other steps because the CCS is the trickiest part that people have no idea how they will be scored. This does not disqualify, again, for USFMDs to be able to work as a mid-level PhA, physician associate, under supervision of licensed MDs. If they fail step 3, and/or have trouble with the licensing process, they can still have an alternative pathway to go on for their lives settled down. Furthermore, this new PhA profession is a step-up to an alternative residency system to become licensed besides the present traditional one as I explain in more details of this project at the bottom of this letter. Additionally, this project is not restricted to USFMDs, domestic trained doctors from allopathic or osteopathic pathways as MD/DO can also use this pathway if they are in need of urgent help as a shelter for their progress.

I have been living in the US, California for 12 years. I have observed much of the problems about USFMDs who have been wasting their life-saving skills since the ECFMG established around the 1940s. There are thousands and thousands of them who have already proved their competency by passing all the hard US medical board examinations and credentialing their foreign medical school transcripts and medical school clinical work, and most of these FMDs had been working in their previous countries for years before immigrating to the US so they definitely bring their “chests of gold” with them to this immigrant-based country and the American people do not have to pay any penny for their foreign medical training. (Medicare funding and the giant student loan systems from tax payers subsidize a great deal for the present US medical education system, counting from day 1 a student in pre-med until they are released into practices as licensed MDs for no less than 8 to 10 years; this is why averagely, a US domestic medical student loan is no less than $200,000) while these USFMDs went to medical schools in their previous countries paid their own tuitions and expenses, worked to serve the people there for some time; their lives turned the corner as they immigrated to the US, again, on their own visas and expenses without any aid from the US medical licensing system and then continued the sagas struggling for the new lives in this country, becoming legal residents and citizens complying with citizenship responsibilities. Their stories sound solid! Upon completing all the requirements, they are granted the ECFMG certificates, but they complain that even after all that hard work and investment to get the ECFMG certificates, they cannot work just yet, but have to continue other high-mountains, residency,

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board certification, recertification, CME, this, that, the other, and the other, etc. The list never ends! Furthermore, the current residency selection system has shown proofs of age and origin discrimination against those USFMDs; the massive roadblock, for which the deep-rooted chronic causes are built up multiple and intricate, is neither their mistakes to stop them from advancing further nor disqualifying their evident qualifications as medical professionals in the US. They deserve justice!

This is very much reflecting the “Supersize Me, America” culture! I have observed not only about professional opportunities so I can steer my wheels, but also general life. You know, there is nothing concept as retailed buyers can shop in bulk in Vietnam (where houses are smaller and less spaces, same as many other countries); there are no store brands like Costco, FoodMaxx, Wholesale Foods, and many kinds of wholesale for clothing, household and business utilities, goods, freights, etc. American people can buy in bulk with lower prices, in such a way of saving, that is the advantage; however, this deep-rooted concept controls the way people think; I see this culture reflects in everyday life, every fields e.g. communities, socio-economy, politics, businesses, etc. especially our healthcare industry is not an exception! “Supersize Me, America!” culture kills in other ways! Yes, it does! When people have fewer choices, fewer ways to go, they get stuck, that is when many pathological mechanisms happen! People go bankrupt; people become depressed, psychological problems, etc. Think about all those things that can fail social welfare, security/quality of life, community well-being, economy bursting, etc.

Our reverent Ex-President Abraham Lincoln’s famous quote: “America will never be destroyed from the outsides; if we falter and lose our freedom, it is because we destroy ourselves!”

This project I wish to do is to find a way to give a relief for this stress that is actually getting too much tense to explode, a way of protecting our freedom for professional development!

People get tired, different people may have different perspectives in their live goals and so easily become dejected if a very long and tiring process like our licensing process for MDs; that is very normal human nature; insulting words like “laziness”, “procrastination” without scrutinizing of the deep causes would only further traumatizing our own well-beings and putting negative drawbacks on people’s healthy development one way or another. If there is some kind of a “break” for their tough journeys that would be pretty much helpful while they are working tirelessly on their goals without necessarily compromising their life quality.

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Also, it is wise to figure that traumatizing our doctors is not a smart way to make them give good quality of care to communities! It is realistic.

Besides, with the current high-cost healthcare industry and medical training expenses, we try to put USFMDs with ECFMG enhancement into PhA physician associate positions seems to be a good solution to bring the cost down somehow while those USFMDs still be able to work their skills and knowledge and experiences helping communities.

I only wish my little contribution to make a better life for the people and take care of community well-beings.

KATHERINE MILLER, USFMD, ECFMG Enhancement

The steps we need to achieve building this project:

PhA- eAML project- Physician Associate–Attainable Medical Licensing project

Logo for the project: (please see appendix for explanations of logo)

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  • Sanction for USFMD with ECFMG certificate enhancement to be able to work LEGALLY and accepted by all employers, recruiters in healthcare industry with the new title as a mid-level provider PhA-Physician Associate, enact a new license for PhA Physician Associate once they complete all the USMLE step 1, step 2 CS, step 2 CK and step 2 CS and credentialing their official medical school transcripts from the foreign countries they graduate medical schools from.

  • Implementing transparency procedures into USMLEs, e.g. test-takers can request to compare their examination performances with the answers and explanations of their real examination delivered on examination dates. This is a democracy promotion.

  • Re-evaluation, reconsideration most essential and/or overlapping of USMLE step 2 CK and USMLE step 3 that contain two separate examinations. This would reduce expenses, time, and energy for both test-takers and personnel’s at USMLE/ FSMB as well as NBME organizations. All the MDs who pass the exams and working as PhAs would attend serious and quality CMEs as the essential activities to enhance their knowledge and skills all the times so those USMLEs should not exaggerate their standings in the licensing systems.

  • Create programs at work to help PhAs complying with specific working protocols of diagnoses, treatments, patient education, and clinical with or without managerial activities under MDs’ supervision at their workplaces aimed towards primary care besides other subspecialties. By reaching this, creating bids among different medical facilities without restrictions of sizes and types (can be teaching or nonteaching, hospitals, clinics, even private MD offices), any MDs who have good will/good wish to take part in employment and education for PhAs, they are free to participate with their specific proposals comporting to guidelines from state medical board/ federal medical boards with professional inputs, the bids will come to a number of PhAs who will be filled into those facilities.

