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	<title>Medicare Archives - Charles F. Mullen</title>
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	<description>Challenges and Opportunities in Optometry and Optometric Education</description>
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	<title>Medicare Archives - Charles F. Mullen</title>
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		<title>Three Critical Components for Expanded Scope of Optometric Practice</title>
		<link>https://www.charlesmullen.com/three-critical-components-for-expanded-scope-of-optometric-practice/</link>
		
		<dc:creator><![CDATA[Charles Mullen]]></dc:creator>
		<pubDate>Thu, 16 Sep 2021 17:21:32 +0000</pubDate>
				<category><![CDATA[Federal and State Initiatives]]></category>
		<category><![CDATA[Education]]></category>
		<category><![CDATA[GME]]></category>
		<category><![CDATA[Medicare]]></category>
		<guid isPermaLink="false">https://www.charlesmullen.com/?p=2393</guid>

					<description><![CDATA[<p>Optometric Education needs to change from the current four year curriculum to a Postgraduate Clinical Training Model to qualify for GME.</p>
<p>The post <a href="https://www.charlesmullen.com/three-critical-components-for-expanded-scope-of-optometric-practice/">Three Critical Components for Expanded Scope of Optometric Practice</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
]]></description>
										<content:encoded><![CDATA[<h2>Introduction</h2>
<p>Medical Education leads the Medical Profession by developing the educational structure and clinical training programs <em>in advance of</em> new patient care initiatives. In contrast, State Optometric societies lead the Optometric Profession with Optometric Education <em>reacting</em> to the States’ expanded scope of practice initiatives with specific educational programs. Consequently, there is not a comprehensive educational structure nor a uniform indicator of an optometrist’s knowledge and clinical skills to support all of the States’ expanded scope of practice initiatives.</p>
<p><strong>Requiring postgraduate clinical training in medical eye care for optometrists is not only essential preparation for Expanded Scope of Practice, but also positions optometry for inclusion in the $18 billion Graduate Medical Education Program (GME).</strong></p>
<p>These are the three missing components that need to be developed:</p>
<h3>1) Necessary Capacity for Advanced Clinical Training in Medical Eye Care</h3>
<ul>
<li>In 1931 Medicine acknowledged that clerkships contained within the four year medical school curriculum were inadequate preparation for rapidly changing medical practice, and instituted mandatory postgraduate clinical training.</li>
<li>Even though optometric practice has dramatically and rapidly expanded encompassing medical eye care, clerkships within the four year optometry curriculum remain the only required clinical training component.</li>
<li>The current four year curriculum does not provide optometry graduates with the types and quantity of clinical teaching encounters necessary to practice expanded scope of practice in all States.</li>
<li>Postgraduate clinical training in medical eye care is now essential preparation for advanced optometric practice.</li>
</ul>
<h3>2) Federal Funding to Support Advanced Clinical Training</h3>
<ul>
<li>Optometry is not included in the $18 Billion Graduate Medical Education Program (GME) because clinical education takes place primarily within the four year curriculum, and not in postgraduate residencies.</li>
<li>Inclusion in GME, the educational component of Medicare, would not only encourage the development of new residency positions in Medical Eye Care by providing funding to host facilities, but also by providing funding to directly support advanced clinical training.</li>
<li>Optometric Education needs to change from providing clinical education within the current four year curriculum to a Postgraduate Clinical Training Model to qualify for GME.</li>
<li>Like medicine, clinical clerkships or rotations would take place within the final years of the curriculum.</li>
</ul>
<h3>3) Nationally Recognized Certification Board to Provide a Uniform Indicator of an Optometrist’s Advanced Knowledge and Skills to Practice Expanded Scope of Practice Optometry</h3>
<ul>
<li>The American Board for Certification in Medical Optometry (ABCMO) is a well-established Board that meets GME expectations. However, ABCMO serves mostly Department of Veterans Affairs (VA) optometrists, and needs to be recognized by the entire Optometric Profession.</li>
</ul>
<h2>More Information</h2>
<ul>
<li><a href="https://www.charlesmullen.com/optometry-specialties-and-subspecialties/">The State of Optometry Specialties and Subspecialties</a></li>
<li><a href="https://eyesoneyecare.com/resources/optometry-scope-of-practice-united-states/">Optometry Scope of Practice in the United States</a></li>
<li><a href="https://www.charlesmullen.com/changes-necessary-to-include-optometry-in-the-gme/">Changes Necessary to Include Optometry in the Graduate Medical Education Program (GME)</a></li>
<li><a href="https://abcmo.org/">The American Board of Certification in Medical Optometry (ABCMO)</a></li>
<li><a href="https://www.charlesmullen.com/principles-in-developing-specialties-and-subspecialties/">Principles to Follow in Developing Specialties and Subspecialties</a></li>
<li><a href="https://www.charlesmullen.com/required-postgraduate-clinical-training-for-optometry-license/">Required Postgraduate Clinical Training for Optometric License</a></li>
<li><a href="https://abos.us/">American Board of Optometry Specialties (ABOS)</a></li>
</ul>


<p></p>
<p>The post <a href="https://www.charlesmullen.com/three-critical-components-for-expanded-scope-of-optometric-practice/">Three Critical Components for Expanded Scope of Optometric Practice</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
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		<item>
		<title>Recommended Briefing Points for Advocates of Optometry&#8217;s Inclusion in GME</title>
		<link>https://www.charlesmullen.com/briefing-points-for-advocates-optometry-in-gme/</link>
		
		<dc:creator><![CDATA[Charles Mullen]]></dc:creator>
		<pubDate>Thu, 12 Aug 2021 23:26:58 +0000</pubDate>
				<category><![CDATA[Federal and State Initiatives]]></category>
		<category><![CDATA[GME]]></category>
		<category><![CDATA[Medicare]]></category>
		<category><![CDATA[Optometry]]></category>
		<guid isPermaLink="false">https://www.charlesmullen.com/?p=2353</guid>

