BILL ANALYSIS                                                                                                                                                                                                    







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        |Hearing Date:April 5, 2010         |Bill No:SB                         |
        |                                   |1410                               |
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                      SENATE COMMITTEE ON BUSINESS, PROFESSIONS 
                               AND ECONOMIC DEVELOPMENT
                         Senator Gloria Negrete McLeod, Chair

                         Bill No:        SB 1410Author:Cedillo
                  As Introduced:     February 19, 2010    Fiscal:Yes

        
        SUBJECT:  Medicine:  licensure examinations.
        
        SUMMARY:  This bill is an urgency measure.  Deletes the existing  
        limitation that an applicant for a physician's and surgeon's  
        certificate can only make  four   attempts  to obtain a passing score on  
        Part III of the United States Medical Licensing Examination (USMLE),  
        and would make this change retroactive to January 1, 2007.  Requires  
        the Medical Board of California (MBC) to accept as a passing score  
        from an applicant the passing score that was adopted by the MBC, and  
        in effect on the date an applicant registered for that examination or  
        for part of the examination, and would make this requirement  
        retroactive to January 1, 2007.  Requires the MBC to adopt a formal  
        process for determining whether to adopt recommended scores from the  
        Federation of State Medical Boards.

        Existing law:
        
        1) Establishes the MBC to regulate physicians and surgeons.  Requires  
           an applicant for a physician and surgeon certificate to take  
           examinations designed to ascertain the applicant's fitness to  
           practice medicine.  States that examinations may be conducted by  
           the MBC, and allows the MBC to make such arrangements with  
           organizations furnishing examination material as it deems  
           desirable.

        2) States that applicants may elect to take written examinations in  
           separate parts.  Requires that a passing score is required for the  
           entire examination or for each part of an examination, as  
           established by  resolution  of the MBC.

        3) Requires an applicant to obtain a passing score on Part III of the  





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           USMLE  within   not   more   than   four   attempts  in order to be eligible  
           for a physician's and surgeon's certificate.  States that an  
           applicant who obtains a passing score on Part III of the USMLE  in   
            more   than   four   attempts  and who meets specified requirements is  
           eligible to be considered for an issuance of a physician's and  
           surgeon's certificate.

        4) States that a passing score on a written examination shall be valid  
           for a period of ten years from the month of the examination for  
           purposes of qualification for licensure in California.  Indicates  
           that this period of validity may be extended by the MBC for good  
           cause and for time spent in post-graduate program, as specified.

        

        This bill:

        1) Deletes the existing limitation that an applicant for a physician's  
           and surgeon's certificate can only make  four   attempts to obtain a  
           passing score on Part III of the United States Medical Licensing  
           Examination (USMLE), and would make this change retroactive to  
           January 1, 2007. 

        2) Deletes existing provision that allowed an applicant who obtains a  
           passing score on Part III of the USMLE  in   more   than   four   attempts   
           and who meets other specified requirements to be eligible to be  
           considered for an issuance of a physician's and surgeon's  
           certificate.  Makes this change retroactive to January 1, 2007.

        3) Requires the MBC to accept as a passing score on an examination, or  
           part of an examination, the passing score that was adopted by the  
           MBC and in effect on the date the applicant registered for that  
           examination or part of the examination.  Makes this provision apply  
           retroactively to January 1, 2007.

        4) Requires the MBC to adopt a formal process for determining whether  
           to adopt recommended passing scores from the Federation of State  
           Medical Boards (FSMB).

        5) States legislative findings and declarations on the USMLE  
           examinations. 

        FISCAL EFFECT:  Unknown.  This bill has been keyed "fiscal" by  
        Legislative Counsel.

