100+ Free ABEM HPM Practice Questions

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Question 1

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According to the WHO analgesic ladder, what is the recommended FIRST step for mild cancer pain?

Strong opioid such as morphine

Non-opioid (acetaminophen or NSAID) with or without an adjuvant

Weak opioid such as codeine

Methadone

to track

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2026 Statistics

Key Facts: ABEM HPM Exam

~220

HPM Exam Questions (Single Day)

ABMS HPM Exam Information

~10 hours

Total Test Day Length at Pearson VUE

ABIM HPM Exam Schedule

$2,375

ABEM HPM Application + Exam Fee (approximate)

ABEM Subspecialty Fee Schedule

~85-90%

First-Time Pass Rate (All Sponsoring Boards)

ABMS HPM Pass Rate Data

12 months

ACGME HPM Fellowship Required

ACGME Program Requirements for HPM

Every 2 years

Exam Administration (Fall of Odd Years)

ABIM HPM Exam Calendar

The ABEM Hospice and Palliative Medicine (HPM) subspecialty exam is a multi-board ABMS examination that ABEM credentials and issues the certificate for emergency-medicine diplomates. The exam itself is co-sponsored by 11 ABMS boards (ABIM, ABFM, ABP, ABPN, ABA, ABS, ABOG, AOA, ABEM, ABR, and ABPM&R) and administered by ABIM. It is a single-day computer-based examination delivered at Pearson VUE testing centers - approximately 220 single-best-answer multiple-choice questions split across two sessions, with total seat time of about 10 hours including breaks. The exam fee is approximately $2,375 (varies by year). Content blueprint covers pain management (~20%), non-pain symptoms (~18%), communication and goals of care (~12%), Medicare Hospice Benefit and eligibility (~10%), prognostication (~8%), ethics at end of life (~8%), palliative emergencies (~6%), advance care planning/POLST (~6%), pediatric palliative care (~5%), spiritual/psychosocial/bereavement (~4%), and interdisciplinary team (~3%). Eligibility for ABEM diplomates requires active ABEM primary certification plus successful completion of an ACGME-accredited 12-month HPM fellowship. The exam is offered every two years (typically odd-numbered fall years - next administration expected fall 2027). Continuous certification is maintained via the ABEM HPM Longitudinal Assessment (HPM-LA), a quarterly question delivery program similar to ABIM's LKA. Hospice and palliative care is one of the fastest-growing physician subspecialties, with the U.S. Bureau of Labor Statistics SOC 29-1228 (Physicians, All Other) median wage above $230,000 and continued strong demand projected through 2034 as the population ages.

Sample ABEM HPM Practice Questions

Try these sample questions to test your ABEM HPM exam readiness. Each question includes a detailed explanation. Start the interactive quiz above for the full 100+ question experience with AI tutoring.

1According to the WHO analgesic ladder, what is the recommended FIRST step for mild cancer pain?

A.Strong opioid such as morphine

B.Non-opioid (acetaminophen or NSAID) with or without an adjuvant

C.Weak opioid such as codeine

D.Methadone

Explanation: The WHO analgesic ladder begins with non-opioid analgesics (acetaminophen or NSAIDs) with or without an adjuvant for mild pain (Step 1). Step 2 adds a weak opioid (codeine, tramadol) for moderate pain, and Step 3 uses strong opioids (morphine, oxycodone, hydromorphone) for severe pain. Adjuvants (such as anticonvulsants, antidepressants, or corticosteroids) may be added at any step. The ladder is intended as a starting framework; in practice, severe cancer pain often requires moving directly to Step 3.

2A patient is taking morphine 30 mg PO every 4 hours around the clock. What is the approximately equianalgesic IV morphine 24-hour dose?

A.30 mg IV per 24 hours

B.60 mg IV per 24 hours

C.90 mg IV per 24 hours

D.180 mg IV per 24 hours

Explanation: The patient takes 30 mg PO morphine x 6 doses = 180 mg PO morphine per 24 hours. Oral to IV morphine ratio is 3:1, so 180 mg PO ÷ 3 = 60 mg IV per 24 hours. Standard equianalgesic conversions: morphine 10 mg IV ≈ 30 mg PO. Always verify with a published conversion table and consider reducing the new dose 25-50% for incomplete cross-tolerance when changing opioids.