					<description><![CDATA[<p>Optometry, a significant provider of eye care services to Medicare beneficiaries, is not currently included in the GME.</p>
<p>The post <a href="https://www.charlesmullen.com/briefing-points-for-advocates-optometry-in-gme/">Recommended Briefing Points for Advocates of Optometry&#8217;s Inclusion in GME</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
]]></description>
										<content:encoded><![CDATA[<h3>Background</h3>
<ul>
<li>Optometry is a significant provider of medical eye care services to Medicare beneficiaries (<strong>$1.33 billion annually</strong>) for conditions such as glaucoma, cataracts and retinal diseases, but is not included in the Graduate Medical Education Program (GME), the educational component of Medicare.</li>
<li>Medicine, Podiatry and Specialty Dentistry receive $18 billion in GME support annually for postgraduate clinical education. Podiatry was included in GME in 1972 by amendment, and changed its clinical training model in 1990. Podiatry now receives regular GME payments to support resident training.</li>
<li>It will be necessary to include Optometry in GME by amendment to appropriate laws/regulations or by inclusion in proposed legislation in advance of the introduction of a new optometry postgraduate clinical education model.</li>
</ul>
<h3>Clinical Training of Optometrists</h3>
<ul>
<li>Optometry has traditionally provided clinical education within the four year optometry school curriculum with postgraduate clinical training being optional, thus, optometry&#8217;s current clinical education model does not meet GME requirements.</li>
<li>Costly, optometric clinical education receives no Federal Support, and is largely financed by student tuition contributing to high graduate debt of approximately $200,000.</li>
<li>Optometry graduates have the highest loan payments as a percentage (<strong>14.9%</strong>) of income of all professions.</li>
<li>High debt is a contributing factor in that applicants to optometry schools and colleges have not effectively increased in 10 years.</li>
</ul>
<h3>Reasons Optometry Should be Included in GME</h3>
<ol>
<li>Nationwide expansion of the scope of optometric practice by numerous changes to State Practice laws.</li>
<li>A steadily increasing demand in providing Medicare beneficiaries with medical eye care services &#8211; Optometrists currently provide <strong>$1.33 billion</strong> in services annually managing serious eye conditions of Medicare recipients.</li>
<li>A major increase in optometric management of serious eye conditions will accompany the proposed addition of refractive care (refraction, eyeglasses and contact lenses) in Medicare.</li>
</ol>
<ul>
<li>The above will require the schools and colleges of optometry to restructure their traditional clinical education approach into a Postgraduate Medical Clinical Educational Model in order to provide the quantity and diversity of clinical teaching encounters necessary to properly prepare optometry graduates for clinical practice.</li>
<li>In 1930 Medicine adopted required postgraduate clinical training because the 4 year medical school curriculum did not provide the quantity and diversity of clinical encounters to properly train physicians.</li>
<li>Postgraduate optometric clinical education can be provided in cost effective outpatient facilities. GME&#8217;s hospital-based training requirement needs to be waived.</li>
</ul>
<h3>Optometry&#8217;s Inclusion in GME is Necessary</h3>
<ul>
<li>GME is needed to support optometry&#8217;s postgraduate clinical education to meet current and future demand for well-trained optometrists in advanced medical eye care practice.</li>
<li>GME support will ensure a sufficient number of well-trained optometrists to meet current and projected demand for eye care services of Medicare beneficiaries.</li>
</ul>
<h3>See Also</h3>
<ul>
<li><a href="https://www.charlesmullen.com/changes-necessary-to-include-optometry-in-the-gme/">Changes Necessary to Include Optometry in the Graduate Medical Education Program (GME)</a></li>
<li><a href="https://www.charlesmullen.com/wp/wp-content/uploads/2021/06/Rationale-for-Optometrys-Inclusion-in-GME.pptx">Rationale for Optometry&#8217;s Inclusion in GME (PowerPoint)</a></li>
<li><a href="https://www.charlesmullen.com/opportunities-lost-opportunities-regained/">Opportunities Lost &#8211; Opportunities Regained</a></li>
<li><a href="https://www.npr.org/sections/health-shots/2021/08/09/1026104398/democrats-hope-to-beef-up-medicare-with-dental-vision-and-hearing-benefits">Democrats Hope To Beef Up Medicare With Dental, Vision And Hearing Benefits</a></li>
</ul>


<p></p>
<p>The post <a href="https://www.charlesmullen.com/briefing-points-for-advocates-optometry-in-gme/">Recommended Briefing Points for Advocates of Optometry&#8217;s Inclusion in GME</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
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		<title>Medicare Teaching Compliance Protocol for New England Eye</title>
		<link>https://www.charlesmullen.com/teaching-compliance-protocol-for-new-england-eye/</link>
		
		<dc:creator><![CDATA[Charles Mullen]]></dc:creator>
		<pubDate>Tue, 10 Sep 2013 12:30:29 +0000</pubDate>
				<category><![CDATA[Building Quality Institutions]]></category>
		<category><![CDATA[Clinical Training]]></category>
		<category><![CDATA[Education]]></category>
		<category><![CDATA[Healthcare]]></category>
		<category><![CDATA[Medicare]]></category>
		<category><![CDATA[Optometry]]></category>
		<category><![CDATA[Students]]></category>
		<guid isPermaLink="false">https://www.charlesmullen.com/?p=986</guid>

					<description><![CDATA[<p>The Teaching Compliance Protocol for New England Eye (PDF) describes the practical implementation of NEE Health Insurance Teaching Compliance Policy.</p>
<p>The post <a href="https://www.charlesmullen.com/teaching-compliance-protocol-for-new-england-eye/">Medicare Teaching Compliance Protocol for New England Eye</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
]]></description>
										<content:encoded><![CDATA[<div><img decoding="async" src="https://www.charlesmullen.com/wp/wp-content/uploads/2013/09/NEE-logo.png" alt="New England Eye Logo" width="147" height="147" class="alignright size-full wp-image-992" /></div>
<p>New England Eye is the Patient-Centered Care and Clinical Education Affiliate of the New England College of Optometry.</p>
<p><a href="https://www.charlesmullen.com/wp/wp-content/uploads/publications/Health-Care-Insurance-Teaching-Compliance-Policy.pdf">The Teaching Compliance Protocol for New England Eye (PDF)</a> describes the practical implementation of NEE Health Insurance Teaching Compliance Policy.</p>
<p>Authors: Senior Management Staff, NEE.</p>
<p>The post <a href="https://www.charlesmullen.com/teaching-compliance-protocol-for-new-england-eye/">Medicare Teaching Compliance Protocol for New England Eye</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
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		<title>Affordable Care Act: Opportunity for New Optometry Student Clinical Training Model</title>
		<link>https://www.charlesmullen.com/aca-opportunity-for-optometric-clinical-training-changes/</link>
		
