The One Where I Try to Guess What the AMA CEJA Report 1-A-11 Means

If you’ve come here seeking answers about what the AMA’s passing of CEJA report 1-A-11 means to the CME community, let me assure you that you are in the wrong place. I have no idea what it means. I’m not even exactly sure how I feel about it. The Alliance for CME certainly doesn’t seem to be a big fan of it; they didn’t like it before it was passed, and they don’t like it now. Medical Meetings columnist Stephen Lewis shares similar feelings and Sue Pelletier agrees with him. On the other side of the spectrum, Dr. Carlat celebrates the AMA’s decision with a picture of a popping champagne cork. Tom Sullivan shares his opinion on his Policy and Medicine blog and seems fairly middle-of-the-road about it.

But no one seems to know what’s going to happen next, so I thought, what the heck, I’m going to guess. Am I qualified to do this? Pfft…no. Are my predictions going to be wrong? Most likely yes, but I do get tired of being right all the time (that was a joke, people, only a joke…) So, without further ado, here are each of the recommendations from CEJA report 1-A-11 along with my prediction/guess as to how it will play out in the future. And as a special nod to the AMA CEJA, I’ve done this with absolutely no empirical evidence to back me up (yes, yes, more jokes…).

(a) be transparent about financial relationships that could potentially influence educational activities.
OK, good, this is an easy one. Obviously, this is already covered by the ACCME’s Standards for Commercial Support and is already being done by CME providers, so there should be no need for any further action (right? RIGHT?).

(b) provide the information physician-learners need to make critical judgments about an educational activity, including: (i) the source(s) and nature of commercial support for the activity; and/or…
Right. Again, covered by the SCS and already being done.

…(ii) the source(s) and nature of any individual financial relationships with industry related to the subject matter of the activity; and…
SCS. Being done. Sheesh.

…(iii) what steps have been taken to mitigate the potential influence of financial relationships.
Hmmm. Resolving conflicts of interest is certainly part of the SCS, but there has not been any requirement of public disclosure of this process on a per activity basis. Looking into my crystal ball, I see a requirement that providers describe their COI resolution process in the front matter of all activities…which nobody will read. Moving on.

(c) protect the independence of educational activities by: (i) ensuring independent, prospective assessment of educational needs and priorities…
As long as they keep repeating things from the ACCME’s SCS and accreditation criteria, this might not be too bad…

…(ii) adhering to a transparent process for prospectively determining when industry support is needed…
I assume this goes hand-in-hand with this recommendation from earlier in the narrative:

When possible, CME should be provided without such support or the participation of individuals who have financial interests in the educational subject matter.
In some circumstances, support from industry or participation by individuals who have financial interests in the subject matter may be needed to enable access to appropriate, high-quality CME. In these circumstances, physician-learners should be confident that that vigorous efforts will be made to maintain the independence and integrity of educational activities.
I see 3 different scenarios in how this might play out:
  1. This is the death knell for industry supported CME in all but the most extreme cases of financial need
  2. Business as usual, but make sure you can show us that your CME activity budgets are legitimate and that you’re really using commercial support for what you’re supposed to be using it for.
  3. Somewhere in between
How’s that for covering all my bases? Oh, we’re not done.

…(iii) giving preference in selecting faculty or content developers to similarly qualified experts who do not have financial interests in the educational subject matter…
You know what? I’m cool with this. If I am deciding between two faculty members who are similarly qualified and one of them has industry relations and one doesn’t, sure, I’ll give preference to the one with no relationships. If that makes everyone happy, I’m glad to do it. I’m curious how this will be documented, though. Am I going to have to show every single potential candidate for a faculty position, their credentials, and their disclosure information? And someone from the AMA is going to look at all of these and decide whether or not I chose the right person? That would be kind of a pain…and highly unlikely.

…(iv) ensuring a transparent process for making decisions about participation by physicians who may have a financial interest in the educational subject matter…
I know I sound like a broken record but, again, this reaffirms the SCS and is already being done (or should be) by CME providers.

… (v) permitting individuals who have a substantial financial interest in the educational subject matter to participate in CME only when their participation is central to the success of the educational activity; the activity meets a demonstrated need in the professional community; and the source, nature, and magnitude of the individual‘s specific financial interest is disclosed; and…
Yes, yes, SCS, blah blah blah. Here is my interpretation of the first part: if you do choose a faculty member with a substantial financial interest in the content of your CME, you better really, really, REALLY need their participation. My questions: what is the definition of “substantial financial interest” and what qualifies as “central to the success”? Who is the arbiter of these criteria?

…(vi) taking steps to mitigate potential influence commensurate with the nature of the financial interest(s) at issue, such as prospective peer review…
Great! We finish up with one last point already covered by the SCS, specifically the conflict resolution process all CME providers have in place.
In summary, this doesn’t really seem too bad. For the most part it appears that CEJA is basically reinforcing the need for the policies the ACCME already has in place. It is obviously their preference that providers look to other sources of funding for CME, but they have not gone so far as to ask for the complete elimination of commercial support. If I had to guess (OK, I don’t HAVE to guess, but I’m going to anyway), I would say that CME providers may be asked to provide a little more documentation about faculty selection and conflict resolution processes, but I don’t anticipate any major shake-ups.

But what do I know?

Maybe the most interesting part of this exercise has been reading various blogs and opinions on the passing of CEJA report 1-A-11. It’s amazing to me how people can read the exact same report, yet come to such completely different conclusions on it’s meaning. To me, it re-emphasized the need to always consult multiple sources of information and always read blogs with a critical eye and a grain of salt. With such diametrically opposite views on this issue, SOMEBODY is going to be wrong…

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