3A patient is on long-acting morphine 60 mg PO every 12 hours. What is an appropriate breakthrough (rescue) dose of immediate-release morphine?

A.1-2 mg PO q4h PRN

B.12-24 mg PO q1-2h PRN

C.60 mg PO q1h PRN

D.120 mg PO q4h PRN

Explanation: Breakthrough dosing is typically 10-20% of the total 24-hour scheduled opioid dose. This patient's 24-hour dose is 60 mg x 2 = 120 mg PO morphine. 10-20% = 12-24 mg PO immediate-release morphine, available every 1-2 hours PRN. If breakthrough doses are required more than 3-4 times per day, the scheduled dose should be increased to incorporate the breakthrough requirement.

4When rotating from one opioid to another in a patient with stable pain, what dose adjustment is generally recommended for the new opioid?

A.Increase the calculated equianalgesic dose by 25-50%

B.Use 100% of the calculated equianalgesic dose

C.Reduce the calculated equianalgesic dose by 25-50%

D.Reduce the calculated equianalgesic dose by 75-90%

Explanation: When rotating opioids, the calculated equianalgesic dose of the new opioid should be reduced by 25-50% to account for incomplete cross-tolerance — the phenomenon where tolerance to one opioid does not fully transfer to another. A larger reduction (50-75%) is appropriate when the patient is elderly, frail, has well-controlled pain, or when rotating to methadone (which has even more variable conversion). Always provide adequate breakthrough doses during the transition.

5Which statement about methadone for cancer pain is MOST accurate?

A.Methadone has a fixed equianalgesic ratio of 1:1 with morphine

B.Methadone conversion ratios vary with the prior opioid dose; higher prior doses require larger reductions

C.Methadone can be safely titrated daily because of its short half-life

D.Methadone has no risk of QTc prolongation

Explanation: Methadone is unique because the conversion ratio with morphine is dose-dependent: at lower morphine equivalents (<100 mg/day) the ratio may be 3-4:1 (morphine:methadone), but at higher doses (>500 mg/day) it can be 12-20:1 or more — meaning higher prior opioid doses require proportionally larger reductions. Methadone has a long, variable half-life (8-59 hours), so titration must be done slowly (every 4-7 days). It can prolong the QTc and cause torsades; baseline ECG and periodic monitoring are recommended.

6Which class of medication is considered FIRST-LINE for neuropathic pain in palliative care?

A.NSAIDs

B.Anticonvulsants such as gabapentin or pregabalin

C.Topical capsaicin only

D.Short-acting opioids alone

Explanation: First-line agents for neuropathic pain include gabapentinoids (gabapentin, pregabalin), serotonin-norepinephrine reuptake inhibitors (duloxetine, venlafaxine), and tricyclic antidepressants (nortriptyline, amitriptyline). These are evidence-based and recommended by NeuPSIG, IASP, and palliative care guidelines. Opioids may be added but are second-line for chronic neuropathic pain. NSAIDs alone are not effective for true neuropathic pain. Topical agents (capsaicin, lidocaine 5%) can help focal neuropathic pain but are often adjunctive.

7A patient with metastatic prostate cancer has localized severe pain from a vertebral metastasis. Which palliative radiation regimen has shown equivalent pain relief to multi-fraction therapy with greater convenience?

A.8 Gy in a single fraction

B.30 Gy in 10 fractions

C.60 Gy in 30 fractions

D.Stereotactic body radiotherapy 24 Gy in 1 fraction

Explanation: Single-fraction palliative radiation of 8 Gy provides equivalent pain relief to multi-fraction regimens (such as 30 Gy in 10 fractions or 20 Gy in 5 fractions) for uncomplicated bone metastases, per multiple meta-analyses (Chow 2007, RTOG 9714). Single-fraction is more convenient for patients with limited prognosis but has higher retreatment rates. Bisphosphonates and denosumab are also used for diffuse bone pain, and NSAIDs are first-line systemic adjuvants for inflammatory bone pain.

8A patient on chronic opioids develops constipation refractory to scheduled senna and polyethylene glycol. Which medication is specifically indicated for opioid-induced constipation?