		<dc:creator><![CDATA[Charles Mullen]]></dc:creator>
		<pubDate>Sun, 14 Jul 2013 16:13:50 +0000</pubDate>
				<category><![CDATA[Building Quality Institutions]]></category>
		<category><![CDATA[Clinical Training]]></category>
		<category><![CDATA[GME]]></category>
		<category><![CDATA[Medicare]]></category>
		<category><![CDATA[Optometry]]></category>
		<category><![CDATA[Students]]></category>
		<guid isPermaLink="false">https://www.charlesmullen.com/?p=960</guid>

					<description><![CDATA[<p>With the implementation of the Affordable Care Act (ACA), it is an opportune time for optometry schools and colleges to change to a Teaching Physician-Centered Model and reinforce their CMS compliance policy and Electronic Health Records (EHR) procedures for students.</p>
<p>The post <a href="https://www.charlesmullen.com/aca-opportunity-for-optometric-clinical-training-changes/">Affordable Care Act: Opportunity for New Optometry Student Clinical Training Model</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
]]></description>
										<content:encoded><![CDATA[<p>I am writing this paper to urge schools and colleges of optometry to change from Student-Driven Clinical Training to a Teaching Physician-Centered Model to facilitate compliance with the <a href="https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/Downloads/Teaching-Physicians-Fact-Sheet-ICN006437.pdf">Center for Medicare/Medicaid Services (CMS) Guidelines for Teaching Physicians, Interns and Residents as the Guidelines pertain to Students</a>. With the implementation of the Affordable Care Act (ACA), it is an opportune time for optometry schools and colleges to change to a Teaching Physician-Centered Model and reinforce their CMS compliance policy and Electronic Health Records (EHR) procedures for students. I realize such a dramatic change in optometric clinical training would have significant budgetary implications as teaching physician/faculty expense would increase and patient services revenues would likely decline. However, the current Student-Driven Training Model continues to pose a high risk of CMS violations with associated fines and other sanctions. It is anticipated that audits of Federal Health Care Programs will increase with the implementation of the Affordable Care Act (ACA).</p>
<p>The paper does not discuss the educational benefits of the Teaching Physician-Centered Model. However, the model has been successfully utilized in medical student education for many years.</p>
<h2>Background</h2>
<p>Because the Department of Health and Human Services (HHS) does not consider optometry residents to be “real” residents, I do not address optometry residents’ compliance in this paper since CMS Teaching Guidelines do not technically apply. An optometry resident once licensed is no different than any licensed optometrist. Also, optometry residency programs do not qualify for the Graduate Medical Education (GME) program. Nor does optometry have a trainee classification that qualifies as intern. A teaching physician is defined as optometric school/college faculty, affiliate attending staff, or extern preceptor.</p>
<p>The CMS Teaching Guidelines apply to Medicare, other Federal Health Care Programs, Medicaid in most states, and most major private insurers.</p>
<p>Page 3 of the Teaching Guidelines state:</p>
<blockquote><p>Evaluation and Management-Documentation Provided by Students—Any contribution of a student to the performance of a billable service must be performed in the physical presence of a teaching physician or resident… the student may document in the medical record. However, the teaching physician may only refer to Review of Systems (ROS) and Past Family/Social History (PFSH)….the teaching physician may <em>not</em> refer to the students findings and must verify and re-document the history of present illness and perform (repeat) and re-document the examination and medical decision making (treatment plan).</p></blockquote>
<p>Page 7 – Medicare does <em>not</em> pay for any services furnished by students.</p>
<p>I base my recommendation to change the teaching model on research and writing on the subject, consultation with American Optometric Association (AOA) Medicare experts, consultation with teaching physicians, interviews with medical students and residents and ongoing discussions with (AOA) Federal Relations staff and optometric academic administrators and faculty along with viewing the Office of the Inspector General (OIG) <a href="http://oig.hhs.gov/fraud/enforcement/cmp/false_claims.asp">False and Fraudulent Claims Report</a>, where CMS Teaching Guidelines violations are reported. I also have extensive experience in optometric clinical education and with Federal Health Care policy. See: <a href="https://www.charlesmullen.com/curriculum-vitae/">Dr. Charles Mullen CV</a>.</p>
<h2>Compliance with CMS Teaching Guidelines and EHR Procedures</h2>
<p>Failure to fully comply with the Teaching Guidelines and EHR procedures creates self-induced risk which could result in institutional fines, legal fees and other severe penalties. There is also the potential of individual liability and damage to the reputations of faculty members, affiliate attending staff or extern preceptors since Medicare/Medicaid Fraud and Abuse sanctions are reported to the National Practitioners Data Bank. Should an extern preceptor be sanctioned for Medicare fraud or abuse the damage to optometry school/college alumni relations would be extensive. HHS has intensified its efforts to identify and prosecute Medicare fraud by increasing the reward pool for “whistle blowers” to $10 million.</p>
<h2>Student Notations Risks with Electronic Health Record (EHR)</h2>
<p>If student notations are placed in the patient’s record (either written or EHR), they must be clearly delineated and not used to bill for services. Intentionally and knowingly using student examination findings to bill Medicare is considered a fraudulent claim. The Association of Academic Medical Centers (AAMC) issued a <a href="https://www.charlesmullen.com/wp/wp-content/uploads/publications/AAMC-Compliance-Advisory.pdf">Compliance Advisory</a> regarding students and Electronic Medical Records (EMR). The Compliance Advisory cautioned teaching physicians about the risks of student notations in the electronic medical record and delineated procedures to avoid Medicare violations and sanctions.</p>
<h2>Self Disclosure</h2>
<p>Optometry schools and colleges that suspect Medicare violations in their clinical operations may want to consider Self Disclosure rather than exposing the institution to an uninvited Medicare audit which could result in catastrophic fines, legal fees and severe sanctions. The <a href="http://www.oig.hhs.gov/compliance/self-disclosure-info/protocol.asp">OIG Self Disclosure</a> program may permit the institution to negotiate any fines and potentially prevent higher fines and more severe penalties such as exclusion from all Federal Health Care Programs. <a href="https://www.charlesmullen.com/wp/wp-content/uploads/publications/Medicare-Fraud-and-Abuse.pdf">Medicare Fraud and Abuse</a> fines are up to $10,000 to $50,000 plus three times the damages for each violation. The Self Disclosure protocol requires the institution to furnish extensive information on the Medicare/Medicaid violations including how the school/college plans to prevent future violations. Suggested measures to prevent CMS violations are delineated in the next section of the paper.</p>
<h2>Teaching Physician-Centered Model</h2>
<p>The current optometric Student-Driven Clinical Training Model is not compatible with CMS Teaching Guidelines, while the Teaching Physician-Centered Model is consistent with all of the following CMS compliance expectations:</p>
<ol>
<li>that the teaching physician is in charge of the patient</li>
<li>that patient care is personally rendered or repeated by the teaching physician and</li>
<li>that the examination is personally documented in the medical record by the teaching physician including history of present illness, diagnosis and management/treatment plan.</li>
</ol>
<p>This model is successfully utilized in medical student clerkships.</p>
<p>Optometry programs must clearly demonstrate how students are incorporated in the care of the patient to learn and practice clinical procedures and not to provide patient services. Also, programs must demonstrate how students participate when the care of the patient is actively and personally provided by the teaching physician. Schools and colleges should view student clinical placements as <em>clerkships</em> where the student can practice history taking and examination procedures along with assisting the supervising physician, but not provide patient services except ROS and PFSH.</p>
<p>Optometry schools and colleges must ensure:</p>
<ol>
<li>a CMS compliance policy is in place, including a EHR policy regarding student notations</li>
<li>that the compliance policy is monitored and enforced by annual internal compliance audits</li>
<li>that all clinical affiliates and extern preceptors receive copies of the institution’s compliance policy along with CMS and OIG supporting documents</li>
<li>that regular briefings on compliance by senior school/college officials are presented to all external training venues</li>
<li>that all college faculty and optometry students receive compliance training prior to participating in patient care</li>
<li>that the school/college or teaching clinic has a Compliance Officer</li>
<li>that lines of communications are open</li>
</ol>
<p><a href="https://www.charlesmullen.com/wp/wp-content/uploads/publications/VHA-Handbook.pdf">The Veterans Health Administration (VHA) Eye Care Handbook</a> also mandates compliance with CMS Teaching Guidelines in all optometric teaching programs. Annually, 1400 optometry student clinical rotations are available at VA facilities along with 186 residents and 3 research fellows. Although optometry residents are not considered residents by HHS, the VA requires compliance with CMS Teaching Guidelines for both optometry residents and students.</p>
<p>Although implementation of the Teaching Physician-Centered training model would be a major step forward in addressing optometry student compliance with CMS Teaching Guidelines, serious consideration should be given to the overall restructuring of optometric education by placing optometry in parallel with medicine for both student and postgraduate clinical training. Restructuring the curriculum would present the opportunity for inclusion in GME and further enhance CMS compliance. See: <a href="https://www.charlesmullen.com/restructuring-optometry/">Restructuring the Profession of Optometry &#8211; The Next Bold Move</a>.</p>
<h2>Reference Documents</h2>
<ol>
<li><a href="https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/Downloads/Teaching-Physicians-Fact-Sheet-ICN006437.pdf">CMS Guidelines for Teaching Physicians, Interns and Residents (Students)</a></li>
<li><a href="http://oig.hhs.gov/fraud/enforcement/cmp/false_claims.asp">OIG False and Fraudulent Claims Report</a></li>
<li><a href="https://www.charlesmullen.com/wp/wp-content/uploads/publications/Provider-Self-Disclosure-Protocol.pdf">OIG Self Reporting Protocol</a></li>
<li><a href="https://www.charlesmullen.com/wp/wp-content/uploads/publications/Medicare-Fraud-and-Abuse.pdf">Medicare Fraud and Abuse Summary</a></li>
<li><a href="https://www.charlesmullen.com/wp/wp-content/uploads/publications/VHA-Handbook.pdf">Veterans Health Administration (VHA) Eye Care Handbook</a></li>
<li><a href="https://www.charlesmullen.com/restructuring-optometry/">Restructuring the Profession of Optometry &#8211; The Next Bold Move</a></li>
</ol>
<p>The post <a href="https://www.charlesmullen.com/aca-opportunity-for-optometric-clinical-training-changes/">Affordable Care Act: Opportunity for New Optometry Student Clinical Training Model</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
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		<title>A Strategic Framework for Optometry and Optometric Education</title>
		<link>https://www.charlesmullen.com/a-strategic-framework-for-optometry-and-optometric-education/</link>
		
