ACGME Common Program Requirements:
Response Guide for Emergency Medicine

Do not delete Review Committee final approval of the program director. The Review Committee for Emergency Medicine has the specialty-specific knowledge to judge whether a candidate is qualified to lead an EM residency; a GMEC does not.

Program director continuity is directly tied to program stability and the resident experience. Frequent turnover is a recognized warning sign, and deleting this requirement removes one of the few early signals the Review Committee has. If the concern is penalizing programs for departures beyond their control, narrow the requirement rather than delete it.

Three years is not a magic number, but it is a reasonable floor. The program director is the single most important determinant of residency quality. The role should be filled by an experienced educational leader, not by the most available faculty member supported by a mentoring plan. A program that cannot field an experienced, expert-level program director should not be a program. Retain the three-year minimum and keep the exception pathway with the Review Committee, which understands the specialty’s needs.

A mentoring plan is a good practice for every new program director; it is not a substitute for the experience requirement. If retained, make it an addition to 2.11, not an alternative to it.

The program director must be a board-certified expert in the specialty of the program. In Emergency Medicine that means current ABEM or AOBEM certification. A GMEC-approved pathway for an individual who is not eligible for certification in the specialty undermines the specialty’s own definition of expertise, and the sponsoring institution does not have the specialty-specific knowledge to make that judgment. The Review Committee must retain the authority to specify that only ABMS/AOA certification in the specialty is acceptable.

Do not delete the Review Committee’s authority to specify additional program director qualifications. EM currently requires ongoing clinical activity, core faculty status, and demonstrated leadership experience; those reflect the realities of running an emergency medicine residency and should remain within the specialty’s control.

I support faculty development in CBME. I do not support the bracketed instruction that specialty-specific supervision requirements “should include flexibility” for supervision by faculty in other specialties. Emergency Medicine residents caring for emergency department patients must be supervised by emergency physicians who completed an EM residency. The current EM requirements already contain defined exceptions for pediatric and low-acuity settings. This language reads as an accommodation for programs that lack sufficient EM faculty, not as a benefit to residents or patients. The Review Committee should retain full authority over supervising-faculty qualifications.

Physician faculty who supervise and teach EM residents must be board certified in Emergency Medicine (ABEM/AOBEM). The GMEC exception process, combined with deleting the Review Committee’s authority to require only ABMS/AOA certification, lowers the faculty qualification standard. Faculty must also be scholars in the field — producing peer-reviewed work and pursuing research and service. The Review Committee, not the GMEC, is the appropriate body to define faculty qualifications for the specialty.

Same objection as 2.24: retain Review Committee authority over physician faculty qualifications.

This is the most damaging change in the proposal for Emergency Medicine. EM currently requires one core faculty member for every three residents. Capping what a Review Committee may require at 1:5 would cut our program’s required core faculty from 13 to 8. Core faculty status is how an academic department gives protected time to physicians who want to build careers in education and scholarship; with mentorship and career development, those faculty grow into the academicians who write the papers, run the trials, lead quality work, and train the next generation. Over the past decade, GME expansion in EM has been dominated by programs outside academic institutions, with smaller academic faculty groups that often support only the required FTE. A 1:5 ceiling will reduce dedicated faculty for didactics, mentorship, and assessment; reduce the number of emergency physicians who develop as academicians; and accelerate divestment from academic Emergency Medicine. The stated rationale — reducing variability across specialties and lowering barriers for small programs — is administrative, not educational. The Review Committee must retain the authority to set the ratio the specialty needs. If a ceiling is retained at all, it must not override a specialty’s existing, more rigorous standard.

Two problems. First, the language moves from what residents must demonstrate to what programs must provide instruction in and assess — an outcome standard becomes a process standard. Second, deleting the Review Committee’s authority to further specify patient care removes the specialty’s ability to define what an emergency physician must be able to do. Graduates of every accredited EM program should have comparable ability at the end of training; that requires specialty-wide standards, not local program expectations, which are not equivalent.

Procedural competence (airway management, resuscitation, procedural sedation, and the rest of the EM procedure list) is the core of emergency medicine training. The Review Committee must retain authority to specify the procedures that define the specialty and the expectation that residents demonstrate competence in them.

Retain Review Committee authority to specify the medical knowledge base of the specialty and the expectation that residents demonstrate it. The common requirement is too general to define any specialty’s knowledge standard.

Pain management and recognition of substance use disorder should remain a common requirement for every specialty with patient contact, not an item a Review Committee may optionally specify. The opioid crisis touches every specialty, and the common requirement was one of the few explicit accreditation levers supporting that education.

The proposed minimum — one qualifying activity every three years, which a single didactic lecture satisfies — is not a scholarship standard. Physician faculty should be scholars in their field: producing peer-reviewed publications and pursuing research and service. The current EM requirement (accomplishment across at least three scholarly domains plus dissemination including peer-reviewed publication) is appropriate and should be preserved. Lowering the floor this far diminishes expectations for generating and disseminating new knowledge across EM and the broader house of medicine. Programs that choose to exceed the floor will be the ones with the resources to do so, widening the gap between academic and non-academic programs and producing a more tiered distribution of training quality.

Once every three years is too infrequent, and the list of qualifying activities is too broad for a minimum. Core faculty should demonstrate scholarly activity annually, and the Review Committee should be able to require peer-reviewed publication across the faculty.

Do not delete the Review Committee’s authority to further specify resident scholarly activity.

Do not delete the eight-hours-off minimum between scheduled work periods. Combined with the deletion of Emergency Medicine’s own “equivalent time off between scheduled ED work periods” requirement, this leaves no minimum turnaround between shifts anywhere in the requirements. Shift-based specialties depend on this protection.

I do not object to the at-home call language. I object to deleting the bracket “[The Review Committee may further specify under any requirement in 6.29–6.39].” That bracket is the mechanism that lets Emergency Medicine keep its shift-length and weekly-hour limits. Deleting it removes the specialty’s ability to set any work-hour standard stricter than the common ceiling. The rationale offered — consistency across specialties and institutional scheduling burden — is administrative, not educational. The ACGME should set the floor and allow each specialty to adapt the requirements to the realities of its field. Retain Review Committee authority to further specify under 6.29–6.39.