A.Loperamide

B.Methylnaltrexone (peripherally acting mu-opioid receptor antagonist)

C.Naloxone IV

D.Lactulose alone

Explanation: Methylnaltrexone, naloxegol, and naldemedine are peripherally acting mu-opioid receptor antagonists (PAMORAs) that block opioid effects in the gut without crossing the blood-brain barrier — preserving central analgesia while reversing constipation. They are indicated when conventional laxatives (stimulant + osmotic) have failed. Lubiprostone is also approved for OIC. Loperamide is for diarrhea. IV naloxone would reverse analgesia and precipitate withdrawal. All patients on scheduled opioids should also receive prophylactic stimulant laxatives.

9A patient with malignant spinal cord compression has severe back pain. In addition to opioid analgesia and urgent radiation, which adjuvant should be initiated immediately?

A.Gabapentin 100 mg TID

B.High-dose dexamethasone (10 mg IV bolus, then 4 mg q6h)

C.NSAIDs alone

D.Bisphosphonate IV

Explanation: Suspected malignant spinal cord compression requires immediate high-dose dexamethasone (typical regimen: 10 mg IV bolus followed by 4 mg PO/IV every 6 hours) to reduce edema and preserve neurologic function while urgent MRI of the whole spine and radiation oncology / neurosurgery consultation are arranged. Steroids also provide analgesia for cord compression and many bone pain syndromes. Gabapentin and bisphosphonates may have a role in chronic management but are not the immediate priority.

10A patient on high-dose morphine develops new-onset myoclonus, hyperalgesia, and confusion. What is the MOST appropriate next step?

A.Increase the morphine dose to control the new pain symptoms

B.Rotate to a different opioid (e.g., hydromorphone or fentanyl) at a reduced equianalgesic dose

C.Add a benzodiazepine to control myoclonus and continue current opioid

D.Stop all opioids abruptly

Explanation: Opioid-induced neurotoxicity (OIN) — myoclonus, hyperalgesia (paradoxically worse pain with higher doses), allodynia, delirium — typically occurs with accumulated active metabolites (especially morphine-3-glucuronide). Management is opioid rotation to an agent with different metabolism (hydromorphone, fentanyl, methadone) at a reduced equianalgesic dose (often 50-75% of calculated dose), plus aggressive hydration if the patient is volume-depleted. Increasing the offending opioid worsens symptoms. Abrupt cessation causes withdrawal and inadequate pain control.

About the ABEM HPM Exam

The ABEM Hospice and Palliative Medicine (HPM) subspecialty certification is the recognized credential for emergency physicians who complete an ACGME-accredited 12-month HPM fellowship. The exam is a multi-board collaboration co-sponsored by 11 ABMS member boards and administered by ABIM via Pearson VUE: a single-day computer-based exam of approximately 220 single-best-answer MCQs over ~10 hours. Content covers pain and non-pain symptom management, communication and goals-of-care, the Medicare Hospice Benefit, prognostication, ethics at end of life, advance care planning and POLST, palliative emergencies, pediatric palliative care, and interdisciplinary teamwork. ABEM diplomates qualify by holding active ABEM primary certification plus completing an ACGME HPM fellowship.

Questions

220 scored questions

Time Limit

Single test day ~10 hours total at Pearson VUE (two sessions plus breaks)

Passing Score

Criterion-referenced pass/fail (scaled score by ABMS HPM standard-setting)

Exam Fee

ABEM HPM application + exam fee ~$2,375 (varies by year) (American Board of Emergency Medicine (ABEM) - exam co-sponsored and administered by ABIM on behalf of 11 ABMS boards)

ABEM HPM Exam Content Outline

~20%

Pain Management

WHO ladder; opioid pharmacology and equianalgesic conversion (morphine 10 mg IV ≈ 30 mg PO ≈ oxycodone 20 mg PO ≈ hydromorphone 1.5 mg IV ≈ 7.5 mg PO); incomplete cross-tolerance reduce 25-50% on rotation; methadone variable conversion (use published tables, start low); breakthrough = 10-20% of 24h dose; neuropathic adjuvants (gabapentin, pregabalin, duloxetine, TCAs); bone pain (NSAIDs, bisphosphonates, palliative XRT 8 Gy single fraction); PAMORAs (methylnaltrexone, naloxegol) for OIC; opioid-induced neurotoxicity (myoclonus, hyperalgesia).