		<dc:creator><![CDATA[Charles Mullen]]></dc:creator>
		<pubDate>Tue, 16 Apr 2013 16:20:19 +0000</pubDate>
				<category><![CDATA[Presentations]]></category>
		<category><![CDATA[Signature Papers]]></category>
		<category><![CDATA[Strategic Planning and Measured Performance]]></category>
		<category><![CDATA[Accreditation]]></category>
		<category><![CDATA[Board Certification]]></category>
		<category><![CDATA[Clinical Training]]></category>
		<category><![CDATA[Education]]></category>
		<category><![CDATA[Healthcare]]></category>
		<category><![CDATA[Medical]]></category>
		<category><![CDATA[Medicare]]></category>
		<category><![CDATA[Optometry]]></category>
		<guid isPermaLink="false">https://www.charlesmullen.com/?p=876</guid>

					<description><![CDATA[<p>An eight step plan to comprehensively restructure the profession of optometry by placing optometry in parallel with medicine.</p>
<p>The post <a href="https://www.charlesmullen.com/a-strategic-framework-for-optometry-and-optometric-education/">A Strategic Framework for Optometry and Optometric Education</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
]]></description>
										<content:encoded><![CDATA[<blockquote><p>If optometry is to maintain its position as the Nation’s leader in primary eye and vision care in a rapidly evolving health care system&#8230; we have a responsibility to frame our own future.</p></blockquote>
<h2>Abstract</h2>
<p>The following slide presentation describes an eight step plan to comprehensively restructure the profession of optometry to meet the expectations of private, Federal and State insurers, external certifying agencies, and credentialing and privileging boards by placing optometry in parallel with medicine.</p>
<p>Significant changes to optometric education, clinical training, licensure requirements, board certification and accreditation are described (1) to qualify optometry for inclusion in the Graduate Medical Education Residency Program (GME), a $10 billion annual program which currently funds post graduate training for physicians, dentists and podiatrists, and (2) to meet Federal insurance compliance guidelines for teaching programs.</p>
<p><a href="https://www.charlesmullen.com/wp/wp-content/uploads/2016/01/A-Strategic-Framework-for-Optometry.pdf">A Strategic Framework for Optometry and Optometric Education (PDF)</a></p>
<p><a href="https://www.charlesmullen.com/wp/wp-content/uploads/2016/01/A-Strategic-Framework-for-Optometry.ppt">A Strategic Framework for Optometry and Optometric Education (PPT)</a></p>
<p>Charles F. Mullen<br />
Janice E. Scharre<br />
David S. Danielson</p>
<p>The post <a href="https://www.charlesmullen.com/a-strategic-framework-for-optometry-and-optometric-education/">A Strategic Framework for Optometry and Optometric Education</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
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		<title>Eight Strategic Steps to a Secure Future for Optometry</title>
		<link>https://www.charlesmullen.com/eight-strategic-steps-to-a-secure-future-for-optometry/</link>
		
