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Frequently Asked Questions (FAQ)

Expedited Licensing through the Interstate Medical Licensing Compact

Can a physician apply for more than one license at a time through the compact?

Yes, but all states chosen must have adopted the compact. A physician practicing under the compact is bound to comply with the statutes, rules, and regulations of each compact state wherein he/she chooses to practice medicine.

How can I participate in commission meetings or decisions?

Commission meetings (including meetings of the executive committee) are publicized through the participating states. The compact commission shares meeting notices and press releases with the federation of state medical boards and the national center for interstate compacts/council of state governments. Compact commission meetings are open to the public and include a telephone conference call for individuals who cannot attend in person. It’s possible that video conferencing also might be used in the future.
 

How long does a "home state" certification last once it’s sent to the commission?

The letter of qualification is valid for one year.

Is the compact in operational now?

Yes. Member states have begun issuing licenses. However, Washington’s Legislation does not go into effect until 7/23/2017. Check back around this time to apply for your Washington Compact License or follow us on Twitter and like us on Facebook for immediate notification of when Washington will begin issuing IMLC licenses.

What are the responsibilities of the "home state" in licensing?

Conducting the review of the applying physician’s qualifications under terms of the compact; informing the compact commission of the results.

What are the responsibilities of the IMLC commission in licensing?

Mostly, the compact commission will act as an information exchange between a home state/state of principal license and a receiving state. The IMLC also envisions the compact commission as the entity that collects fees from physicians and transfers licensure fees to receiving states.

What are the responsibilities of the physician in the licensing process?

Submitting an application and paying whatever fees are assessed. It’s also possible thephysician might be asked by the home state to provide evidence to verify state of principal license.

What are the responsibilities of the “receiving state” in licensing?

Issuing licenses to qualified physicians once notified by the compact commission and depositing license fees when received from the compact commission. State medical boards participating in the compact are required to share complaint/investigative information with each other.

What does the IMLC do?

It creates a new “expedited” pathway to state licensure for experienced physicians who have outstanding practice histories. It sets the qualifications for licensure and outlines the process for physicians to apply and receive licenses in states where they’re not currently licensed. The IMLC also details the role of the governing IMLC commission and sets limits on what the commission can do.

What if a physician wants to add another license later? Does the process repeat?

Under the IMLC, the process would repeat exactly as it operated the first time. However, thecompact commission could write rules about this subject. (None are contemplated at this time.)

What is an interstate compact?

An interstate compact is a legal agreement among states. In the case of the interstate medical licensure compact (IMLC or “the compact”), it’s an agreement that addresses the licensing of physicians across state lines.

What will a physician have to do to get a license through the compact?

A physician must apply to a state within the compact where the physician already has a license. That state becomes the physician’s state of principal license or “home state.” The home state reviews the physician’s qualifications and shares the results with the compact commission. The compact commissionthen notifies the “receiving state(s)” within the compact where the physician wishes to be licensed.

Where did the IMLC come from?

A group of state medical board executives, administrators and attorneys wrote the language of the IMLC in 2013 and 2014. The national federation of state medical boards (FSMB) also was involved and helped facilitate the creation of the compact. But no one “owns” the IMLC.

Who is in charge of the compact?

The compact creates a commission (compact commission) made up of two representatives from each adopting state. Commissioners must be either:

  1. A physician member of a medical or osteopathic physician licensing board.
  2. A public member of such a board.
  3. An executive director or administrator of such a board.

If a state has only one medical board, then both commissioners must come from that board. But if it has two boards, a medical board, and an osteopathic board, then each board gets one seat.

File a Complaint against an MD or PA

Can a physician or physician assistant refuse to give me copies of my medical records because of an outstanding balance?

A physician or physician assistant may charge a search and copying fee before the records are released, but cannot withhold records because of an outstanding balance on your account.

Can I be sued for filing a report?

A law suit can be filed by anyone for anything at any time. The immunity Laws / Rules give a complainant who files a complaint in good faith an affirmative defense against a law suit.

Can I make a complaint without giving my name?

