The Council on Podiatric Medical Education (CPME) is deeply concerned about the tone and implications of the propositions G25 – K25 scheduled to be put before the APMA House of Delegates in March 2025. CPME has created an issue brief concerning these propositions. Please carefully review these materials to more fully understand the impact these propositions would have on the profession as a whole.
Summary
The proposed propositions raise serious concerns about the autonomy of the Council on Podiatric Medical Education (CPME) and its critical role in safeguarding the standards of podiatric medical education and training. The CPME operates as an independent accrediting body under the oversight of the U.S. Department of Education (USDE) and the Council for Higher Education Accreditation (CHEA). Its autonomy is vital for effectively overseeing the accreditation of colleges, and the same rigor is applied to the approval of continuing education providers, residency and fellowship programs, and recognition of specialty boards in a fair and unbiased manner. Granting the American Podiatric Medical Association (APMA) control over these areas would undermine CPME’s unified authority, potentially compromising its ability to uphold accreditation standards and safeguard educational integrity. Such a shift could jeopardize CPME’s continuing recognition by the USDE and CHEA. CPME is scheduled to begin its re-recognition process with the USDE and CHEA 2025. Both of these entities will require CPME to demonstrate that it operates independently, adhering to its established policies and procedures, free from external influence. Many of the proposed changes would make it impossible for CPME to meet these criteria, putting its accrediting status at risk.
Further, if APMA assumes oversight, decisions could be influenced by organizational politics rather than evidence-based educational practices, potentially leading to a decline in the quality of resident and fellow training. The proposed changes would fragment the CPME’s responsibilities, limiting its independence and jeopardizing the future of podiatric education. The inability to maintain a singular, cohesive body would compromise the rigorous standards required to prepare competent professionals and ensure compliance with regulatory frameworks.
The integrity of podiatric medical education hinges on a unified and independent CPME governing all aspects of education, including residencies, fellowships, specialty boards, and continuing education programs. To preserve the future of the profession, it is essential for the podiatric community to advocate against these propositions. CPME urges all APMA members to consider the long-term implications carefully and uphold the autonomy necessary to maintain the high-quality education and training standards.
Proposition G25 – CPME Oversight
The proposition’s ambiguous language sets a concerning precedent. Involving the HOD and APMA Board of Trustees (BOT) in Continuing Education Committee (CEC), Residency Review Committee (RRC), or Specialty Board Recognition Committee (SBRC) matters introduces potential conflicts of interest and compromises objectivity.
While CPME follows strict rules due to its oversight by the U.S. Department of Education (USDE) and the Council for Higher Education Accreditation (CHEA), the proposition seeks additional control over committees like the CEC, RRC, and SBRC. Specific concerns include:
- Public Records: CPME already publishes minutes, decisions, and reports on its website,
- Conflict of Interest Disclosure: CPME has opted not to release conflict of interest lists, in alignment with the practices of other accrediting bodies.
- Response Timelines: A vague 30-day deadline for responding to HOD or BOT requests is impractical and unrealistic.
- Incorporation of Directives: Requiring the incorporation of HOD directives into CPME standards and requirements to override established processes ignores the broader implications of these actions
- Standards Compliance: Forcing CPME to comply with APMA bylaws jeopardizes CPME’s autonomy and ability to maintain independent, effective oversight.
- Appeals: CPME already has a qualified pool of appeal panel members to include podiatric educators, administrators, academics, practitioners, and public members, ensuring appeals are handled by experts familiar with CPME processes.
Proposition H25 – Process for Recognition of a Special Area of Practice
CPME’s role within the profession is focused on assessing quality and ensuring compliance with established standards, rather than evaluating need. Decisions on new specialty boards, practice areas, or subspecialties belong to the profession, which may submit recommendations to the SBRC. The SBRC then evaluates compliance with CPME 220 standards.
Key issues include:
- Document References: Proposition H25 cites draft documents (CPME 220, CPME 230) not yet approved.
- Process Development: Determining the need for new specialties, special areas of practice, or subspecialty certification requires a robust framework.
Proposition I25: APMA Authority over Standards for Residency and Fellowship Programs, Specialty Boards, and Continuing Education Programs
This proposition grants APMA authority over CPME standards, undermining CPME’s independence. Allowing the HOD and BOT to dictate residency, fellowship, continuing education, and specialty boards standards would disrupt the established revision process, where CPME already seeks input from these bodies. Limiting public comment to BOT-approved sections would delay revisions indefinitely and compromise CPME’s authority.
Proposition J25: Graduate Medical Education – Residency Programs
Mandating American Medical Association (AMA)-owned CPT codes for procedure logging is impractical. CPME lacks authorization to use them, and they don’t reflect podiatric practice nuances. CPME 320 and 330 were adopted following a four-year review process, with implementation in July 2023. A full rewrite is already planned for six years post-revision, and reopening standards now would set a problematic precedent. Additional concerns include:
- Data Access & Misuse: Could miscategorization or fragmentation noted by review teams raise concerns about fraudulent billing?
- Third-Party Impact: Would insurers use this data against podiatric physicians and surgeons?
- Board Review Implications: How would this affect surgical board case review since ABFAS currently uses the same categories for PLS logging?
- Cost & Access: Would all providers who have access to PRR be considered users, which would drastically increase the cost per year to the program?
- Training & Implementation: A change in logging format would necessitate further training for program reviewers and programs.
- Variation in CPT coding: There is such great variation in how surgeons bill and code with CPTs, which would create disparities in resident surgical logging across programs. Using CPT codes for H&Ps would require a complete revision of the comprehensive H&P requirements, as billing criteria do not necessarily align with the CPME 320 standards. This change would also impact MAV requirements and disrupt newly established wound care and clinical procedure categories for office-based settings.
While incorporating CPT codes into the logging process may have potential benefits, any meaningful shift in this direction should be explored collaboratively. If the profession is interested, engaging the APMA, certifying boards, and PRR to develop and beta-test a structured program would provide critical insights before implementing such a change.
- Milestones: Nearly finalized, they will be published in 2025.
- Parity with ACGME: CPME standards (CPME 320) already align with ACGME requirements.
Proposition K25: Graduate Medical Education – Fellowship Programs
The assertion that CPME lacks comparable fellowship standards to ACGME is inaccurate. CPME standards (CPME 820) are based on ACGME criteria. However:
- Curriculum Standardization: Fellowships vary in focus, making a standardized curriculum unsuitable.
- Resource Constraints: Hospital resources differ, complicating uniform implementation.
Public notice released on February 11, 2025.