		<dc:creator><![CDATA[Charles Mullen]]></dc:creator>
		<pubDate>Thu, 16 Aug 2012 15:10:07 +0000</pubDate>
				<category><![CDATA[Strategic Planning and Measured Performance]]></category>
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					<description><![CDATA[<p>Since optometrists are classified as physicians under Federal law, they are (or will) be judged by Federal and State governments, external certifying organizations, credentialing and privileging boards of medical facilities and third party insurers utilizing the medical model as the standard.</p>
<p>The post <a href="https://www.charlesmullen.com/eight-strategic-steps-to-a-secure-future-for-optometry/">Eight Strategic Steps to a Secure Future for Optometry</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
]]></description>
										<content:encoded><![CDATA[<blockquote><p>The tranquilizing drug of incremental progress &#8211; Anonymous</p></blockquote>
<h2>Background</h2>
<p>Over the past 40 years, changes to optometric practice laws and Federal/State current and anticipated health care policy have been addressed by specific, <em>incremental</em> modifications to licensure requirements, clinical education, postgraduate training and advanced competency certification/re-certification rather than systemic restructuring of the profession in accordance with a comprehensive strategic plan.</p>
<p>Consequently, unaddressed <em>structural</em> issues persist and weaken optometry&#8217;s position as an independently licensed profession in a third party dominated health care system. Also, structural issues prevent optometry from receiving Federal support for clinical training. Currently, clinical training costs are often passed on to the optometry student in the form of higher tuition resulting in additional graduate debt.</p>
<p>Since optometrists are classified as physicians under Federal law, they are (or will) be judged by Federal and State governments, external certifying organizations, credentialing and privileging boards of medical facilities and third party insurers utilizing the <em>medical model</em> as the standard. Optometrists, like physicians, will be/or are already expected to demonstrate clinical competency by board certification and maintenance of competency by re-certification.</p>
<p>Also, all optometric clinical teaching venues are expected to comply with the Center for Medicare/Medicaid Services (CMS) Guidelines for Teaching Physicians, Interns and Residents.</p>
<p>A <em>eight-step approach</em> is recommended to comprehensively restructure the profession by placing optometry in parallel with medicine.</p>
<h2>Most Important Events of the Past 40 Years</h2>
<ul>
<li>Expansion of optometric state laws, initiated in Rhode Island in 1972, authorizing the use of pharmaceuticals and advanced clinical procedures.</li>
<li>Creation in 1976 of the Department of Veterans Affairs Optometry Service, now the largest optometric patient care and clinical training program in the country with 675 VA optometrists providing 1.5 million visits annually. And clinical training provided for 80% of optometric students and over 50% of all residents.</li>
<li>Inclusion in Medicare in 1987, now $1.0 billion in optometric services are provided annually.</li>
<li>Optometry&#8217;s broad-based inclusion in the Affordable Care Act (ACA) will likely be another significant event. Participation in the ACA will also facilitate inclusion in other Federal Programs such as the Graduate Medical Education Program (GME) and the National Health Service Corps (NHSC).</li>
</ul>
<p>Although these were major achievements, the absence of a visionary plan at the time resulted in missed opportunities:</p>
<ul>
<li>to advocate for the passage of broadly drafted state optometric practice laws that would allow for the future expansion of the scope of practice without further amendments,</li>
<li>to agree on the purpose of optometric post graduate clinical training. Was it intended to qualify for state licensure and/or board certification or just advanced training?</li>
<li>and to include optometric clinical training support (GME) in the Medicare component of the Social Security Act.</li>
</ul>
<h2>Three Major Challenges Facing Optometry</h2>
<ol>
<li>Optometry is (or will) be judged by Federal and State governments, external certifying organizations, credentialing and privileging boards and third party insurers utilizing the medical model as the standard.</li>
<li>The $10 billion Graduate Medical Education (GME) program is based on the medical clinical training model and optometry&#8217;s clinical training, licensure requirements and advanced competency certification/re-certification do not meet GME expectations for participation.</li>
<li>The Center for Medicare/Medicaid Services Guidelines for Teaching Physicians, Interns and Residents prohibit optometric students from providing billable services in all training venues.</li>
</ol>
<h2>Detailed Structural Issues and Missed Opportunities</h2>
<h4>Postgraduate Clinical Training and Advanced Competency Certification</h4>
<ul>
<li>No mandatory postgraduate training is required for optometric licensure with the exception of Arkansas and Delaware.</li>
<li>No nationwide acceptance of optometric postgraduate specialty training, board certification and maintenance of certification presently exists, however, the American Board of Optometry(ABO) has been recognized by the Center for Medicare/Medicaid Services (CMS) for bonus payments (PQRS) and the American Board of Certification in Medical Optometry (ABCMO) has been recognized by the Joint Commission on Accreditation of Health Care Organizations (JCAHO) as a certifying agency.</li>
<li>Although a significant provider of Medicare services ($1.0 billion annually), optometry is not included in the Graduate Medical Education Program (GME) the educational component of Medicare because optometry&#8217;s clinical training model does not meet GME expectations.</li>
<li>Because of the above, current optometric residents are not recognized by the Department of Health and Human Services (HHS).</li>
<li>No expeditious route presently exists for board certification in General Optometry for most new optometric graduates. In 2012 there were only 367 available resident positions for 1600-1800 graduates.</li>
</ul>
<h4>Education</h4>
<ul>
<li>The increasing costs of optometric clinical training are passed on to students in the form of higher tuition. </li>
<li>Debt is too high for optometry school graduates averaging $140,000 (public) to $175,000 (private) vs. median annual income of $95,000.</li>
<li>The Bureau of Labor Statistics is projecting a 33% increase in demand for optometrists or 11,300 additional optometrists for the period (2010-2020), however, the student applicant pool is declining.</li>
<li>The declining student applicant pool for optometric schools (only 1.0 unique applicants per entering seat) is exacerbated by the proliferation of new schools (five schools added in recent years) and by expanded enrollments in existing schools. This is significant problem now and will likely be continued in the future. High debt to potential income and increasing commercialization of the profession are likely contributing factors.</li>
<li>Schools and colleges of optometry perpetuate a curriculum where optometric clinical training required for licensure is contained within the basic curriculum. GME only supports <em>postgraduate</em> clinical training and paid an average of $95,000 per medical resident to hospitals in 2010.</li>
</ul>
<h4>Medicare/Medicaid Compliance</h4>
<ul>
<li>CMS Guidelines for Teaching Physicians, Interns and Residents compliance vulnerabilities persist in all clinical teaching venues including externship sites, because optometric students are restricted by regulation from providing billable services. Also, private insurers apply CMS Guidelines. Two optometry schools have already been cited by the Office of Inspector General (OIG) for violations</li>
</ul>
<h2 id="steps">Eight Strategic Steps to a Secure Future for Optometry</h2>
<p><em>The proposed actions are highly sensitive, politically challenging and replete with timing and sequencing issues. However, there is no easy path, if optometry is to maintain its independence as a doctoral-level prescribing profession in a rapidly evolving health care system.</em></p>
<p>Again, the states are called upon to lead the profession, as Rhode Island did in the 1970&#8217;s. ASCO member institutions, NBEO and ACOE would likely follow with compensatory actions as they have historically done.</p>
<p>The steps are designed to facilitate synergism among State licensure requirements, postgraduate training, board certification/re-certification, optometric curricula; and position optometry to meet the expectations of private/Federal/State insurers, external certifying agencies, credentialing and privileging boards and the Graduate Medical Education Program (GME).</p>
<ol>
<li>
<p>States should mandate one or two years of mandatory post graduate training for optometric licensure. Only Delaware and Arkansas already mandate post graduate training. State Optometric Practice Laws amended to include — &#8220;One or (two) years of postgraduate clinical training, in an accredited program leading to Board Certification, is required for licensure.&#8221;</p>
</li>
<li>
<p>It would be necessary for optometric educational institutions to adjust curricula by awarding the O.D. degree after three years and to reclassify the 4th year as the first year of residency.</p>
<p><em>Two optometry colleges already offer accelerated programs, the New England College of Optometry offers a two year program and in the past, a three-year program and Salus University a three year program (deferred) while medical schools are now offering three year programs.</em></p>
<p>Consolidation of curriculum into three years can be accomplished by moving basic course material to pre-optometry requirements and extending the academic year to twelve months, permitting completion of all competency-based course material in three calendar years. Increased use of on-line instruction would facilitate completion of the accelerated curriculum.</p>
<p>A three calendar year curriculum would allow reallocation of 1600-1800 current 4th year student placements for postgraduate residency training.</p>
<p><em>A three-year O.D. degree program along with GME residency stipends would reduce optometry student debt $30,000 to $50,000 or more.</em></p>
<p><strong><em>U.S. Medical Schools (Allopathic &#038; Osteopathic) Offer 3-Year Degrees.</em></strong></p>
<p><em>In the last five years, at least four medical schools have initiated or are developing three-year programs including Mercer University School of Medicine, Lake Erie Osteopathic College of Medicine, Texas Tech University Health Sciences Center, Louisiana State University School of Medicine.</em></p>
<p><em>Also, three other schools have applied for Federal funds (CMS Innovation Grants) to develop three-year programs: Indiana University School of Medicine, East Tennessee State University Quillen College of Medicine, and the University of Kentucky College of Medicine.</em></p>
<p><em>The Carnegie Foundation for the Advancement of Teaching recommends all medical schools consider a three-year option.</em></p>
<p><em>Two Canadian Medical schools have three-year programs.</em></p>
<p><em>The three-year program will save the medical student $50,000 in debt.</em></p>
</li>
<li>
<p>National Board of Examiners in Optometry (NBEO) examination sequencing would need to be adjusted to accommodate new curriculum and mandatory postgraduate training.</p>
</li>
<li>
<p>One year of postgraduate training required for certification in General Optometry, two years for specialties and three years for fellowship trained sub-specialties.</p>
<p>Certifications boards need to developed and/or recognized for General Optometry (ABO) and the Specialties of Medical Optometry (ABCMO), Cornea/Contact Lenses, Pediatrics, and Vision Rehabilitation. Also, sub-specialty certification boards for Neuro-Optometry and Glaucoma developed.</p>
</li>
<li>
<p>To ensure consistent standards among various certification boards, establish an oversight board for all specialty certification boards, the American Board of Optometric Specialties (ABOS).</p>
<p>There is an immediate need for an oversight board as three newly developed optometric certifying boards, as well as other organizations awarding advanced competency status, have varying standards.</p>
</li>
<li>
<p>Only postgraduate clinical training programs accredited by the Accreditation Council on Optometric Education (ACOE) would be recognized for board certification. Mechanisms must be established to record resident patient care experiences to ensure the resident has received the quantity and diversity of patient care encounters to qualify for board certification.</p>
<p>Consideration should be given to accrediting existing and new schools to a maximum enrollment.</p>
<p>Care (CCOC) should be re-instated to ensure high standards of optometric patient care and sufficient patient volume at all clinical training venues</p>
</li>
<li>
<p>With completion of Steps 1-6, optometry would now be parallel with medicine and consistent with current and anticipated Federal/State policies, external certifying agencies, credentialing and privileging boards and private insurers&#8217; requirements.</p>
</li>
<li>
<p>Also, optometry’s clinical training model, licensure requirements and advanced competency certification/re-certification process would meet GME expectations and comply with CMS Guidelines for Teaching Physicians, Interns and Residents. AOA advocacy could now move forward with a credible position.</p>
<p>Since optometric clinical training is largely in outpatient facilities, GME regulations would need to be expanded from hospitals only to include outpatient patient care/clinical training.</p>
</li>
</ol>
<h2>Resources</h2>
<ul>
<li><a href="http://abcmo.org/">American Board of Certification in Medical Optometry</a></li>
<li><a href="http://americanboardofoptometry.org/board-certification/get-certified/">American Board of Optometry</a></li>
</ul>
<p>The post <a href="https://www.charlesmullen.com/eight-strategic-steps-to-a-secure-future-for-optometry/">Eight Strategic Steps to a Secure Future for Optometry</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
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		<title>Strategy to Include Optometry in the Graduate Medical Education Program (GME)</title>
		<link>https://www.charlesmullen.com/strategy-to-include-optometry-in-the-graduate-medical-education-program-gme/</link>
		