The philosophy is teaching is not all about knowledge; the enthusiastic hearts of the educators play an important role. Furthermore, according to reliable resources, some scientific studies validate that teaching

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itself is an effective method of learning and reinforcement. So we should spread out this great scientific-proof method of teaching and learning and nurturing our educational system, especially medical education rather than enclosed it inside the boundaries of the present facilities. Besides, AAMC reported lately that the US has about 400 teaching facilities and about 128,000 attending physicians nationally. These numbers do not seem to fit proportionately with American population of 318,292,000 as of June 2014 census! It seems the present GME (graduate medical education) system is too overloaded; particularly, the primary care section is in deep shortage. Lately, President Obama planned to increase the number of residency slots as an emergency aid for the residency selection crisis, but this would not solve the long-term problem. I believe all current practicing licensed MDs have at least some capability to teach; it does not matter where they practice, as long as they have the enthusiastic spirit plus clinical experiences, they can participate in the bids with their approved qualified proposals, they can take some numbers of PhAs from the pool, the same methods for hospitals, clinics, facilities, recruiter companies that have specialist consultants. To solve this intricate, multifaceted and chronic conundrum, we need to build a more sophisticated large-scaled designed system.

  • For USFMDs/AMGs/MD/DO unable to get residency training slots in the traditional pathway, if they agree to commit working as PhAs for three to four years and want to continue to become licensed and have passed the USMLE step 3, they only need this new pathway of ONE-YEAR program, which will be designed accordingly, to become licensed while other PhAs who do not want to continue and/or who do not pass USMLE step 3 can still work at the mid-level position PhAs with CME programs supportively for their works.

  • Stop issue visas for foreign medical doctors as specifically for medical residency training visa; this is one of the top professional jobs and should be preserved for US citizens/ green-cards before the guests. Embark a moratorium on current residency programs that sponsor non-immigrant visas and interns and residents who are not on immigrant visas, not US citizens and green card holders. This is against the Constitution to take away American jobs from American citizens’ right on American soil. The investment to train each interns and residents in a residency program is estimated around 200 grand dollars ($200,000) per year, and the major fund for this financial supply is from Medicare and Medicaid, which are from public and national resources from tax payers. This wrongdoing about sponsoring visas and outsourcing jobs right at home is apparently both morally and economically damaged to American public social security and well beings and USFMDs. (Please see appendix for the article about this) http://www.healthaffairs.org/healthpolicybriefs/brief.php?brief_id=73

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  • Sanction for EEOC eligible to investigate and enforce ACGME, ECFMG, federal medical board, state medical boards to support this project to bring USFMDs back to healthcare industry. LEAVE NO USFMDs BEHIND! Currently, EEOC does not have jurisdiction to investigate ACGME. This is unfair and unjust policy!

  • Make a connection with the immigration department to approach new medical doctors who immigrate to the US legally on other types of visas (NOT J1/H1 for medical residency training) to orient their medical careers in America once they become legal resident moving toward US citizens, if they are willing to return to medicine.

Activities from RRP group: Leader of the group: Doctor Neviana Dimova

Petitioning Representative Grace Meng and 6 others

Do not outsource American jobs when Americans qualify for them

https://www.change.org/p/robert-m-wah-md-do-not-outsource-american-jobs-when-americans-qualify-for-them

Neviana Dimova Louisville, KY

Create similar to Senate Bill 716 MO for every state without limitation on graduation date and time since passing USMLE exams. Increase the number of GME Residency Slots for US Citizen & Resident IMGs (International Medical Graduates). http://www.senate.mo.gov/14info/pdf-bill/tat/SB716.pdf

Implement a version of the Canadian model (Manitoba) for individual assessment of the clinical, diagnostic and management skills of physicians that have already trained in residency programs or practiced outside of the USA, and if adequate, prepare IMGs to work under supervision or directly in underserved areas (under sponsors). These physicians could be granted year limited restricted license (sponsored by an institution or practicing physician). That license could be extended on an annual basis as needed. After 5 years practicing under such circumstances the physician in question should be evaluated for eligibility to apply for a full unrestricted state license for the scope of practice that he has been engaged in, considering he has fully satisfied his examination requirements of passing USMLE Step 1, 2 and 3

 

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http://umanitoba.ca/faculties/medicine/education/imgp/index.html, https://www.cpsnl.ca/default.asp?com=Pages&id=117&m=319 http://www.health.gov.on.ca/english/providers/project/img/img_mn.html, http://www.cehpea.ca/

Place a moratorium on all J1 visas for residency training for 3 years (or use a mandatory tier system: I. US medical students II. US and permanent residents who are international medical graduates (IMGs) II. IMGs, non-us citizens, unless governments of their countries of origin are sponsoring their visas and paying for their tuition and living expenses during residency. For example: http://www.sacm.org/MedicalUnit/PDF/Acceptance2013.PDF http://www.sacm.org/MedicalUnit/PDF/Acceptance2014.PDF Studying the international experience of countries like Spain, Canada, Great Britain in the matter of preferentially matching candidates who are citizens of the country in question http://www.curso-mir.com/Informacion-para-medicos-extranjeros/movimientos-migratorios.html; http://www.carms.ca/en/residency/r-1/eligibility-criteria/ , http://www.foundationprogramme.nhs.uk/pages/home/how-to-apply/FP2015-Eligibility-Information.

Provide targeted training for IMGs who have graduated their respective schools outside USA but have not entered or completed residency training, following the example of California Business code 855: http://law.onecle.com/california/business/855.html These pilot programs could provide adequate training to prepare these doctors to serve as primary care physicians under the supervision of a fully licensed doctor in underserved areas.

As it stands now: The State Department regulations 22 CFR 62.22(f)(2)(v) require that approved

J-1 trainee or intern visa sponsors do not “displace” US workers or “fill a labor need.”

Sponsoring training hospitals routinely issue a Form DS-2019 to the alien physician.

62.22(b)(1)(ii) Exchange Visitor Program training and internship programs must not be used as substitutes for ordinary employment or work purposes; nor may they be used under any circumstances to displace American workers. The requirements in these regulations for trainees are designed to distinguish between bona fide training, which is permitted, and merely gaining additional work experience, which is not permitted. The requirements in these regulations for interns are designed to distinguish between a period of work-based learning in the intern’s academic field, which is permitted (and which requires a substantial academic framework in the participant’s field), and unskilled labor, which is not.

