STATE OF WISCONSIN
Podiatry Affiliated Credentialing Board
IN THE MATTER OF RULEMAKING PROCEEDINGS BEFORE THE
PODIATRY AFFILIATED CREDENTIALING BOARD
PROPOSED ORDER OF THE PODIATRY AFFILIATED CREDENTIALING BOARD
(CLEARINGHOUSE RULE )
An order of the Podiatry Affiliated Credentialing Board to repeal Pod 1.05; to renumber and amend Pod 1.08 (2) and 1.09 (2); to amend Pod 1.01, 1.02 (intro.), 1.03 (title), (intro.), and (1), 1.06 (1) (a) (intro.), (2), and (4), 1.08 (1) (a) (Note), 1.09 (1) (a) (Note), and 1.10 (1) (a) and (b) (Note); and to create Pod 1.03 (1) (Note) and (3), relating to licensure requirements.
Analysis prepared by the Department of Safety and Professional Services.
Explanation of agency authority:
Section 15.085 (5) (b), Stats., provides affiliated credentialing boards “[s]hall promulgate rules for its own guidance and for the guidance of the trade or profession to which it pertains. . .” The proposed rule seeks to provide guidance within the profession on licensure requirements. Section 440.071 (1), Stats., provides “. . . the department or a credentialing board or other board in the department may not require a person to complete any postsecondary education or other program before the person is eligible to take an examination for a credential the department or credentialing board or other board in the department grants or issues.” Section 448.695 (2), Stats., provides “[t]he affiliated credentialing board may promulgate rules to carry out the purposes of this subchapter.”
Related statute or rule:
Plain language analysis:
Pursuant to 2013 Wisconsin Act 114, the Department of Safety and Professional Services and its attached boards may no longer require any person to complete any postsecondary education before the person is eligible to take an examination for a credential. In accordance with this legislation, the proposed rules revise ch. Pod 1 to allow applicants seeking licensure as a podiatrist to take their credentialing exam before completing any postsecondary education. The Podiatry Affiliated Credentialing Board conducted a comprehensive review of ch. Pod 1 to ensure the rules are consistent with current professional, academic, and licensing practices and applicable Wisconsin statutes. The resulting changes are to update references and notes in ss. Pod 1.01, 1.02, 1.06 (2), 1.08 (1) (a), 1.09 (1) (a), and 1.10 (1) (b).
Summary of, and comparison with, existing or proposed federal regulation:
Comparison with rules in adjacent states:
An applicant for the National Board of Podiatric Medical Examiners (NBPME) PM Lexis examination for licensure as a podiatric physician must file an application at least 60 days prior to an examination date. The application must include: (1) A complete work history indicating all employment since graduation from an approved podiatric medical program; (2) Certification of graduation from an approved podiatric medical program; (3) Proof of passage of Part I and Part II of the examination given by the National Board of Podiatric Medical Examiners (NBPME) by NBPME standards; (4) Certification from the jurisdictions of the United States in which the applicant was originally licensed and is currently licensed, if applicable, stating: (a) The time during which the applicant was licensed in that jurisdiction, including the date of the original issuance of the license; and (b) Whether the file on the applicant contains any record of disciplinary actions taken or pending; and (5) The required fee (68 Ill. Admin. Code 1360.45).
Iowa Administrative Code does not explicitly state that an applicant for a license as a podiatrist must complete the required education prior to taking the examination for licensure (645 IAC 220.2 and 220.3).
To be eligible for part III of the podiatric examination administered by the NBPME, an applicant must submit an application for licensure together with the requisite fee. To assure eligibility to sit for the nbpme examination, an applicant must submit his or her completed application not less than 30 days before the date of the examination (Mich Admin Code, R 338.8104).
Minnesota Statutes and Administrative code do not explicitly state that an applicant for a license as a podiatrist must complete the required education prior to taking the examination for licensure (Minnesota Rules, Part 6900.0020; Minnesota Statutes s. 153.16).
Summary of factual data and analytical methodologies:
The proposed rules were developed by reviewing the provisions of 2013 Wisconsin Act 114 in conjunction with the current rules relating to licensure under ch. Pod 1 and obtaining input and feedback from the Podiatry Affiliated Credentialing Board.