		<dc:creator><![CDATA[Charles Mullen]]></dc:creator>
		<pubDate>Thu, 12 Jul 2012 13:28:26 +0000</pubDate>
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					<description><![CDATA[<p>Clinical education is inherently inefficient and expensive with costs likely to rise. Costs are often passed on to students in the form of higher tuition and debt.</p>
<p>The post <a href="https://www.charlesmullen.com/strategy-to-include-optometry-in-the-graduate-medical-education-program-gme/">Strategy to Include Optometry in the Graduate Medical Education Program (GME)</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
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										<content:encoded><![CDATA[<p><a href="https://www.charlesmullen.com/wp/wp-content/uploads/publications/2012 Strategy to Include Optometry in the GME Program.pdf">Strategy to Include Optometry in the Graduate Medical Education Program (PDF)</a></p>
<p><a href="https://www.charlesmullen.com/wp/wp-content/uploads/publications/2012 Strategy to Include Optometry in the GME Program.ppt">Strategy to Include Optometry in the Graduate Medical Education Program (PPT)</a></p>
<p>The post <a href="https://www.charlesmullen.com/strategy-to-include-optometry-in-the-graduate-medical-education-program-gme/">Strategy to Include Optometry in the Graduate Medical Education Program (GME)</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
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		<title>Illinois College of Optometry Commencement Address (Video &#038; Transcript)</title>
		<link>https://www.charlesmullen.com/illinois-college-of-optometry-commencement-address-by-charles-f-mullen-od/</link>
		