I am a US Citizen myself and a fully trained physician from Bulgaria. I myself and the members of my organization, Residency Ready Physicians are ECFMG certified and completed all required licensing exams, but cannot practice in the US because we cannot complete a required residency. There are thousands of us, International Medical Graduates (IMG’s), living in the great country, who want to help people and alleviate the physician shortage, but two things keep us out of the system: not enough residencies and thousands of visiting residents on J1 and H1B visas taking these taxpayer funded positions. No matter how much education we have, we cannot practice without this last step. These Medicare funded position are given to thousands of doctors from abroad who have not paid taxes in the US or have any commitment to this country, while thousands of US citizens and permanent residents are left wasting their education and talents.

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In 2014, 3613 of the 26,678 available residency positions went to NON US International Medical graduates while 975 American graduates (each with approximately 200,000 dollars in student loans) and 4882 International Medical Graduates who are US Citizens and permanent residents who have passed the required licensing exams and who applied, were unable to find a position. Additionally 611 DO (Doctor of Osteopathy) US citizens did not match. At the same time 6,335 IMGs non-US citizens matched. This is a significant number representing 24.7 percent of all NRMP matches and 22.9 percent of all NRMP and AOA year matches combined and well above the percent of foreign-educated individuals in most other health professions, like nursing and pharmacy, which runs generally in the 5 to 10 percent range.

The above numbers by the way only count the IMGs that applied to the match. It costs an IMG about $1500 or more to apply so most only try two or three times before giving up. That is after taking the required exams, which cost about $800 for each step (there are 3 steps). We do not get student loans for these expenses.

The cost of physician shortage is a major problem. Not enough doctors means that hospitals and practices must compete for those available, offering higher pay and benefits. My organization, Residency Ready Physicians, has several recommendations for using the estimated 6000 International Medical Graduates who are currently underemployed. IMGs mainly from India and Pakistan make the major numbers of J1 visa applicants for medical residency. While they are supposed to go back to their home countries after their training, they actually never do and find ways to immigrate to USA because of the better pay compared to their countries of origin. Therefore is also unethical to admit doctors on J1 visas and “close our eyes” knowing that majority of them will never go back and drain the medical taskforce of their countries of origin. In addition (see papers attached) the numbers of J1 visas issued closely approximates the numbers of US IMGs applying for residency but being unmatched.

So far I have been personally lucky not to have to go into too much debt, taking student loans for my medical education. However we have many members who are Caribbean or American Medical graduates with an average of $200,000 in student loans. Unfortunately, as they are denied residency positions and subsequently medical license several of our members after years of applying to the residency Match and not being matched have defaulted on their student loans and went into bankruptcy and their families are currently living on “food stamps”.

We do not want special treatment, but just the opportunity to join the system and help those most in need. I would willingly serve in the poorest Appalachian town, the inner-city, or wherever my talents are needed. I trained all my life to serve as a doctor, to heal. All I am asking; all our group is asking for, is for the opportunity to serve. Please consider our requests.

Sincerely

Neviana Dimova

Letter to

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Representative Grace Meng

Representative Thomas Emmer

mediarelations@jama-archives.org

and 4 others

AMA president Steven.Stack@ama-assn.org

President Barack Obama

Senator Bernie Sanders

Sylvia Burwell

I just signed the following petition addressed to: Congress.

—————-

Do not outsource American jobs when Americans qualify for them

Read more

Updates

1. 3 months ago

Petition update

Gofundme update

Congratulations to all supporters. In 6 days we received $113 in donations for the creations and lobbying of our own organization to protect and work for the rights of US IMGs and AMGs to get residency…

3 months ago

Petition update

Gofund me account created for funding of our own non-profit organization.

Money will be used for lobbing, advertising and perhaps going to Washington DC. Link:

http://www.gofundme.com/u7aefs

14

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2.

gofundme.com

5 months ago

Petition update

“Private” information…

Dear supporters, just wanted to drop a note and let you know that certain people seems to have complained against exposing “private” information in the petition and there are links that have been…

6 months ago

Petition update

Congratulations to all supporters reaching 1000 votes goal just before the Match

Updated the petition what exactly we want to be done: 1. Create similar to Senate Bill 716 MO for every state without limitation on graduation date and time since passing USMLE exams. Increase the number of…

7 months ago

1,000 supporters

3 years ago

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Neviana Dimova started this petition

SENATE COMMITTEE ON BUSINESS PROFESSIONS

AND ECONOMIC DEVELOPMENT

REGULATORY REQUEST QUESTIONNAIRE

Section C: Sunrise Criteria

This part of the questionnaire is intended to provide a uniform method for obtaining information regarding the merits of a request for governmental regulation of an occupation. The information you provide will be used to rate arguments in favor of imposing new regulations (such as educational standards, experience requirements, or examinations) to assure occupational competence.

Part C1 – Sunrise Criteria and Questions

The following questions have been designed to allow presentation of data in support of application for regulation. Provide concise and accurate information in the form indicated in the Instructions portion of this questionnaire.

UNREGULATED PRACTICE OF THIS OCCUPATION WILL HARM OR ENDANGER THE PUBLIC HEALTH SAFETY AND WELFARE

What is the nature and severity of the harm? Document the physical, social, intellectual, financial or other consequences to the consumer resulting from incompetent practice.

Thursday August 27th 2015, responded by MILLER, KATHERINE T, USFMD

Since this new proposals have not yet implemented into the public consumerism, there has not yet been established any of harm in any ways of nature and severity.

However, it is predictable to extrapolate the nature of the possible harm incurred by this new practitioner PhAs of this proposal will be similar to yet less in quantity than any of the current professional practitioners: licensed MDs, PAs and NPs for the natures of the project for PhAs is to minimize harms from occuring. One of the construction to build this project for PhAs to be able to practice with low incidence of harm occurring is that there will be a strict and extensive supervising and supportive network system for PhAs to work on and constantly communicating with this control center to get feedbacks.

 

One other reason may reduce harms for PhA practice is that this new practitioners will work in a much more organized programs with much more focuses and the project is designed in the fashion that PhAs would be much better connections with patients in every way: better communication in conversations, their behaviors in practices, their attitudes toward expectation and duties in their careers since they are actually MD level of medical education and willing to work as a mid -level career; their messages are clear with a dedication and devotion attitude more than seeking privileges. With better transparency pictures, healthcare costs reduce together with quality improvement. Also, this new career promises many better changes: e.g. shortage of primary care MDs since PhAs focus on primary care, family practice, healthcare accessible for minority ethnic groups especially disparity communities that are in language and culture differences would be mitigated.