~18%

Non-Pain Symptom Management

Dyspnea: low-dose opioids first-line (morphine 2.5-5 mg PO q4h); O2 only if SpO2 <90%; fan to face; benzo for anxiety component. Nausea: cause-based (haloperidol for opioid/uremic; metoclopramide for gastroparesis; ondansetron for chemo; dexamethasone + octreotide for malignant bowel obstruction; olanzapine 2.5-5 mg as broad-spectrum). Terminal delirium: haloperidol 0.5-2 mg; benzos worsen. Anorexia/cachexia: mirtazapine; dexamethasone or megestrol short-term; avoid olanzapine for survival. Secretions: glycopyrrolate, hyoscyamine, scopolamine. Constipation: prophylactic stimulant laxative with all opioids.

~12%

Communication & Goals of Care

SPIKES (Setting, Perception, Invitation, Knowledge, Emotion, Strategy); NURSE empathy statements (Name, Understand, Respect, Support, Explore); 'Ask-Tell-Ask'; REMAP for goals-of-care (Reframe, Expect emotion, Map values, Align, Plan); Serious Illness Conversation Guide (Ariadne Labs); family meetings; cultural humility; AND (Allow Natural Death) language preferred over DNR; honest prognosis with hope ('hope for the best, prepare for the worst').

~10%

Hospice Eligibility & Medicare Benefit

Medicare Hospice Benefit eligibility: ≤6-month prognosis if disease runs usual course, certified by attending + hospice medical director. Four levels: routine home, continuous home (crisis), general inpatient (GIP - acute symptom control), respite (≤5 days). LCDs: heart failure NYHA IV; COPD with hypoxemia; dementia FAST 7C + complications. Hospice waives curative Medicare A for terminal Dx. Recertifications: two 90-day, then unlimited 60-day; face-to-face encounter required at 3rd benefit period. Concurrent care for children under ACA Section 2302.

~8%

Prognostication

Surprise question ('Would I be surprised if this patient died in 12 months?'). Tools: Palliative Performance Scale (PPS), Karnofsky (KPS), ECOG. PPS ≤40% suggests weeks-to-months. Disease-specific: Seattle Heart Failure Model, BODE for COPD, FAST for dementia (7C eligible for hospice), PaP and PPI for cancer. Functional decline is strongest non-cancer predictor. Communicate prognosis as ranges (hours-to-days, days-to-weeks, weeks-to-months, months-to-years). Active dying signs: mottling, Cheyne-Stokes, terminal secretions, decreased oral intake, withdrawal.

~8%

Ethics in End-of-Life Care

Withholding = withdrawing (ethically and legally equivalent). Principle of double effect (intent matters; symptom relief is OK even if hastens death). Surrogate hierarchy varies by state. Substituted judgment > best interests when patient preferences known. AND orders. Medical Aid in Dying (MAID): legal in 10 states + DC; requires two oral + one written request, two clinicians, ≤6-month prognosis, self-administered. Palliative sedation for refractory symptoms is proportionate, not euthanasia. Conflicts → ethics consult.

~6%

Advance Care Planning & POLST

Advance directive (legal document - living will + healthcare power of attorney/DPOAHC) vs POLST/MOLST (actionable medical order, signed by clinician, travels across settings, intended for serious illness or 1-year mortality). POLST complements but does not replace advance directives. Five Wishes is a popular advance directive format. Conversation Project resources. Ensure surrogate knows patient values; revisit at every health change.

~6%

Palliative Emergencies

Spinal cord compression: urgent MRI whole spine, dexamethasone 10 mg IV bolus then 4 mg q6h, radiation oncology + neurosurgery consult; goal preserve ambulation. SVC syndrome: head elevation, dexamethasone, urgent oncology - endovascular stenting often first-line for malignant cause. Malignant hypercalcemia: IV NS, IV bisphosphonate (zoledronic acid) or denosumab, calcitonin for rapid 24-48h effect, avoid loop diuretics unless volume overloaded. Hemorrhage: dark towels, midazolam 5-10 mg for sedation, family preparation. Seizures: benzo first-line, phenobarbital subcutaneous in hospice.

~5%

Pediatric Palliative Care

ACA Section 2302 concurrent care: children on Medicaid/CHIP can receive curative + hospice simultaneously. Perinatal palliative care for lethal anomalies. Developmental approach to discussing death (preschool: magical thinking; school-age: concrete; adolescent: abstract). Family-centered decision-making; sibling support; weight-based opioid dosing (morphine 0.05-0.1 mg/kg). Complex chronic conditions (CCC). Trisomy 18, severe neurologic impairment, NICU/PICU end-of-life, organ donation discussions.