Complaints that do not include the name of the person involved are sometimes difficult to investigate. As a consumer of health care or a health care provider, you have whistleblower protection; RCW 43.70.075 and WAC 246.15, your name will not be disclosed without your permission. Your consent may be necessary in order to question the physician, physician assistant or witnesses and to secure your medical records if they are needed for the investigation. In that event, you would be asked to complete a release of confidentiality and would be given the necessary information to make a decision.

Can the Medical Commission send a physician or physician assistant to jail?

No, the Medical Commission does not have the authority to invoke or enforce criminal or civil penalties. Authority is limited to taking corrective action against a physician or physician assistants license in order to prevent harm and protect the health and safety of the public.

Do I have to be the patient in order to file a complaint?

Anyone who has knowledge of a physician or physician assistant’s unprofessional conduct may file a report.

How do I find out how my complaint is progressing?

Details of an ongoing investigation will not be given, but you can call to receive an update on the general status of your complaint. The Medical Commission has guidelines as to how long a complaint can take in each step of the disciplinary process. However, please remember that due to the complex legal and medical issues involved, the disciplinary process can be lengthy. Your patience is appreciated.

How long will it take to resolve my complaint?

The time will vary depending on the nature of the complaint, the complexity of the case and the cooperation of all parties involved. Patience is needed when dealing with the many legal and health care investigations. Cases may take as little as a few weeks or, in some cases, as long as two years.

If I file a complaint against a physician or physician assistant and it results in disciplinary action, what kind of compensation can I get from the Medical Commission or the individual?

Under some circumstances, the Medical Commission can require a physician or physician assistant to refund fees collected from the consumer. However, the Medical Commission does not have jurisdiction in matters of malpractice compensation. Malpractice must be pursued in civil court.

Is there a time limit to file a complaint?

No. There is no statutory time limit in which to file a complaint; however, it is possible that a case cannot be acted upon because the information needed to make a decision is no longer available. It is best to report as soon as possible so the records can be obtained and potential witnesses can be located. It is a good idea to make a written note of the circumstances soon after the experience so facts are not forgotten. When submitting a complaint, be as specific as you can with the facts and dates.

My physician or physician assistant is rude. Is there anything I can do about it?

Rudeness is not a violation of the law. However, actions that mislead, harm or are of a sexual nature are considered to be unprofessional conduct and should be reported to the Medical Commission. If you are simply not comfortable with your doctor, another option may be to find one more suitable for you.

My physician or physician assistant told me they don’t want me as a patient anymore. Can they do that?

Yes, a medical provider can terminate the physician/patient relationship just as the patient can end the relationship it they feel it is no longer mutually productive.  The provider cannot abandon a patient and generally must provide 30 days of emergency care or until the patient established with a new provider.

Should I file a malpractice suit or just report a physician or physician assistant?

This is a decision that you must make. You may seek legal advice and file a report with the Medical Commission at the same time.

What are examples of actions the Medical Commission cannot take?
  • Help you bring suit against a physician or physician assistant for money.
  • Handle a fee dispute between you and your physician or physician assistant.
  • Discipline a physician or physician assistant who is not required to be regulated by the Medical Quality Assurance Commission.
  • Return any money you feel you are owed.
  • Resolve questions about disability compensation or insurance reimbursement.
  • Resolve issues involving rudeness by a physician or physician assistant or their staff.
  • Resolve issues involving typing errors, miscommunication, or a mistake of facts.
What happens if the physician, physician assistant or facility doesn’t respond to the Medical Commission concerning my complaint?

Failing to cooperate with an investigation is a violation of the law. The Medical Commission can discipline a physician or physician assistant for not responding.

What part will I play after filing a complaint?

You likely be asked to sign a release to waive your right to confidentiality so that your complaint can be investigated. Additional information may be asked of you, either by letter or interview during the investigation. You may be required to testify if a formal hearing is necessary.

Who do I contact if I disagree with my billing statement?

Contact the physician or physician assistant or your insurance company. The Department and boards and commissions do not investigate billing disputes unless fraud appears to be involved.

General Licensing

Does my application need reviewing by the Commission before approval?

Approval of the routine applications (those with no derogatory information) can take approximately three to five business days for approval in the office by Commission staff. Those applications with minor derogatory information (considered non-routine) can be reviewed by a member of the Commission and require an additional two weeks for review. Those applications with serious issues or current/prior disciplinary action must be reviewed by the full Commission and can take anywhere from three to six months (or longer depending on the issues). Please note: if grounds for denial exist, any application the Commission receives may not be withdrawn.

