The Market Has Already Delivered Its Verdict. Only Organized Medicine Has Not.
The institutions that actually credential and reimburse physicians have spent the last three years reaching a conclusion about Maintenance of Certification that organized medicine refuses to acknowledge. These are not the specialty boards, not the AMA, and not the organizations that profit from mandatory participation. They are the bodies that determine whether hospitals and health plans operate with national accreditation, the federal agencies that govern competition in healthcare markets, and the commercial insurers that cover the majority of working Americans. Their verdict is documented in formal credentialing policy changes, updated accreditation standards, federal regulatory guidance naming unnecessary physician recertification as a potential antitrust violation, and bylaw amendments now adopted by more than 250 hospitals and health systems. It is not close and it is not preliminary.
Every major national accreditation body has formally recognized NBPAS as meeting its standards. The Joint Commission designated NBPAS as a Designated Equivalent Source Agency effective July 1, 2022, adding it to the glossary of accreditation manuals covering hospitals, ambulatory care, behavioral health, critical access hospitals, and office-based surgery facilities. The National Committee for Quality Assurance included NBPAS in its 2022 Health Plan Accreditation Standards and Guidelines. URAC, DNV, the Center for Improvement in Healthcare Quality, and the Accreditation Commission for Health Care have all confirmed that NBPAS meets their standards. Their collective recognition of NBPAS means that no credentialing or accreditation standard requires ABMS recertification as a condition of hospital or health plan operation. The ABMS gate is not an accreditation requirement. It is a private preference enforced through institutional inertia. ABMS's response to the Joint Commission's independent designation was to distribute what it called a toolkit created specifically to address what ABMS characterized as NBPAS's false inferences that an NBPAS certificate is equivalent to ABMS certification. The Joint Commission made that designation based on its own standards. ABMS responded by mounting a coordinated institutional campaign to undermine hospital recognition of an organization the nation's premier accreditor had just formally approved.
The federal signal arrived in April 2024, but its foundation had been laid seven months earlier. NBPAS formally filed a complaint with the FTC in September 2023, arguing that ABMS and its constituent boards were using monopoly power to exclude competitors from the continuing certification market. In April 2024, the FTC, DOJ, and HHS jointly launched
HealthyCompetition.gov, a portal for public reporting of anticompetitive practices in healthcare, and explicitly listed unnecessary healthcare provider recertification or accreditation requirements as an example of potentially anticompetitive conduct that may raise the costs of practicing medicine and reduce the number of healthcare practitioners. The sequence is clear. NBPAS filed the complaint. Seven months later, the federal government launched a portal naming the exact conduct NBPAS had identified. Three months after that, in July 2024, CMS updated its guidance on End Stage Renal Disease Medical Directors to formally accept NBPAS-certified nephrologists, including in rural areas and federally-designated Health Professional Shortage Areas. The federal government identified mandatory physician recertification as a potential antitrust violation and then changed its own clinical guidance in the same direction within the same year.
The three largest commercial insurers have followed. UnitedHealthcare, the largest health insurer in the United States, formally confirmed in a letter to NBPAS that its credentialing policies do not require participation in MOC programs, that physicians certified by NBPAS may be credentialed under its existing policies, and that physician competency is best demonstrated through initial board certification, ongoing clinical practice, and a commitment to lifelong learning. That statement is a precise repudiation of the ABMS mandatory recertification model, delivered in writing by the organization that insures more Americans than any other. Elevance Health, formerly Anthem, operates Blue Cross Blue Shield plans in 14 states and covers more than 115 million lives. Elevance accepts NBPAS under its alternative credentialing criteria for physicians with ten or more years of clinical experience. Health Care Service Corporation, the largest customer-owned health insurer in the United States, operating Blue Cross Blue Shield plans in Illinois, Montana, New Mexico, Oklahoma, and Texas, formally accepts NBPAS board certification. Blue Cross Blue Shield of Massachusetts, a five-star NCQA-rated plan, has accepted NBPAS. The American Thoracic Society has added NBPAS as a recognized board certification option in its professional database.
Hospital adoption is accelerating entirely through physician-led bylaw amendments, requiring no legislation and no institutional permission beyond a Medical Executive Committee vote. NBPAS is now recognized by more than 250 hospitals and health systems nationwide. Forty-four hospitals added NBPAS to their bylaws in 2025 alone. Named institutions include HCA Florida Woodmont Hospital, Ascension Saint Thomas hospitals in Tennessee, WVU Medicine, hospitals in the ScionHealth network, Hackensack Meridian Health in New Jersey, and St. Joseph's Health Hospital in Syracuse. Most hospitals, as NBPAS has documented, simply were not aware that an alternative existed.
