Last Updated: Aug 14, 2020
Final-form regulations increasing the licensure and renewal fees for all practitioners licensed by the State Board of Osteopathic Medicine were published in the August 15, 2020 edition of the Pennsylvania Bulletin.
View the final-form regulations here.
The regulations take effect immediately. This means that licensure and renewal fee increases for practitioners licensed by the Board are now in effect. Note these increases apply to osteopathic physicians (DOs) and not allopathic physicians (MDs).
These regulations increase licensure application and renewal fees for the next three licensure periods. The fee increases for DOs are as follows:
- 2020 licensure period:
- Application fees would increase from $45 to $170.
- Licensure renewal fees would increase from $220 to $330.
- 2022 licensure period:
- Application fees would increase from $170 to $185.
- Licensure renewal fees would increase from $330 to $420.
- 2024 licensure period:
- Application fees would increase from $185 to $205.
- Licensure renewal fees would increase from $420 to $450.
Please review the final-form regulations for information regarding fee increases for other practitioners licensed by the Board.
Background of Fee Increases
On March 7, 2020, the Board issued proposed regulations seeking to increase both application fees and licensure fees for practitioners under the authority of the Board. The Board cited these fee increases as necessary for its revenues to meet its expenses. For the past few fiscal years, the Board has had to use its reserve funds to cover its expenses. State licensure boards receive no funding from the general fund and almost all their revenue comes from licensure fees.
PAMED submitted comments, including questions concerning how the fees would be implemented over the proposed three-cycle licensure period.
On May 6, 2020, the Independent Regulatory Review Commission (IRRC), the government entity that approves or disapproves proposed regulations issued by government agencies, published its comments to the proposed fee increases set forth by the Board.
In its comments, IRRC reiterated concerns expressed by PAMED and the Pennsylvania Osteopathic Medical Association relating to how the biennial fee increases would be implemented if the rulemaking were not finalized before the start of the biennial renewal period beginning on November 1, 2020. IRRC noted that the Board should ensure that if it plans to go through with these regulations that they be finalized and effective in advance of the opening of the biennial renewal period.
In addition, IRRC noted comments submitted by the House Professional Licensure Committee that recommended that the proposed rulemaking be delayed until after the end of the COVID-19 emergency. IRRC reiterated comments submitted by individual physicians arguing that imposing fee increases at this time is not reasonable and would harm them financially. IRRC agreed with these commentators and specifically asked the Board to withdraw the proposed regulations and resubmit them later.
View the regulatory package, as well as all public comments submitted, here.
Board Response to Comments Submitted and Approval of Final Rulemaking
After reviewing the comments summited, the Board voted to move forward with the proposed fee increases. However, due to decreased expenditures during the COVID-19 pandemic, the proposed fees for physician renewal were readjusted and decreased from the initial proposal.
The Board submitted final-form regulations to IRRC for final determination. IRRC considered these regulations at its July 16, 2020 meeting and voted to approve the final-form regulatory package.
In the final-form regulations, the Board summarized and responded to comments that were submitted during the 30-day public comment. Regarding the necessity of the increases, the Board noted that it is statutorily obligated to increase fees by regulation when revenues raised by fees, fines and civil penalties under the act are insufficient to meet expenditures over a two-year period.
The Board responded to PAMED’s concerns over implementation of the proposed increases. The Board cited that it believes it has enough time to implement the increases before the renewal period opens later this summer.
What Happens Next?
The regulations take effect immediately. This means that for the upcoming renewal period, DO renewal fees are increased from the previous $220 to $330.