How can I meet the requirement in order to sign the AIDS training affidavit?

You can meet this requirement by either attending a formal training course, self-directed activities like journal reading, or even treatment of AIDS patients. This is to ensure you have current knowledge on blood-borne contagious diseases.

How do I get an application?

You can download your application from our Application and Frms page.

How should I pay the application, renewal, or other fee?

The Department of Health accepts personal checks, cashier’s checks, or money orders. All checks and money ordersneed paymentin U.S.funds. At this time, the Department cannot accept payment by credit or debit card. You can mail the payment to:

Department of Health
P.O.BOX 1099
Olympia WA 98507-1099
Why do I have to provide you with my Social Security Number?

Federal legislation mandates that any government entity that issues a license (driver’s license, business license, professional license) must collect a social security number. Compliance is mandatory for the issuance of a license. For those individuals coming from outside the country, you will have to work with the Immigration and Naturalization Service to obtain the appropriate visa that will allow the Social Security Administration to issue you a social security number.

Why is my first license Valid for less than a year?

Your first license is valid only until your first birthday after issuance, not for a full calendar year. After your first renewal of that license, you will begin renewing in the two-year renewal cycle established for your profession. WAC 246-12-020.

Physician Assistant (PA)

How do I have my license verified to another state board?

To have a written verification of your license sent to another state, you must submit the request in writing. Your request should include your name, license number, and the name and address of the state board where the verification should be sent. This can sent via email, faxed or mailed. These requests are processed within five business days of having received the request.
 

I did not receive my renewal notice. What do I do?

It is the responsibility of the licensee to renew their license, whether the notice has been received or not. (WAC 246-12-030)The license is expired if it is not renewed on or before the expiration date. Any renewal received by the department that is postmarked or presented after midnight on the expiration date is late and the licensee is required to pay the late fee. There is no grace period for renewal of a license.

I haven’t passed the NCCPA initial examination yet. Do you have some type of permit?

We do have an interim permit that can be requested when the physician assistant application is submitted. (WAC 246-918-050) The interim permit is for individuals who have graduated from an accredited commission approved physician assistant program and who have not yet taken or passed the NCCPA examination. The interim permit is only valid for one year from the completion of a commission approved physician assistant training program.  If you have not passed the NCCPA by the time it expires, you CANNOT practice after the expiration date. Please note: without NCCPA certification, you will not be approved for a remote site setting.

I want to work with an Osteopath physician. Do I still apply through you?

No. Physician assistants who want an Osteopath physician their primary physician must apply through the Osteopathic Board.

Once I apply, how long does it take to get a license?

The average processing time for a license application is approximately four to six weeks.

  1. A Commission licensing representative will contact you with a status update via email within one to two weeks of receiving the complete application and fee;
  2. It is your responsibility to request all verifications required from the primary sources.
  3. After receiving the application and fee, if required,  we will mail you the FBI fingerprint packet, which you must complete at your local law enforcement office.
  4. Once all documents are received and background checks are cleared, our staff will review the completed application and issue your license.
  5. We will email you when the license is issued but you may check your status at any time on the Provider Credential Search site.

The majority of our applications take 45 days to complete the licensing process, but this can be reduced by following the best practices and regularly communicating with your licensing representative. If you have any other questions please contact us via email: medical.commission@doh.wa.gov or at 360-236-2750 option #1.

Once I have my license, can I go ahead and practice?

No, you must have a Delegation Agreement approved by the Commission prior to being able to commence practice. (RCW 18.71A.030 and .040) You can get the Delegation agreement forms on the bottom of the Applications and Forms page. This can be submitted for review and approval at any time. The Medical Commission can only approve your agreement once the license or interim permit has been issued. Average processing time for reviewing a delegation agreement is approximately 30 business days. It may take longer if you are also requesting a remote site.

What exactly is a remote site setting?