~4%

Spiritual, Psychosocial & Bereavement

FICA spiritual history (Faith, Importance, Community, Address). HOPE tool. Chaplaincy as core IDT. Distinguish demoralization (loss of meaning) vs depression (anhedonia, guilt) vs anticipatory grief. Complicated grief = Prolonged Grief Disorder in DSM-5-TR (≥12 months; intense yearning, identity disruption, avoidance). Dual process model (Stroebe). Medicare requires hospices to provide bereavement support for 13 months post-death. Risk factors for complicated grief: sudden death, young age of deceased, dependent relationship, prior mental illness.

~3%

Interdisciplinary Team & Care Settings

Hospice IDT (per Medicare): physician (medical director), RN, MSW, chaplain; plus aide, volunteer, bereavement coordinator, pharmacist. IDT meeting ≥every 15 days. Primary palliative care (any clinician) vs secondary (specialist). Inpatient palliative consult service vs hospice unit (GIP) vs home hospice vs nursing-home hospice. Community-based palliative care (often non-Medicare). Palliative care in the ED for rapid goals-of-care discussions before admission.

How to Pass the ABEM HPM Exam

What You Need to Know

Passing score: Criterion-referenced pass/fail (scaled score by ABMS HPM standard-setting)
Exam length: 220 questions
Time limit: Single test day ~10 hours total at Pearson VUE (two sessions plus breaks)
Exam fee: ABEM HPM application + exam fee ~$2,375 (varies by year)

Keys to Passing

Complete 500+ practice questions
Score 80%+ consistently before scheduling
Focus on highest-weighted sections
Use our AI tutor for tough concepts

ABEM HPM Study Tips from Top Performers

1Anchor your study to the ABMS HPM exam blueprint - it is freely available and maps directly to exam content; use it as a personal checklist throughout your 12-month fellowship rather than cramming in the final month

2Master opioid equianalgesic conversions cold - know morphine 10 mg IV ≈ 30 mg PO ≈ oxycodone 20 mg PO ≈ hydromorphone 1.5 mg IV ≈ 7.5 mg PO, reduce 25-50% for incomplete cross-tolerance on rotation, breakthrough is 10-20% of 24h scheduled dose, and methadone uses variable published conversion ratios (always start low, titrate slowly, watch QTc)

3Learn the Medicare Hospice Benefit rules at regulation level - 6-month prognosis, four levels (routine home, continuous home, general inpatient/GIP, respite ≤5 days), two 90-day periods then unlimited 60-day with face-to-face at 3rd period, LCDs for heart failure/COPD/dementia (FAST 7C), and ACA Section 2302 concurrent care for children

4Drill communication frameworks until they are automatic - SPIKES for breaking bad news, NURSE for empathy statements, REMAP for goals-of-care discussions, the Serious Illness Conversation Guide from Ariadne Labs, and the cultural humility framework; many exam questions are vignettes asking you to choose the next best statement

5Use AAHPM HPM PASS and the UNIPAC series as your foundation, then add a question bank (BoardVitals or TrueLearn HPM) for 1,500-2,000 timed questions in the final 4-6 months; complement with CAPC online modules for case-based learning and review the Oxford Textbook of Palliative Medicine or AAHPM Primer for deep-dive on weak topics

Frequently Asked Questions

What is the ABEM Hospice and Palliative Medicine (HPM) exam and how is it structured?

The ABEM HPM exam is a subspecialty certification examination for emergency physicians who have completed an ACGME-accredited 12-month Hospice and Palliative Medicine fellowship. The exam is co-sponsored by 11 ABMS member boards (ABIM, ABFM, ABP, ABPN, ABA, ABS, ABOG, AOA, ABEM, ABR, ABPM&R) and is administered by ABIM via Pearson VUE testing centers. It is a single-day computer-based examination of approximately 220 single-best-answer multiple-choice questions split across two sessions, with total seat time of about 10 hours including breaks. ABEM is the credentialing board that issues the HPM certificate to its emergency-medicine diplomates.

Who is eligible to take the ABEM HPM subspecialty exam?