		<dc:creator><![CDATA[Charles Mullen]]></dc:creator>
		<pubDate>Sat, 21 May 2011 17:15:41 +0000</pubDate>
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		<guid isPermaLink="false">https://www.charlesmullen.com/?p=459</guid>

					<description><![CDATA[<p>Efforts must be made to attract more optometrists to medically underserved areas through financial incentives, such as tax free student loan repayment, by including optometrists in the National Health Service Corps.</p>
<p>The post <a href="https://www.charlesmullen.com/illinois-college-of-optometry-commencement-address-by-charles-f-mullen-od/">Illinois College of Optometry Commencement Address (Video &#038; Transcript)</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
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										<content:encoded><![CDATA[<div class="video-container">
<iframe width="640" height="360" src="//www.youtube.com/embed/7T3QJurXDy4?rel=0" frameborder="0" allowfullscreen></iframe>
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<p></p>
<p>Thank you for this high honor. </p>
<p>Trustees, President Augsburger, colleagues, honored guests and above all doctoral degree candidates. </p>
<p>I know you are eager to receive your degrees and celebrate your hard earned achievements, however, as tradition dictates, there will be no degrees until the old guy speaks. </p>
<p>Congratulations on earning your Doctor of Optometry degree.</p>
<p>Today, I join with your families and friends in sharing the pride of your outstanding accomplishments.</p>
<p>Your future is bright with unparalleled practice opportunities.</p>
<p>You have been fortunate for the past four years to be touched by the uncommon power of the ICO experience.</p>
<p>This experience ensures your success in a changing health care environment.</p>
<p>An outstanding faculty has prepared you well for opportunities in the areas of public health, patient care and clinical education.</p>
<p>In the area of public health there is an increasing awareness of unmet visual health needs in medically underserved areas.</p>
<p>And there are opportunities for you to meet the needs of special populations: for those who live in poverty, the homeless, the frail elderly, the homebound, the developmentally disabled and the visually impaired.</p>
<p>The Illinois Eye Institute’s community outreach to the underserved population of Chicago serves as an outstanding example of collaborative medical care.</p>
<p>I hope you will use your ICO training to help others in need.</p>
<p>In patient care, opportunities are available to you in interdisciplinary care as optometrists manage more complex clinical conditions and diseases, requiring close coordination with other professionals.</p>
<p>Also, telemedicine technologies and electronic health records provide the means for more effective patient management. </p>
<p>ICO’s commitment to excellence in patient care is affirmed by grant awards from prestigious organizations and corporations.</p>
<p>The College’s network of over 150 clinical training sites in 47 states and abroad is one of the most extensive in optometry.</p>
<p>In clinical education, there are opportunities for you, as preceptors, by sharing your experiences in: patient-centered education and cooperative clinical training between optometry and ophthalmology. </p>
<p>ICO’s support from external sources for clinical training is the highest of all optometric institutions and is an acknowledgement of the College’s excellence in clinical education.</p>
<p>My education, like yours, prepared me not only to be a competent clinician but also to contribute to the profession’s future.</p>
<p>Your professional status will also provide entree to numerous social, civic and political activities.</p>
<p>In the past, it has been the foresight and persistence of many dedicated individuals to move the profession forward.</p>
<p>You are now called upon to make such a contribution.</p>
<p>Given the aging population, uncertain optometric manpower needs and the impact of national health care reform, there is a need for broad based strategic planning including professional, academic and corporate participation.</p>
<p>I encourage your active involvement at the local, state or national level in planning for your profession’s future.</p>
<p>Current Board Certification and Continued Professional Competency initiatives require your attention and understanding of their place in your profession.</p>
<p>There are unprecedented opportunities for optometry to seek inclusion in three major Federal programs while the federal budget is being re-structured.</p>
<p>These programs could potentially benefit the current generation of optometrists as well as future optometric students, residents and graduates.</p>
<p>The first initiative which is already in progress is the expansion of optometry’s impact in the community health care system.</p>
<p>Community health centers provide accessible and cost effective primary medical care to 20 million Americans in rural areas and poor urban neighborhoods.</p>
<p>However, only 20% of federally qualified health centers offer eye care services, despite the growing need in rural and inner-city America.</p>
<p>Federal funding is required to establish optometric services in all of the Nation’s community health centers.</p>
<p>It is estimated that 5,000 optometrists would be needed in the Nation’s underserved areas over the next decade providing not only new practice opportunities, but also additional student and resident clinical training placements.</p>
<p>The second program is the National Health Service Corps.</p>
<p>Efforts must be made to attract more optometrists to medically underserved areas through financial incentives, such as tax free student loan repayment, by including optometrists in the National Health Service Corps.</p>
<p>Classification of optometry by the Federal government as a Primary Care Profession is a necessary next step to qualify for this program.</p>
<p>Third and long overdue, is optometry’s inclusion in the Graduate Medical Education program, GME, the clinical educational component of Medicare.</p>
<p>Optometrists have been included in the Medicare program since 1987 and currently provide $970 million in services annually to Medicare beneficiaries. </p>
<p>Now it is time to join medicine, dentistry and podiatry as a recipient of GME funding for clinical training.</p>
<p>Optometry’s inclusion in the $9.5 billion program would address: the increasing costs of clinical training and the need for workforce development as the scope of optometric practice continues to expand and growth in the demand for eye care services by the Medicare population.</p>
<p>Although the work ahead will be challenging, inclusion in these three major Federal programs would provide visual health care to tens of thousands of underserved individuals, strengthen the profession of optometry’s position at the national level and forever change the financial landscape of optometric education.</p>
<p>I am confident that the profession’s future leaders are in this Chapel today.</p>
<p>And as those before you, you must move forward with a balance of discretion and audacity.</p>
<p>Be willing to take risks with innovative approaches. </p>
<p>In whatever you do, follow the example of your Alma Mater and strive for pinnacles of excellence.</p>
<p>For in the final analysis, it is neither about financial rewards nor power, but pride in your professional and personal achievements. </p>
<p>Character and contribution will define your success.</p>
<p>Thank you and congratulations.</p>
<p>May 21, 2011</p>
<p>The post <a href="https://www.charlesmullen.com/illinois-college-of-optometry-commencement-address-by-charles-f-mullen-od/">Illinois College of Optometry Commencement Address (Video &#038; Transcript)</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
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		<title>Charles F. Mullen, OD, to Deliver 2011 Illinois College of Optometry Commencement Address</title>
		<link>https://www.charlesmullen.com/charles-f-mullen-od-to-deliver-2011-illinois-college-of-optometry-commencement-address/</link>
		