A remote site is either a setting physically separate from the physician’s primary place for meeting patients OR a setting where the physician will be present less that 25 percent of the physician assistant’s practice time. Whether a physician assistant is utilized across town or next door, if it is physically separate, it’s a remote site. In addition, if a physician assistant is employed full time at 40 hours perweek but the physician is on site less than 10 of those hours, it becomes a remote site. (WAC 246-918-120
 

What should I do if I want to quit working for a physician?

Physician assistants and/or their supervising or sponsoring physician are required to submit a letter notifying us that their working relationship has been terminated. This can be emailed to the Medical Commission. Until we have received such notification, the Delegation Agreement remains in effect. (WAC 246-918-055)

Physician and Surgeon (MD)

Do you have a locum tenens license or some type of temporary permit?

We do not have a locum tenens license. We do have a temporary permit. It must, however, be requested in conjunction with a full application. Please these items to process the request: full license application, temporary permit request, fees, and state license verifications. The applicant must also meet the eligibility requirements applicants as listed in (WAC 246-919-390) Once approved, temporary permits are issued for a period of 90 days and expire either on the 90th day, upon the approval of the full license application, OR upon initiation of an investigation of the applicant. (WAC 246-919-395) Please note: it often occurs that the last document needed to issue a temporary permit is also the last document to complete the full license, but fees are NON-REFUNDABLE. (WAC 246-12-340)

How do I request a license verification letter for another state board?

Go to www.veridoc.org and follow the instructions to create and send verification. Veridoc sends verifications immediately. The fee is $60.00.

I did not receive my renewal notice. What do I do?

It is the responsibility of the licensee to renew their license, whether we receive the noticeor not. (WAC 246-12-030) The license expires unless renewal takes place on or before the expiration date.  (WAC 246-12-030) Any renewal the department receives after midnight (postmark or in-person) is late and the licensee must pay the late fee.

There is no grace period for renewal of a license.

I have been out of practice for more than 3 years. Are there additional requirements I would be required to do by the Medical Commission?

Depending on the circumstances and the time you have been out of the practice, the Commission may require an individual to pass the Special Purpose Examination (SPEX) given by the Federation of State Medical Boards. (WAC 246-919-370) Generally, if you havebeen out of practice for a period of 3 years or longer, the Commission will need to see some kind of evidence that you have kept current with medical knowledge.

I went to an approved medical school and received a DO degree. Can the Medical Commission still license me?

No, law specifically prohibits this. (RCW 18.71.055)

You can visit the Osteopathic webpage for licensing information. 

Once I apply, how long does it take to get a license?

The average processing time for a license application is 8 to 20 weeks.

When can I start accumulating hours?

You may start accumulating CME hours upon first renewal up through your 2nd renewal cycle. You will need to attest to the completed 200 hours every four years.

Where can I reference the specific rules pertaining to continuing medical education requirements for physicians?

Please refer to Washington Administrative Code WAC 246-919-430 through 470 regarding continuing medical education (CME) requirements for physicians. Please also refer to WAC 246-12, Administrative Procedures and Requirements for Credentialed Health Care Providers. Part 7 of this chapter specifically addresses CME, when it is required, how to prove compliance, auditing, acceptable auditing documentation, exemptions, how credit hours are determined, carrying over CME credits, and taking the same course more than once during a reporting cycle. The requirements of WAC 246-12 apply to all health care practitioners; use will be in conjunction with WAC 246-919-430, for physicians.

Who can accredit or certify a facility for safe and effective analgesia and anesthesia administration in office-based surgical settings?

In accordance with WAC 246-919-601(5), below are the entities approved by the Medical Commission to accredit or certify a facility for safe and effective analgesia and anesthesia administration in office-based surgical settings:

  • American Association for Accreditation of Ambulatory Surgical Facilities
  • Accreditation Association for Ambulatory Health Care
  • Institute for Medical Quality
  • National Abortion Federation
  • Planned Parenthood of Greater Washington and North Idaho
  • The Joint Commission

Physician Limited License

Once approved, for how long is the license valid?

Your limited license is issued specific to a particular program and so the program dates are the issuance and expiration dates -- such as a residency year beginning July 1, 2002 and ending June 30, 2003; these would become the issue and expire dates.

Once I apply, how long does it take to get a license?

