Last week, we began examining Standard B3.06a, which is causing confusion, difficulty, and citations for a fair number of PA Programs. In the last five or six years, the Commission's attitude regarding board certification requirements for preceptors has become increasingly rigid. I see many programs struggling with this issue. The trend will likely worsen over the next few years unless PA programs use the time before their validation visits to overhaul the way they assign preceptors to Supervised Clinical Practice Experiences.

I’d like to use the blog today to share some examples of the language of such citations. In doing so, we can piece together what the Commission is looking for and what it considers unacceptable.

Citation Examples

The following are excerpts from various citations:

This comment shows the perceived inadequacy of the program’s vetting process for its preceptors. “The program demonstrated numerous active physician preceptors who were specialty board-certified in an area other than their area of instruction for pediatrics, women’s health, and behavioral health. The program stated its verification process included review of the patient population, ability to practice at the site including verification of licensure and board certification, review of faculty generated site visits and student generated evaluation of the site and preceptor.” 

“The program failed to present a compelling reason, acceptable to the commission, for the use of physicians who were not board certified in their area of instruction.”

“While the program described its process for evaluation of physicians who were not board certified in their area of instruction, the program did not provide a compelling reason, unique to the program and acceptable to the ARC-PA, for not meeting the standard.”

“The program stated it used these non-board-certified physicians because of the shortage of physicians in the region and many of these physicians practice in health care shortage areas which aligns with the mission of the program. The program currently has more than 300 active preceptors available for SCPEs and did not address why students could not complete the SCPEs with board-certified physician preceptors.” This description of a “shortage” was inadequate to the Commission. I’ve seen that several times. The Commission’s question was: if there are more than 300 active preceptors, why could the program not use preceptors that were board-certified in the correct field? 

“The program did not provide any documentation of how it determined the current physician preceptors who were not board-certified in their area of instruction were qualified to meet the learning outcomes for Pediatrics, Women’s Health, and Behavioral Health rotations.”

“...the program did not provide evidence of a defined process consistently used by the program by which preceptors not board certified in their area of instruction were deemed appropriate for the specified area of instruction.”

As we can see from these examples, the Commission looks seriously at the board certifications of preceptors. If a program does not use board-certified preceptors in the field of students’ learning, the program must be prepared to thoroughly and convincingly justify the Commission of its vetting process. 

Strategies for Compliance

1. Conduct quality assurance to ensure that the program has 100% board-certified physicians acting as preceptors. This is one of the first questions I ask any of my clients to confirm.

2. Systematically eliminate individuals who were “grandfathered in,” such as non-board-certified surgeons, and emergency medicine providers. Or, if you wish to keep using those providers without going through the vetting process to establish their validity, designate a PA as the preceptor of record.

3. Develop learning outcomes and preceptor evaluation tools that are perfectly cross-walked in each of the required disciplines. This will enable measurement of each required clerkship area as defined by the standards.

4. Develop a vetting process for all preceptors that incorporates an evidence based approach. 

5. Request funding from your institution to access board certification documentation for inclusion into your files. This should include the actual certificate copy. I will note here that many programs struggle to collect board-certificate copies. If you’re looking at your visit two years from now, ask for funding now, because you may need to pay for some of these databases. I’ve seen some programs spending a fair amount of money to retrieve all such documentation.

Risk Mitigation Strategies

1. Replace all non-board-certified physicians with PA/NPs who practice in that specialty. A word about this, however: the murky area has been whether the Commission will accept an NP that doesn’t have a specialty certificate for that specific area. I have seen inconsistent results.

2. For programs that do not have traditional rotations, such as pediatrics, women’s health, and behavioral medicine, which are instead integrated with primary care rotations, consider delineating a short specific clinical rotation (of perhaps two weeks) with the opportunity to rotate with a board-certified provider in that area to supplement the students’ experience. Let’s say you have a long, primary care practice rotation but don’t have a pediatrics-specific rotation. Find an opportunity for at least a focused rotation with an individual preceptor that the ARC-PA will accept.

3. If eliminating all non-board-certified preceptors is impossible, then develop a comprehensive vetting process to validate why these preceptors are sufficient to ensure that students meet learning outcomes. 

Next time in our blog…

Despite everything we have discussed about the demands of Standard B3.06, the real world doesn’t always comply. Circumstances may align under which there simply is no choice but to use non-board-certified physicians as your preceptors. However, for the Commission to accept this, you must put your preceptors through convincing vetting and show proof. Therefore, next week, we’ll wrap up our Standard B3.06 discussion by considering my suggestions for such a vetting process.