        COMMENTS:





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        1.Purpose.  The  Author  is the Sponsor of this measure.  The Author  
          points out that the MBC has no formal procedure for adopting new  
          passing scores for the USMLE and that has proved to be problematic.   
          The lack of a formal adoption process combined with the three-month  
          window provided to take the examination, after registering, has  
          created confusion as the MBC may increase the recommended passing  
          score  at   any   time  without public record, input, or notification to  
          applicants that have already registered for the examination.  Thus,  
          highly qualified physicians have been denied licensure because of  
          the lack of a formalized process.  Additionally, failing to pass the  
          USMLE under an arbitrary cap on the number of attempts does not  
          translate into a lack of competency in providing high-quality  
          medical care.  Furthermore, existing law and the MBC procedure does  
          not allow consideration for learning disabilities, a history of poor  
          performance on standardized tests, hardships, or other variables  
          that may impede the ability of an individual to pass the examination  
          within the current standards.  There is no mechanism for the MBC to  
          consider individuals or extending circumstances that may have  
          contributed to poor performance on the exam.

        2.Background.

           a)   Examinations Requirements.  Existing law requires an applicant  
             for a physician and surgeon certificate to take examinations  
             designed to ascertain the applicant's fitness to practice  
             medicine.  These examinations may be taken in separate parts.   
             Examinations may be conducted by the MBC under a uniform  
             examination system, or MBC may designate other written  
             examinations that it determines are equivalent.  The MBC  
             recognizes several written examinations for licensure, including  
             those of the Federation Licensing Examination, the National Board  
             of Medical Examiners (NBME), Medical Council of Canada, and the  
             USMLE.  The USMLE is sponsored by the Federation of State Medical  
             Boards of the United States (FSMB) and the NBME, and consists of  
             three parts.  Part I assesses whether applicants understand and  
             can apply important concepts of the sciences basic to the  
             practice of medicine, with special emphasis on principles and  
             mechanisms underlying health, disease, and modes of therapy.   
             Part II assesses whether applicants can apply medical knowledge,  
             skills, and understanding of clinical science essential for the  
             provision of patient care under supervision, and includes  
             emphasis on health promotion and disease prevention.  Part III  
             assesses whether applicants can apply medical knowledge and  
             understanding of biomedical and clinical science essential for  
             the unsupervised practice of medicine, with emphasis on patient  





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             management in ambulatory settings.

           The FSMB, which administers the USMLE, establishes a recommended  
             passing score for each of the examinations that a state may use  
             to grade its applicants.  These scores are reviewed periodically,  
             and the changes are posted on the USMLE website.  Since the early  
             1990's, the MBC had adopted the USMLE's recommended score as the  
             passing score in California for these examinations.  In addition,  
             Section 2177 of the Business and Professions Code (Section 2177)  
             requires that a passing score is required for an entire  
             examination or for each part of an examination, as established by  
             resolution of the MBC.  Furthermore, for Part III of the  
             examination, a passing score must be obtained within not more  
             than four attempts.  However, it also provides that an applicant  
             can obtain a passing score on Part III in more than four attempts  
             if they meet other requirements as specified.

           b)   Part III of the USMLE Examination.  This bill deletes existing  
             requirement that an applicant for a physician's and surgeon's  
             certificate obtain a passing score on Part III of the USMLE  
             within not more that four attempts, and instead gives an  
             applicant an  unlimited  opportunity to take the examination.  This  
             four attempts limitation was established by 
            AB 1796  (Bermudez, Chapter 843, Statutes of 2006).  According to  
             the MBC, which sponsored AB 1796, the limitation was necessary to  
             allow the MBC to better assess applicants' ability to practice  
             medicine safely and assure that they are current in their medical  
             knowledge at the time they receive their initial license.  In  
             2007,  SB 1048  (Committee on Business, Professions and Economic  
             Development, Chapter 588, Statutes of 2007), included provisions  
             that allows an applicant who obtains a passing score on Part III  
             of the USMLE in more than four attempts to be considered for a  
             certificate if the applicant meets all of the following criteria:  
              1) He or she holds an unlimited and unrestricted license as a  
             physician and surgeon in another state and has held that license  
             continuously for a minimum of four years prior to the date of  
             application; 2) He or she is certified by a specialty board that  
             is a member board of the American Board of Medical Specialties;  
             3) He or she is not subject to denial of licensure, as specified;  
             4) He or she has not graduated from a medical school that has  
             been disapproved by the MBC or that does not provide a resident  
             course of instruction; 5) He or she has graduated from a medical  
             school recognized by the MBC, as specified, and, 6) He or she has  
             not been the subject of a disciplinary action by a medical  
             licensing authority or of an adverse judgment or settlement  
             resulting from the practice of medicine that, as determined by  