The average processing time for a license application is about four weeks

What are the various types of limited licenses?
  1. Institutional: For employment with either the Department of Corrections or the Department of Social and Health Services. Applicants need a license to practice medicine in another state or Canada, and have completed a period of postgraduate medical training in the U.S. or Canada. This license allows a physician to practice medicine only on patients, residents, or inmates.
  2. City/County: For employment with a city or county health department. If the position is a contracted position and the individual would not be a city or county employee, it DOES NOT qualify for this limited license. Applicants need a license to practice medicine in another state or Canada, and have completed a period of postgraduate medical training in the U.S. or Canada.  This license allows a physician to practice medicine only in connection with their duties in employment with the city or county health department.
  3. Residency: For those individuals who are accepted into a residency program within this state.
  4. Teaching/Research: For employment as a teaching-research member of an institution’s instructional staff. Applicants need a licensed to practice medicine in their country of origin.
  5. Fellowship: For those individuals who have been accepted into a fellowship program within this state. Applicants need a license to practice medicine in their country of origin. This license is for one year and is only renewable one time (for a total of two years).

Suicide Assessment, Treatment, and Management Training

Are employees of a community mental health agency exempt from the training requirement?

According to RCW 43.70.442(12), an employee of a community mental health agency licensed under chapter 71.24 RCW or a chemical dependency program certified under chapter 70.96 RCW is exempt if he or she receives at least six hours of training in suicide assessment, treatment, and management from his or her employer. The training may be in one six-hour block or may be spread among shorter training sessions at the employer’s discretion.

Are government employees exempt from the training requirement?

According to RCW 43.70.442(11), a state or local government employee is exempt from the training requirement if he or she receives at least six hours of training in suicide assessment, treatment, and management from his or her employer.The training may be in one six-hour block or may be spread among shorter training sessions at the employer’s discretion.The statute did not exempt federal employees

Are residents required to take the training?

A resident holding a limited license under RCW 18.71.095(3) is not required to take the training during the time they hold the limited license. However, once a residentholdsa full license he/she would be required to take the one-timetraining.
 

How do I show the Commission that I have completed the training?

There is no requirement to send proof of completion of the training to the Commission. The Commission does not conduct audits for completion of required continuing medical education and will not conduct audits for completion of suicide prevention training. However, during the course of investigating a complaint, the Commission may request proof of completion of CME and completion of a suicide prevention training course. 

If you have further questions or concerns please contact the Commission’s Program Manager, Daidria Underwood, at (360) 236-2727 or daidria.underwood@doh.wa.gov.

If you would like to be notified of the Commission’s rulemaking activities please subscribe to our Rules GovDelivery.
 

How many hours of training am I required to take?

According to RCW 43.70.442(5)(c) you must take a one-time six hours of suicide assessment, treatment, and management training.

What does "brief or limited patient contact" mean?

RCW 43.70.442 permits a disciplining authoritymay exempt a professional from the training requirements if the professional “has only brief or limited patient contact.” The Commission passed a rule exempting allopathic physicians and physician assistants from the training requirement if thephysician or physician assistant “has only brief or limited patient contact, or no patient contact.” The rule does not define “brief or limited patient contact.” Each allopathic physician or physician assistant will have to determine whether he or she meets this exemption.

When do I have to take the training?

The training mustbe taken by the end of the first full CME reporting period after January 1, 2016 or during the first full CME reporting period after initial licensure, whichever is later. For example, if an MD's reporting period expires in 2016 heor she will have until their birthday in 2020 to take the training.If a PA’sreporting period expires in 2016 heor she will have until their birthday in 2018 to take the training.

Where can I find a list of trainings?

You must take training listed onthe Department of Health model list in order to satisfy the requirement.The model list can be found here on the DOH website.

Who is required to take Suicide Assessment, Treatment, and Management Training?

RCW 43.70.442 requires many licensed health professionals, including physicians and physician assistants, to complete suicide prevention training. The Medical Quality Assurance Commission (Commission) recently passed rules setting forth the statutory requirements and exempting allopathic physicians and physician assistants who have brief or limitedcontact with patients.

Will my psychiatry residency fulfill the training requirement?

No. Residency training does not fulfill the training requirement, no matter the specialty.

Pain Management Rule

Are opioid prescriptions written at discharge exempt from the new rules?