Current practitioners with the current issues:

Please see the appendices of 2015 review of medical malpractice for MDs and the one for PAs, NPs.

MD medical malpractice paid for any kinds of harms incurred:

Quotes:

https://www.trustedchoice.com/professional-liability-insurance/medical-malpractice/

Medical Malpractice Facts

  • Anywhere from 44,000 to 98,000 people die each year due to a preventable medical error.

  • Medical errors that occur in hospitals cost between $17 billion and $29 billion annually.

  • In 2000, $6.4 billion was spent on medical malpractice insurance.

  • 1 in 8 preventable medical errors results in a medical malpractice claim.

  • Damages are rarely awarded in medical malpractice claims.

  • Medical malpractice insurance costs physician’s 3.2% of their revenue.

  • 5% of doctors carry 54% of all medical malpractice claims.

The cost of medical malpractice insurance varies depending on your practice and where it’s located, in addition to several other factors. A heart surgeon runs a greater risk of a malpractice versus an RN responsible for taking blood. One area that tends to have a high rate of litigation is obstetrics, but today no areas of specialty are immune to lawsuits.

Costs tend to vary among states. For example, malpractice costs in Minnesota could cost anywhere from $4,000 to $17,000 per year, depending on your specialty. But in California, a surgeon can expect to pay anywhere from $22,000 to $34,000 per year.

PA/NP medical malpractice:

http://expertpages.com/news/Physician_Assistant_Malpractice_History.htm

Malpractice Amount

PA average and median payments were less than that of physicians and APNs. The average and median APN payments were the highest at $350,540 and $190,898. The average and median physician payments were $301,150 and $150,821 while the average and median PA payments were $173,128 and $80,003. The physician adjusted mean payment was 1.74 times higher than PAs but only 0.86 that of APNs. The physician adjusted median payments were 1.89 times that of PAs but only 0.79 that of APNs. It is speculated that APN mean and median payments are higher than that of physicians and PAs because the proportion of APNs who work in the high risk specialties of anesthesia and obstetrics is higher. The proportion of malpractice payments for nurse anesthetists (47%) and nurse midwives (25%) was 72% of total APN payments.

Malpractice Incidence Rate

The rate of malpractice incidence is increasing for PAs and APNs but flat for physicians. This has been attributed to the major increase in number of PA and APN providers but relatively minor (14%) increase in physician workforce between 1991 and 2007. The rate of increased incidence was not greater than the increase in provider workforce.

Amount of Malpractice Payment

In adjusted 2008 dollars, average physician payments were 1.74 times higher than PA payments, and median payments were 1.89 times higher.

Reasons for Disciplinary Action

The most common reason for disciplinary action by state and federal monitoring bodies was the same for all three provider types. The most common disciplinary action was a licensing action by licensing authorities and the most common reasons for the licensing action were for unethical conduct and alcohol/substance abuse.

Reasons for Malpractice Claim

The most common reasons for APN malpractice claims were for obstetric and anesthesia errors. This is due to the disproportionate number of APNs who practice in these specialties compared to physicians and PAs. If these are excluded, the top ranking reasons for malpractice payments were the same for PAs and APNs: in order they are errors in diagnosis, treatment, medication

and surgery. For physicians they were in order errors in diagnosis, surgery, treatment, obstetrics and medication.

Gender Differences

The study found that female health care providers make larger malpractice payments on average than their male counterparts and that female provides are slightly more likely to be successfully sued. It also suggested that more women than men bring about malpractice claims, but this could be a factor of more women than men receiving health care.

Differences in State Actions

States with the most adverse actions against physicians were not necessarily those with the most malpractice payments. Pennsylvania and New York, while ranking high in malpractice incidence, were found to have adverse action ratios that were three times lower than the average. That is, while states on average had about one adverse action for every 4.4 malpractice payments, these states had about one in thirteen. This could be an indication of their ineffectiveness at sanctioning unsafe providers.

SENATE COMMITTEE ON BUSINESS PROFESSIONS

AND ECONOMIC DEVELOPMENT

REGULATORY REQUEST QUESTIONNAIRE

Section C: Sunrise Criteria

This part of the questionnaire is intended to provide a uniform method for obtaining information regarding the merits of a request for governmental regulation of an occupation. The information you provide will be used to rate arguments in favor of imposing new regulations (such as educational standards, experience requirements, or examinations) to assure occupational competence.

Part C1 – Sunrise Criteria and Questions

The following questions have been designed to allow presentation of data in support of application for regulation. Provide concise and accurate information in the form indicated in the Instructions portion of this questionnaire.

UNREGULATED PRACTICE OF THIS OCCUPATION WILL HARM OR ENDANGER THE PUBLIC HEALTH SAFETY AND WELFAR

How likely is it that harm will occur? Cite cases or instances of consumer injury. If none, how is harm currently avoided?

Answers:

Thursday August 27th 2015, responded by MILLER, KATHERINE T, USFMD

Since this new proposals have not yet implemented into the public consumerism, there has not yet been established any of harm in any way of the nature and severity.

(Please read question # 13 for more information)

SENATE COMMITTEE ON BUSINESS PROFESSIONS

AND ECONOMIC DEVELOPMENT

REGULATORY REQUEST QUESTIONNAIRE

Section C: Sunrise Criteria

This part of the questionnaire is intended to provide a uniform method for obtaining information regarding the merits of a request for governmental regulation of an occupation. The information you provide will be used to rate arguments in favor of imposing new regulations (such as educational standards, experience requirements, or examinations) to assure occupational competence.

Part C1 – Sunrise Criteria and Questions

The following questions have been designed to allow presentation of data in support of application for regulation. Provide concise and accurate information in the form indicated in the Instructions portion of this questionnaire.

UNREGULATED PRACTICE OF THIS OCCUPATION WILL HARM OR ENDANGER THE PUBLIC HEALTH SAFETY AND WELFARE

15. What provisions of the proposed regulation would preclude consumer injury?

Answers:

Friday August 21st 2015, responded by MILLER, KATHERINE T, USFMD

We live in an imperfect world. It is both subjectively and objectively imperfect, unwittingly. So when we try to build a new establishment, even we have brainstormed and brain-drained to our utmost perfectionism, there would still be wise to leave an acceptable corridor of low percentage of exceptions and errors (ideally less than 10%).