ABEM diplomates must hold active ABEM primary certification in Emergency Medicine and have successfully completed an ACGME-accredited 12-month Hospice and Palliative Medicine fellowship. An active unrestricted medical license is required. Eligibility to sit for initial certification is valid for 7 years post-fellowship under ABMS rules. Physicians from other primary specialties (internal medicine, family medicine, pediatrics, etc.) qualify through their respective sponsoring boards but take the same exam.

How much does the ABEM HPM exam cost in 2026?

The ABEM HPM application + exam fee is approximately $2,375 (fees vary year-to-year and by sponsoring board). Total preparation cost typically runs $3,500-$5,500 including AAHPM HPM PASS or UNIPAC self-study modules (~$300-$700), question banks like BoardVitals or TrueLearn (~$300-$500), reference texts (Oxford Textbook of Palliative Medicine or AAHPM Primer ~$100-$200), AAHPM membership (~$430/year), and travel to a Pearson VUE testing center.

When is the ABEM HPM exam offered and how do I register?

The HPM exam is administered every 2 years, typically in the fall of odd-numbered years (the next administration is expected fall 2027). Application opens through ABEM's subspecialty certification portal in spring of the exam year. Once your application is verified, ABIM (the test administrator) provides authorization to schedule at any Pearson VUE testing center. Registration deadlines and late fees are published annually; missing the standard deadline typically incurs a late fee of several hundred dollars.

What are the highest-yield topics on the HPM exam?

High-yield content per the ABMS HPM blueprint: pain management (opioid pharmacology, equianalgesic conversions especially methadone, breakthrough dosing 10-20% of 24h dose, neuropathic adjuvants, bone pain), non-pain symptoms (dyspnea with low-dose opioids, nausea by mechanism, terminal delirium with haloperidol, secretions with glycopyrrolate), Medicare Hospice Benefit (eligibility ≤6 months, four levels of care, recertification rules, LCDs for non-cancer diagnoses), communication frameworks (SPIKES, NURSE, REMAP), POLST vs advance directives, palliative emergencies (spinal cord compression, SVC syndrome, hypercalcemia, hemorrhage), pediatric concurrent care under ACA Section 2302, ethics (withdrawal vs withholding equivalence, double effect, MAID basics), and prognostication tools (PPS, KPS, surprise question, FAST for dementia).

What is the HPM Longitudinal Assessment (HPM-LA) for continuous certification?

After initial HPM certification, ABEM diplomates maintain their subspecialty credential through the HPM Longitudinal Assessment (HPM-LA) - a quarterly question delivery program modeled on ABIM's Longitudinal Knowledge Assessment (LKA) that has replaced the traditional 10-year recertification exam at most boards. Diplomates receive ~30 questions per quarter (open-book, asynchronous, on their schedule), pay an annual fee, hold an active license, and agree to the Code of Professionalism. ABEM diplomates must also maintain primary EM certification via MyEMCert.

How should I prepare for the ABEM HPM exam?

Build preparation into your 12-month HPM fellowship. Use the ABMS HPM exam blueprint as your study checklist. Core resources: AAHPM HPM PASS (Hospice and Palliative Care Assessment) and the 9-module UNIPAC self-study series; the Oxford Textbook of Palliative Medicine (5th edition) or the AAHPM Primer of Palliative Care as references; question banks (AAHPM Self-Study Examination, BoardVitals HPM, TrueLearn HPM) - target 1,500-2,000 questions in the final 4-6 months; CAPC modules for case-based communication; CMS Medicare Hospice Benefit regulations. Take two full-length timed practice exams in the final month. Total dedicated study typically runs 200-400 hours on top of clinical fellowship work.

What is the difference between hospice and palliative care?

Palliative care is specialized medical care for people living with serious illness, focused on relief from symptoms and stress at any stage of illness, alongside curative treatment. It is appropriate from diagnosis and is delivered in any setting (hospital, clinic, home). Hospice is a Medicare-defined benefit and a subset of palliative care for patients with a life expectancy of ≤6 months who choose comfort-focused care over disease-directed treatment for their terminal diagnosis. Hospice is delivered by an interdisciplinary team primarily at home (or in a hospice inpatient unit/nursing home/hospital GIP bed) and waives curative Medicare A coverage for the terminal diagnosis - though concurrent care is allowed for children under ACA Section 2302.