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             the MBC, constitutes a pattern of negligence or incompetence.   
             Since this bill allows for unlimited opportunities to take Part  
             III of the examination, these requirements have also been  
             eliminated.

           c)   Recent Court Decision on Part III of the USMLE Examination.   
             On March 1, 2010, in  Marquez v. Medical Board of California  (182  
             Cal. App. 4th 548), the Third Appellate District Court ordered  
             the MBC to establish  by   formal   resolution  the passing scores for  
             the USMLE.  At issue in this case is whether Section 2177  
             requires the MBC to establish by formal resolution the passing  
             score for examinations used to license individuals to practice  
             medicine in California.  The facts indicate that the Ms. Marquez,  
             a graduate of Stanford University and the University of Rochester  
             School of Medicine and Dentistry, registered on the USMLE website  
             to take Part III of the examination on March 8, 2008.  The  
             passing score disclosed on the USMLE Website at the time of her  
             registration was 184.  On April 15, 2008, a notice appeared on  
             the USMLE Website stating that the minimum passing score for Part  
             III had been raised from 184 to 187, and that this passing score  
             would apply to Part III examinations administered on or after May  
             1, 2008.  Ms. Marquez took the May 13, 2008 examination and  
             obtained a score of 184.  Since this was the fourth time Ms.  
             Marquez took Part III of the examination, she was informed by the  
             MBC that she was not eligible for a license.  Ms. Marquez sued  
             the MBC asserting among other things that the MBC has not  
             satisfied the requirements of Section 2177, which states that "a  
             passing score is required for an entire examination or for each  
             part of an examination, as established by  resolution  of the  
             Division of Licensing."  In holding that the MBC cannot  
             implicitly adopt the USMLE score as the passing score without  
             adopting a formal resolution, the court went through a lengthy  
             discussion of the history of the USMLE, the delegation to the  
             FSMB  by the MBC, all aspects of the written examination process,  
             including the processing of applications and scoring.  The Court  
             pointed out that "the Legislature used the term "resolution in  
             Section 2177 to require the Board to adopt a passing score by  
             means of a  formal, memorialized public vote  .  This single,  
             unambiguous statutory burden obviously serves to keep the Board  
             accountable to the Legislature, the medical profession, medical  
             license applicants, and the public, and it prevents the Board  
             from delegating this responsibility to anyone else."

           On January 2009, however, the MBC had already adopted a formal  
             resolution to reaffirm its past practice of accepting the passing  
             score set by the FSMB as its own passing score on all steps of  





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             the USMLE.  Furthermore, according to the MBC, Ms. Marquez was  
             granted a physician and surgeon certificate after she retook Part  
             III of the examination.

        3.Prior Related Legislation.
        
            a)   AB 1796  (Bermudez, Chapter 843, Statutes of 2006) required an  
             applicant for a physician and surgeon certificate to obtain a  
             passing score on Part III of the USMLE within four attempts.

            b)   SB 1048  (Committee on Business, Professions and Economic  
             Development, Chapter 588, Statutes of 2007) an omnibus bill,  
             allowed an applicant who obtains a passing score on Part III of  
             the USMLE on more than four attempts if specified requirements  
             are met.

         4.Policy Issue  :  Should there be a limitation on the number of times  
          an applicant can retake Part III of the USMLE?   The justification  
          by the MBC for placing a limitation on the number of times an  
          applicant could retake Part III of the USMLE was to "better assess  
          the applicants' ability to practice medicine safely and assure they  
          are current in their medical knowledge at the time they receive the  
          initial license."  Should their still be concerns about the 

        competency of the physician and surgeon who continue to retake Part  
          III of the USMLE without any limitation?    

        
        SUPPORT AND OPPOSITION:
        
         Support:  None on file as of March 31, 2010

         Opposition:  None on file as of March 31, 2010



        Consultant:Rosielyn Pulmano