The single most instructive holdout is Blue Cross Blue Shield of Michigan. Despite a physician-led campaign of more than 40 formal requests, intervention from Governor Whitmer's office, and a direct response request from the Michigan Department of Insurance and Financial Services, BCBSM refused to remove its MOC requirement. BCBSM holds more than 80 percent of the commercial insurance market in Michigan. That market concentration means a single insurer's refusal to recognize NBPAS functions as an effective statewide prohibition regardless of what any hospital bylaw or state legislature has done. Dr. Robert Vanderbrook is a solo family medicine physician in Clare, Michigan, practicing in a federally-designated Health Professional Shortage Area, which is a community the federal government has formally identified as lacking adequate physician access. BCBSM removed him from its networks because he chose NBPAS over ABFM recertification. Many of his patients refused to go elsewhere and opted to pay out of pocket to continue seeing him regardless of the financial strain. The BCBSM position is not an argument for the ABMS patient safety rationale. It is an illustration of what market-dominant enforcement of a discredited mandatory program looks like when it lands on a real physician in a real community that cannot afford to lose him.
The state legislative map tells the same story the market has told. Fifteen states have now passed laws limiting or restricting MOC requirements as a condition of physician practice. Six of them (Oklahoma, Texas, Georgia, South Carolina, Arkansas, and Tennessee) have passed comprehensive legislation prohibiting state licensing boards, insurance providers, and hospitals from requiring MOC participation as a condition of licensure, hospital privileges, or insurance panel participation. Oklahoma was first in 2016. Texas followed, with a bill signed by Governor Greg Abbott and sponsored by two physician-legislators: Senator Dawn Buckingham, MD, and Representative Greg Bonnen, MD. Georgia, South Carolina, and Arkansas followed. Nine additional states (Washington, Arizona, North Carolina, Kentucky, Missouri, Maine, Maryland, and others) have passed starter legislation, typically beginning with the licensure provision and building from there. More than a dozen others have introduced legislation that is pending or has expired in prior sessions. The pattern is consistent: a state begins with a narrow bill, builds legislative familiarity with the issue, and returns the following session with broader protections. The AMA's formal policy position has not changed. The enforcement infrastructure beneath it is being systematically removed, one state at a time.
Texas is the most instructive case study because it shows both the momentum and the remaining friction in a single legislative cycle. Texas SB 2207, which would have allowed NBPAS-certified physicians to truthfully advertise as board certified with full disclosure of their certifying board's name, passed the Senate Health and Human Services Committee unanimously at 7-0, passed the full Texas Senate 29-2, and passed the House Public Health Committee 9-1. The bill did not reach a House floor vote before the session ended. In a session where more than 7,000 bills were introduced and only 437 became law, SB 2207 ran out of calendar time rather than political support. The TMA's official policy states it opposes mandatory MOC requirements for licensing, health plan contracting, and hospital credentialing, citing excessive cost, time away from patients, and lack of sufficient research documenting benefits to patient care. Notwithstanding that official position, the TMA testified against SB 2207 before the House Public Health Committee on May 12, 2025, a hearing that ran through the night and concluded testimony at 2:30 in the morning. Physicians who had driven hours to testify in support could not wait out the schedule.
At the TMA's House of Delegates meeting in April 2026, physician members introduced Resolution 202, which would have required the TMA to support efforts to amend Texas Medical Board advertising rules to allow NBPAS-certified physicians to advertise as board certified. The resolution came within two percentage points: 48 percent in favor, 52 percent opposed. That vote is a leading indicator. Nearly half of the TMA's own physician delegates voted to require their association to stop opposing legislation their colleagues in the Texas Senate supported 29-2. The trajectory of that number across future sessions is the story. The AMA holds its formal policy. The states are moving regardless and within the state medical associations themselves, the physician membership is closing the gap between what organized medicine says and what practicing physicians actually want.
The policy argument for Congress, state legislatures, and hospital medical staffs is now straightforward. The market, the federal regulators, and every national accreditation body have reached their verdict. The largest commercial insurers have concluded in writing that mandatory ABMS MOC is not necessary for physician credentialing. The FTC and DOJ have named unnecessary physician recertification as a potential antitrust violation. The Joint Commission, NCQA, URAC, and DNV have all recognized the alternative. Two hundred and fifty hospitals have made the bylaw amendment. Fifteen states have passed legislation. The only institutions still treating ABMS MOC as the exclusive and mandatory pathway are the ABMS itself, the AMA, and a handful of insurers with sufficient market dominance to enforce a requirement the rest of the market has abandoned. What remains is not a debate about evidence or patient safety. That debate is over. What remains is finishing the work.