The new medical practice trend is about quantification of quality by measurements conducted by quality measure task force. The new proposal would adopt it. There would be appointed a quality measure task force for the new practitioner to support them able to do their jobs independently under limited supervisions yet still strictly adhere to quality control and non-stop improve quality of care; patient-center care as the kernel of the proposals.

However, to say, the propose regulation would preclude consumer injury, we would like to clarify that, yes, we strive our best to put public welfare, security and safety to the

foremost priority, yet we cannot one hundred percent (100%) guarantee the preclusion of all and any injury since the proposals are still under provision and need to implement as a testing mode that would still need regulations and modifications to comport to the reality of our imperfect conditions. Even once it is well established into consumerism, it still continues to self-improvement to all the changes and adaptability to guarantee its stands in the public welfare.

EXISTING PROTECTIONS AVAILABLE TO THE CONSUMER ARE INSUFFICIENT

To what extent do consumers currently control their exposure to risk? How do clients locate and select practitioners?

Answers:

Monday August 24th 2015, responded by MILLER, KATHERINE T, USFMD

Since this new proposals have not yet implemented into the public consumerism, there has not yet been established any of harm in any way of the nature and severity.

(Please read question #13 for more information)

SENATE COMMITTEE ON BUSINESS PROFESSIONS

AND ECONOMIC DEVELOPMENT

REGULATORY REQUEST QUESTIONNAIRE

Section C: Sunrise Criteria

This part of the questionnaire is intended to provide a uniform method for obtaining information regarding the merits of a request for governmental regulation of an occupation. The information you provide will be used to rate arguments in favor of imposing new regulations (such as educational standards, experience requirements, or examinations) to assure occupational competence.

Part C1 – Sunrise Criteria and Questions

The following questions have been designed to allow presentation of data in support of application for regulation. Provide concise and accurate information in the form indicated in the Instructions portion of this questionnaire.

EXISTING PROTECTIONS AVAILABLE TO THE CONSUMER ARE INSUFFICIENT

Are clients frequently referred to practitioners for services? Give examples of referral patterns.

Answers:

Thursday August 27th 2015, responded by MILLER, KATHERINE T, USFMD

Currently, this new career is not yet in practice. However, once it is established, there will surely be referral services with evaluation and feedback system with statistic records.

SENATE COMMITTEE ON BUSINESS PROFESSIONS

AND ECONOMIC DEVELOPMENT

REGULATORY REQUEST QUESTIONNAIRE

Section C: Sunrise Criteria

This part of the questionnaire is intended to provide a uniform method for obtaining information regarding the merits of a request for governmental regulation of an occupation. The information you provide will be used to rate arguments in favor of imposing new regulations (such as educational standards, experience requirements, or examinations) to assure occupational competence.

Part C1 – Sunrise Criteria and Questions

The following questions have been designed to allow presentation of data in support of application for regulation. Provide concise and accurate information in the form indicated in the Instructions portion of this questionnaire.

SENATE COMMITTEE ON BUSINESS PROFESSIONS

AND ECONOMIC DEVELOPMENT

REGULATORY REQUEST QUESTIONNAIRE

Section C: Sunrise Criteria

This part of the questionnaire is intended to provide a uniform method for obtaining information regarding the merits of a request for governmental regulation of an occupation. The information you provide will be used to rate arguments in favor of imposing new regulations (such as educational standards, experience requirements, or examinations) to assure occupational competence.

Part C1 – Sunrise Criteria and Questions

The following questions have been designed to allow presentation of data in support of application for regulation. Provide concise and accurate information in the form indicated in the Instructions portion of this questionnaire.

EXISTING PROTECTIONS AVAILABLE TO THE CONSUMER ARE INSUFFICIEN

What sources exist to inform consumers of the risk inherent in incompetent practice and of what practitioner behaviors constitute competent performance?

Answers:

Thursday August 27th 2015, responded by MILLER, KATHERINE T, USFMD

As explained in answers for question #13:

Since this new proposals have not yet implemented into the public consumerism, there has not yet been established any of harm in any ways of nature and severity.

However, it is predictable to extrapolate the nature of the possible harm incurred by this new practitioner PhAs of this proposal will be similar to yet less in quantity than any of the current professional practitioners: licensed MDs, PAs and NPs for the natures of the project for PhAs is to minimize harms from occuring. One of the construction to build this project for PhAs to be able to practice with low incidence of harm

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occurring is that there will be a strict and extensive supervising and supportive network system for PhAs to work on and constantly communicating with this control center to get feedbacks.

One other reason may reduce harms for PhA practice is that this new practitioners will work in a much more organized programs with much more focuses and the project is designed in the fashion that PhAs would be much better connections with patients in every way: better communication in conversations, their behaviors in practices, their attitudes toward expectation and duties in their careers since they are actually MD level of medical education and willing to work as a mid -level career; their messages are clear with a dedication and devotion attitude more than seeking privileges. With better transparency pictures, healthcare costs reduce together with quality improvement. Also, this new career promises many better changes: e.g. shortage of primary care MDs since PhAs focus on primary care, family practice, healthcare accessible for minority ethnic groups especially disparity communities that are in language and culture differences would be mitigated.

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REGULATORY REQUEST QUESTIONNAIRE

Section C: Sunrise Criteria

This part of the questionnaire is intended to provide a uniform method for obtaining information regarding the merits of a request for governmental regulation of an occupation. The information you provide will be used to rate arguments in favor of imposing new regulations (such as educational standards, experience requirements, or examinations) to assure occupational competence.

Part C1 – Sunrise Criteria and Questions

The following questions have been designed to allow presentation of data in support of application for regulation. Provide concise and accurate information in the form indicated in the Instructions portion of this questionnaire.

EXISTING PROTECTIONS AVAILABLE TO THE CONSUMER ARE INSUFFICIENT

What administrative or legal remedies are currently available to redress consumer injury and abuse in this field?

Answer:

Thursday August 27th 2015, responded by MILLER, KATHERINE T, USFMD

There has not been any of those entities, yet there would definitely be needed once it is established the new profession of a mid-level medical practitioner Physician Associates, PhAs.

SENATE COMMITTEE ON BUSINESS PROFESSIONS

AND ECONOMIC DEVELOPMENT

REGULATORY REQUEST QUESTIONNAIRE

Section C: Sunrise Criteria

This part of the questionnaire is intended to provide a uniform method for obtaining information regarding the merits of a request for governmental regulation of an occupation. The information you provide will be used to rate arguments in favor of imposing new regulations (such as educational standards, experience requirements, or examinations) to assure occupational competence.