Yes. The new opioid prescribing rules do not apply to inpatients from the second they are past 24 hours of being admitted to the point of discharge. Discharge medications for an inpatient would be exempt from these rules.

Can my treating MD or PA refuse to refill my existing prescription?

Your provider must document any reason for altering an existing treatment plan and discuss any plans to taper your dosage with you.

Do MDs and PAs have to register with the Prescription Monitoring Program (PMP)?

Yes. If you prescribe opioids in Washington you must register with the PMP or demonstrate proof of access to the program. Learn how to register here.

How do I stay informed about this process or get involved?

We have created an email update to keep people informed. Sign up to receive updates on rulemaking delivered to your inbox. You can send us specific questions on the pain management rules for physicians and physician or request an educational presentation for your organization through the Medical Commission Speaker's Bureau.

I have chronic pain that is currently being managed with opioids. Will these rules impact me?

No. Rules created in 2012 govern the management of chronic, non-cancer pain. Rules for MDs cover WAC 246-919-850 through 863 and PAs WAC 246-918-800 through 813.

If I am transitioning into chronic pain management can opioids still be prescribed?

New patients entering a chronic pain phase must be reevaluated by their chronic pain provider. Providers must identify previous medications received and periodically review the course of treatment.

Is there a Continuing Medical Education (CME) requirement if I prescribe opioids?

Yes. If you prescribe opioids in Washington you must complete a continuing medical education course. The course is one-time for at least one-hour. It must be completed by the end of your first full CME reporting period after January 1, 2019. Or, it may be reported during your first full CME reporting period after getting your license.

What does the bill require?

The bill requires five boards and commissions to adopt rules related to pain management by late fall 2018. These boards and commissions have separate disciplining and rulemaking authority. The legislation does not require one set of rules for all professions.

What is the “inappropriate treatment of pain?”

The rules for prescribing opioids state, “The inappropriate treatment of pain is a departure from standards of practice.” For the purpose of these rules that includes:

  • Nontreatment;
  • Undertreatment;
  • Overtreatment, and;
  • The continued use of ineffective treatments.
What professions are included in the bill?

The legislation specifically names the Medical Quality Assurance Commission (MQAC), Nursing Care Quality Assurance Commission (NCQAC), Board of Osteopathic Medicine and Surgery (BOMS), Dental Quality Assurance Commission (DQAC), and Podiatric Medical Board (PMB) . The professions include: Medical physicians and medical physician assistants, advanced registered nurse practitioners, osteopathic physicians and osteopathic physician assistants, dentists, and podiatrists.

There are other professions with prescribing or dispensing authority, such as optometrists, veterinarians and pharmacists. The legislation did not require those professions to adopt rules on this subject.

What should I do if my doctor doesn’t want to treat me with opioids?

Your provider has the right to discontinue treatment, just as you, the patient, can decide to no longer see the provider. Your doctor should refer you to a pain management specialist or a new primary care physician. Your provider should give you a 30 day notice and 30 days worth of medications before discontinuing treatment.

When should I check the data in the Prescription Monitoring Program (PMP)?

PMP query must be completed at points in the process:

  • At the first refill or renewal of an opioid prescription;
  • At each pain treatment transition phase;
  • Periodically based on the patients risk level;
  • For episodic care of a patient currently on opioids for chronic pain.
Where can I find a risk assessment tool?

The Medical Commission does not maintain a list of these tools. However, any tool that is professionally developed would meet the requirement of the rule. Appendix B (pg.59) of the AMDG Interagency Guideline on Prescribing Opioids for Pain has a list of validated tools for screening and assessment.

Where can I find information or a list of courses that will meet the one-hour CME requirement?

There are no specific requirements in rule as to what the training must contain other than it be regarding best practices in opioid prescribing so any training that offers CME, is at least one-hour in length, and is about opioid prescribing best practices will fulfill the requirement.

Will these rules impact all types of pain management?

No. These rules do not apply when treating patients with cancer related pain, palliative, hospice, end-of -life care, inpatient hospital patients, or procedural pre-medications.

There are documentation and assessment requirements for other types of pain including: acute (0-6 weeks), perioperative (surrounding the performance of surgery), subacute (6 to 12-weeks) and chronic (months or years).