		<dc:creator><![CDATA[Charles Mullen]]></dc:creator>
		<pubDate>Sat, 21 May 2011 17:05:59 +0000</pubDate>
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					<description><![CDATA[<p>Under his leadership at ICO, Dr. Mullen increased the College's externship sites from 9 to 144, significantly improved students' performance on national board examinations, affiliated ICO with the University of Chicago, and developed and implemented a performance-based strategic plan that positioned ICO for future success.</p>
<p>The post <a href="https://www.charlesmullen.com/charles-f-mullen-od-to-deliver-2011-illinois-college-of-optometry-commencement-address/">Charles F. Mullen, OD, to Deliver 2011 Illinois College of Optometry Commencement Address</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
]]></description>
										<content:encoded><![CDATA[<p>May 19, 2011 (CHICAGO) -The Illinois College of Optometry is proud to announce that Charles F. Mullen, OD, who served as president of the institution from 1996 until 2002, will be the keynote speaker at the 2011 ICO Commencement Ceremony to be held at 11:00 a.m., May 21, at Rockefeller Chapel. Dr. Mullen also will receive the honorary degree, Doctor of Science in Optometry, in recognition of his outstanding contributions to the profession of optometry.</p>
<p>Dr. Mullen has served the profession with great distinction since earning his doctor of optometry degree in 1969 from the New England College of Optometry. He has tirelessly advocated for the interdisciplinary approach to clinical education and patient care, and he successfully led the initiative to certify the first American optometrists in the use of pharmaceutical agents.</p>
<p>Under his leadership at ICO, Dr. Mullen increased the College&#8217;s externship sites from 9 to 144, significantly improved students&#8217; performance on national board examinations, affiliated ICO with the University of Chicago, and developed and implemented a performance-based strategic plan that positioned ICO for future success.</p>
<p>Dr. Mullen has received more than 30 prestigious honors and awards, including being inducted into the National Optometry Hall of Fame for lifetime contributions to the profession. Dr. Mullen serves on the boards of NECO and the Blind and Vision Rehabilitation Services of Pittsburgh and has previously served as chair of the board of directors at the New England Eye Institute.</p>
<h2>About the Illinois College of Optometry</h2>
<p>The Illinois College of Optometry, founded in 1872 by Dr. Henry Olin, provides excellence in optometric clinical education and is among the world&#8217;s leading urban optometric institutions. Located in Chicago, ICO has a distinguished legacy of providing aspiring optometrists the education and experience needed to meet the challenges of a changing health care environment and become leaders who will champion their patients and the profession alike. For more information please visit the <a href="http://www.ico.edu/">Illinois College of Optometry</a> website.</p>
<p>The post <a href="https://www.charlesmullen.com/charles-f-mullen-od-to-deliver-2011-illinois-college-of-optometry-commencement-address/">Charles F. Mullen, OD, to Deliver 2011 Illinois College of Optometry Commencement Address</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
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		<title>Federal Financing of Optometric Clinical Training</title>
		<link>https://www.charlesmullen.com/federal-financing-optometric-clinical-training/</link>
		
		<dc:creator><![CDATA[Charles Mullen]]></dc:creator>
		<pubDate>Tue, 22 Mar 2011 16:08:15 +0000</pubDate>
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					<description><![CDATA[<p>Federal Financing of Optometric Clinical Training Power Point Presentation.</p>
<p>The post <a href="https://www.charlesmullen.com/federal-financing-optometric-clinical-training/">Federal Financing of Optometric Clinical Training</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
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										<content:encoded><![CDATA[<p><a href="https://www.charlesmullen.com/wp/wp-content/uploads/publications/2010_Federal_Financing_of_Optometric_Clinical_.pdf">Federal Financing of Optometric Clinical Training (PDF)</a></p>
<p><a href="https://www.charlesmullen.com/wp/wp-content/uploads/publications/2010_Federal_Financing_of_Optometric_Clinical_.ppt">Federal Financing of Optometric Clinical Training (PPT)</a></p>
<p>The post <a href="https://www.charlesmullen.com/federal-financing-optometric-clinical-training/">Federal Financing of Optometric Clinical Training</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
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