Part C1 – Sunrise Criteria and Questions

The following questions have been designed to allow presentation of data in support of application for regulation. Provide concise and accurate information in the form indicated in the Instructions portion of this questionnaire.

EXISTING PROTECTIONS AVAILABLE TO THE CONSUMER ARE INSUFFICIENT

21. Are the currently available remedies insufficient or ineffective? If so, explain why.

Answer:

Thursday August 27th 2015, responded by MILLER, KATHERINE T, USFMD

For this new proposals, there has not yet anything established, and we will try our best to prepare and to keep on improving the quality of practice and patient-central care.

For other current practitioners, there have been many attempts trying to improve quality of care such as quality measure trend recently has been established to improve care and reduce costs. However, the progress is still at work improving.

NO ALTERNATIVES TO REGULATION WILL ADEQUATELY PROTECT THE PUBLIC

Explain why marketplace factors will not be as effective as governmental regulation in ensuring public welfare. Document specific instances in which market controls have broken down or proven ineffective in assuring consumer protection.

Answer:

Friday August 28th 2015, responded by MILLER, KATHERINE T, USFMD (latest update Saturday August 29 – 2015)

To discuss about the protection of public welfare, there are two important issues I would like to address in my arguments why there must be essential need for the government, as the American public representative, to step in and to give regulation for our medical licensing system.

Firstly, I would like to discuss about the evolution of the American healthcare system and the American medical education that supplies MDs for the needs of healthcare demand. To be able to do this analyses and clarification thoroughly, I believe we should have a look back into history and find out “how did it get here?” Then, secondly, I would like to attach the important trend of immigrant medical doctors into the American healthcare system and its own evolution for the better or the worse; this is because America is an immigrant-based country as it has formed and grown.

Healthcare industry is the most complex business in all kinds for its inseparable yet contradicting natures that define itself: as healthcare, it carries humanity conscience property; as a business, it carries the profit and earning property. This is why our healthcare system, when to put into such a robust proto-type operation as of the American capitalistic economy, has accurately been a metaphor as one of the toughest horses for us to control its galloping journey towards the positivity.

To understand the evolution of American healthcare industry, please allow me to take you back into the early time that it has been formed as history builds up the system into what it is like now, the sciences of “how does it work?”

I must say the American healthcare has its heroic and historical development as a close and valiant companion pacing steadily with the growth of the American colonies into

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the United States of America then heading towards one of the most powerful nations of the world of present time.

In the seventeenth century when the American colonies have started segregating from British Sovereign, the primitive American healthcare was all what the early American habitats and settlers had got for their survivals. No medical doctors, only native healers and self -appointed physicians or surgeons from apprenticeship yet their innocent care for the sickness among lot of quacks, charlatans, and pretenders that tried to lure for money. Very few European MDs graduated from medical schools immigrated to the colonies since the poor pioneers and settlers were unable to afford them. To summarize the overwhelmingly many details, what was healthcare for the early Americans was worse than third world countries nowadays. America at this struggling period to form its own independent nation has undauntedly confronted and triumphed over unlimited human and non-human enemies and adverse factors. Many issues for healthcare were the primitive care for the sick, endemic and epidemic infectious diseases, public sanitary, etc. Half of children died before the age of five! The quality of life was unfathomably low and beyond understanding. Healing remedies were made by apothecary shops or drugstores from bark, roots, and herbs. Surgeons treated patients by bleeding them to remove “bad humours”, sucking cure, etc. Physicians and surgeons, very few in numbers, had to travel in vast distances to see patients at their homes, no office visits. George Washington, our very first president and the first founder father of the country died on December 14th, 1799, after a while his physician ordered to bleed him via lancing his veins for five pints of blood as a cure regimen for his cold and sore throat. These kinds of practices were the early American healthcare in the seventeenth, eighteenth and even nineteenth centuries.

American medical education was also too primitive at this period. Medical knowledge was based on assumption of the balances between four main bodily fluids called “humours”: blood (sanguis), phlegm (pituita), yellow bile (chole), and black bile (melanchole). Facing these critical issues of life and death from the growing concern of the American public, the few enthusiastic European-trained American physicians who traveled back and forth from Europe, especially England had shaped the idea to develop formal medical training for MDs in America. The very first American medical school, College of Philadelphia, School of Medicine opened in November 1765, eleven years before the United States gained its independence against Great Britain July 4th, 1776. There were only two professors, Doctor John Morgan, the founder and his colleague, Doctor William Shippen.

The early times of medical education were astonishingly poor conditions and means for learning and researching. Medical students, who stole dead bodies for learning and dissecting anatomy, were called “grave-robbing students” or “resurrectionists”. They caused rages among communities that people stormed into medical schools to destroy classrooms. Since then, dead bodies of black people were more tolerant for medical students to learn anatomy than dead white people. Racism was worse well

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before the final Emancipation Proclamation by President Abraham Lincoln on January 1st 1863 after winning the Civil war 1861.

The forming medical licensing was no less turbulent. Though medical schools were around, a few of them available, yet people who desired to become physicians were unable to afford school fees. This ended up the old paths of becoming a physician via apprenticeship and self-appointed still rampant. Doctors could even purchase their licenses from their home states by mail via sending money to the state offices and their licenses were mailed to their homes. Of course, among these activities, there were many demonstrations and movements to appeal to the government to sanction laws upon licensing for the quality of medicine and healthcare providers.

Not until the 1830s to 1850s, most states required doctors to pass an exam to earn their license before granted the rights to open a shop. Even the freedom-lover country could believe it right to legalize to licensing to prevent quacks and charlatans from harming the public. The AMA, American Medical Association, established by May 1846, pushed further and harder limits for medical students to earn their licenses to practice medicine. One of the requirements was medical school of at least three years. Elizabeth Blackwell was the first female physician graduated in 1849 at Geneva Medical School as the leader in the movement against sex discrimination in medical practice. This was one of the events in the movements of the branching nursing schools mainly for women while medical schools were of male students.

However, the medical education and licensing reform movements were not always at its optimistic peaks. The licensing reforms had had both ups and downs as professions accompanying by regressions. While AMA raised standards for entering medical schools as well as many states required for licensing, the enrollments at medical schools dropped dramatically and the reforms doomed. People argued about the necessity of the subjective standards, medical schools ignored AMA warnings. Harvard Medical School dropped over 40% enrollment. A big scandal came out from the AMA from selling over fake 60,000 medical diplomas by John Buchanan, who worked at the AMA in Pennsylvania shocked the public. By 1990, the AMA raised medical school to at least a four year program and declined any schools that refuse this upgrade to attend AMA conference and would be out of business.

By 1908, Abraham Flexner recommended an overhaul for American medical schools.

By 1920 most medical schools met the standards of MD educations by states and federal laws and unify medical education and licensing via licensing examinations.

Alongside with all the structural changes in education and licensing medicine, medical technologies have been through dramatic leaps that opened a totally new era and new looks for medical sciences and tremendous understanding into anatomy, microbiology (with the discover of microscope in late 1770s), pharmacology (penicillin, the very first antibiotics, discovered in 1941), etc. Louis Pasteur

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discovered pasteurized technology for dairy products; the technique of sterilization for surgery has firstly applied in operating rooms in 1870s. Clinical medicine developments were also a fast racer with basic medical science understanding. The new era of medicine and medical education and researches has turned sharp corners into the brighter horizon with bounty helps from technologies at the end of nineteenth and early twentieth century.

At the mean time, America has been developed into a strong nation with influential throughout the world. While many presidential have tried to keep the nation neutral attitude towards the world, America was pushed into participant in WWII. The end of WWII, the period of 1945 to 1950 was the time with too many convoluted and critical transformations in American cultures, economy, technology for the better and for the worse. Unfortunately, it is for the worse when healthcare system to be absorbed into the national machinery operation of changes. The push of economy has changed medicine and healthcare from a predominant charity and humanity activity before the 1950s into more about a for-profit industry after 1950s. The transformation of health insurances from simply to cover basic needs of low hospital fees into an ever-growing complex and profitable services owned by greedy corporations with greedy corporations that own hospitals, medical facilities, and medical devices, etc. that refuse to control cost because of their own revenue growth. Medicine has really altered into a privilege profession career than its original innocent humanity services. Physicians now open their own offices and patients come to see them, no more home visits or very rare physicians still make this fashion.

Medicine and healthcare services were not recognized their high values until the 1950s. Before this period, physicians and nurses worked for charity just expected to have foods and lodgings and did not expect higher compensation towards their lifestyles. To mention about healthcare costs should be accompanied with its inseparable cost of healthcare education. Medical school tuitions and all expenses have been steadily increasing as medical school duration has now upgraded into six year program instead of four year program. A portion of Medicare from tax payers are paid as financial supplements in medical school education besides medical student loans no less than the minimum of $200,000, many students with no less than $400,000 on their backs at graduation are very commonly heard of.

The licensing procedure has also evolved into much more complicated and even has turned into much bulky and redundant currently with excessive consumption of energy and financial and human resource wasting. This is not about protecting the public welfare anymore, but it has been abused the concept for the profitable purposes.

Many failed attempts of healthcare reforms by many presidential; etc. creating programs to help communities, Medicare, Medicaid, etc. to fight against healthcare costs that has started to climb higher and higher from the 1950s. America started to measure healthcare cost in 1929. Medical costs stayed at the steady rate of 3.5 to 4.5 per

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cent annual GDP; the upward raise has started steadily from 1950s until recently 2015 it has reached roughly 15% GDP!

The problems of our current healthcare system is not only about protecting the public from physical harms by improper medical practices, the much tougher dilemma is about how to strike the skyrocketing costs.

Now, I would like to turn to the second part of my argument: the attachments of the immigrant MDs from foreign countries who immigrated legally and illegally to the US and their saga to become licensed here for practice medicine.

We all acknowledge that America is an immigrant -based nation. It is a magnet for immigration and growth. However, it is surprised for me to find out there has never been a serious arrangement for MDs from foreign countries who come to the US legally by permanent immigrant visas and legitimately become green card holders then US citizens. The current system has degraded equally all kinds of visas both the permanent immigrant visas, which is very hard to obtain versus the visiting visas. This proves the current immigration system is defective as it’s lacking of insightful understanding the righteousness of legal immigration that brings justice and order society instead of the chaos of illegal immigration trying to political pushing for citizenships as cutting the lines, an non-civilized and unconstitutional behavior.

This is why the problems of US-FMDs discrimination has been buried under the rug for too long since 1950s and the public America have no clue about the existence and yet mistreated of US-FMDs. The trend of MD immigration to the US were for many causes, one big cause was from war residues; many of USFMDs were from WWII, Vietnam war, Korean war, etc. amnesty on political causes, oppressions, freedom pursue, etc. These are the pertinent reasons of permanent immigration to the US. These MDs deserve to be treated in justice in their new homeland that they are entitled to return to practice medicine to serve the American public once they meet professional requirements such as passing medical licensing. Then, the trend of permanent immigrant of MDs via their family programs, etc. these MDs come to the US and want to return to medicine. Their pathways to medicine should be modified to adapt to their different situation as they are in much more challenging than the regular domestic trained or the ones still in their countries to obtain a visiting visa to the US.

George D Lunberg said,

“The additional 8,000 are filled by international medical graduates (IMGs). Indeed, 23 percent of the 800,000 physicians in this country graduated from medical schools in foreign countries. This is another political football.

Many of those graduates serve in inner-city residency programs. They take the tough jobs that U.S graduates avoid; without the IMGs, city hospitals would have difficulty caring for the poor!

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That does not detract from the main problem. Too many doctors will do too many things to realize their income expectations. They are wily individuals and always find ways to enhance their incomes. We need to place greater controls on the growth of physician supply…..”

This is exactly the current picture of the licensing system and American healthcare. IMGs are treated as second -class MDs. We need to talk about the ECFMG, which stands for the Educational Commission for Foreign Medical Graduates. It was established in 1956. These US-FMDs had graduated from their previous countries; the American people do not pay any tax dollars for their training. They do not burden student loans for the American financial system with over a few trillions of dollars in debt currently.

Finally, to put the two pictures into one panorama, it is passed due time to establish an organized licensing system for those US-FMDs in a separate pathway so that it is clear for them to know what they should do and what to expect, as the American slogan: work hard, pay back. The current system does not prove this thesis of the American dream idealism.

And the last but not least, it must be the government to step in to establish this regulation since US-FMDs are from many different corners of life and even different generations. It is almost impossible for them to become a strong group to stand up on their own at the first place. They are more of a pessimistic for their suffering from too-long oppression and somewhat with inferior complex mentality in this critical issue about they are absolutely entitled to become a medical professional and able to practice here in the US once they are a legal permanent resident as a green card holder or citizens as long as they obtain their ECFMG certificate with a high valuable qualification they possess. The residency system should no longer be a prerogative hierarchical monopoly roadblock to restrain these USFMDs from advance forward at least at a mid-level provider, PhAs Physician Associates, then there will be invented the special one-year residency program to finalize all the credentials and adding up essential information before these USFMDs eventually grant their MD licenses after their PhA licensing and working for certain established period of time and achievements. This will unearth the hidden treasure that the American people deserve to entertain for their healthcare system enriched, yet they have not been aware of for so long because of the lack of information. America is a democracy nation from its dawn and it will forever stand a democracy and it will fight to protect its democracy. This PhA-AML project is a way to fight and protect democracy, freedom of choices in career development.

Finally, and again, because of the conflicts of interest with many current powerful organizations, it must be the government, who impartially represent the American people, to step in to initiate this project. The first and foremost action is to legalize the ECFMG certificate into Physician Associate PhA licenses and to continue to realize this PhA-AML project for the benefits of American public welfare as a whole eventually.

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References:

1- Miller, Brandon Marrie. (1997). Just What The Doctor Ordered. Lerner

Publications Company. Minneapolis.

2- Lundberg, George D. (2000). Basic Book Publications. Severed Trust. New York.

SENATE COMMITTEE ON BUSINESS PROFESSIONS

AND ECONOMIC DEVELOPMENT

REGULATORY REQUEST QUESTIONNAIRE

Section C: Sunrise Criteria

This part of the questionnaire is intended to provide a uniform method for obtaining information regarding the merits of a request for governmental regulation of an occupation. The information you provide will be used to rate arguments in favor of imposing new regulations (such as educational standards, experience requirements, or examinations) to assure occupational competence.

Part C1 – Sunrise Criteria and Questions

The following questions have been designed to allow presentation of data in support of application for regulation. Provide concise and accurate information in the form indicated in the Instructions portion of this questionnaire.

NO ALTERNATIVES TO REGULATION WILL ADEQUATELY PROTECT THE PUBLIC

 

Are there other states in which this occupation is regulated? If so, identify the states and indicate the manner in which consumer protection is ensured in those states. Provide, as an appendix, copies of the regulatory provisions from these states.

Answer:

Friday August 28th 2015, responded by MILLER, KATHERINE T, USFMD

Currently, the two states have initiated state level bills, not exactly the same as the PhA-AML proposal, the similar idea of a mid-level provider called Assistant Physician: Missouri and Minnesota.

California did have a bill for US-FMDs, however it only focused on US -FMDs who speak Spanish so this does not solve the whole problem of thousands of US-FMDs distributed throughout many languages, many cultures and the problem of accessible to quality healthcare disparity should be addressed via this PhA-AML proposal.

Please see the appendices:

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_ Missouri Bill: SENATE BILL NO. 716 – 97TH GENERAL ASSEMBLY 2014 – 5335S.09T

_ Minnesota Bill: HF-1277 Bill Introduced as 89th Legislature (2015-2016) on

USFMDs

_ California Bill for US-FMDs who are bilingual English-Spanish: Assembly Bill

No. 1533, Chapter 109

SENATE COMMITTEE ON BUSINESS PROFESSIONS

AND ECONOMIC DEVELOPMENT

REGULATORY REQUEST QUESTIONNAIRE

Section C: Sunrise Criteria

This part of the questionnaire is intended to provide a uniform method for obtaining information regarding the merits of a request for governmental regulation of an occupation. The information you provide will be used to rate arguments in favor of imposing new regulations (such as educational standards, experience requirements, or examinations) to assure occupational competence.

Part C1 – Sunrise Criteria and Questions

The following questions have been designed to allow presentation of data in support of application for regulation. Provide concise and accurate information in the form indicated in the Instructions portion of this questionnaire.

NO ALTERNATIVES TO REGULATION WILL ADEQUATELY PROTECT THE PUBLIC

What means other than governmental regulation have been employed in California to ensure consumer health and safety. Show why the following would be inadequate:

code of ethics

codes of practice enforced by professional association

dispute-resolution mechanisms such as mediation or arbitration

recourse to current applicable law

regulation of those who employ or supervise practitioners

other measures attempted

Answer:

Friday August 27th 2015, responded by MILLER, KATHERINE T, USFMD ( latest updated on Saturday August 29 2015 )

All of the above six criteria are very critical and essential for protecting public welfare.

My suggestion is:

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Besides the above criteria of regulation, we should add these featured criteria into the project:

g- Malpractice coverage for PhA-AML and supervised MD h- CME programs for PhAs and AML project (PhA and MD tracks),

i- Supervision programs for supervised MDs on their PhAs with specific benefits and duties

j- Technologies for remote medical education and conversation with supervisors for PhAs,

k- Other supportive programs for Physician Associates PhA, etc.

These are other featured criteria I would want to include and develop in much more detailed and organized fashion once this project is built.

SENATE COMMITTEE ON BUSINESS PROFESSIONS

AND ECONOMIC DEVELOPMENT

REGULATORY REQUEST QUESTIONNAIRE

Section C: Sunrise Criteria

This part of the questionnaire is intended to provide a uniform method for obtaining information regarding the merits of a request for governmental regulation of an occupation. The information you provide will be used to rate arguments in favor of imposing new regulations (such as educational standards, experience requirements, or examinations) to assure occupational competence.

Part C1 – Sunrise Criteria and Questions

The following questions have been designed to allow presentation of data in support of application for regulation. Provide concise and accurate information in the form indicated in the Instructions portion of this questionnaire.

NO ALTERNATIVES TO REGULATION WILL ADEQUATELY PROTECT THE PUBLIC

If a “grandfather” clause (in which current practitioners are exempted from compliance with proposed entry standards) has been included in the regulation proposed by the applicant group, how is that clause justified? What safeguards will be provided consumers regarding this group?

Answer:

Friday August 27th 2015, responded by MILLER, KATHERINE T, USFMD

Since PhA Physician associates has never been established yet, there would not be such groups. Furthermore, this project is about anti-discrimination on age, sex, origin. That means every PhA physician associates to be require to comply to the regulation process for quality control and, again, the protection of the public welfare.

 

There are more questions and answers: Questions 29 to 57 and answers will be uploaded later.