I read with interest this article in the Boston Globe about the 3 Harvard physicians reprimanded for failing to disclose conflicts of interest to the university. It made me think about my responsibilities as a CME Director, charged with all issues related to accreditation and compliance of CME . It made me think about how much “effort” is expected of me in maintaining compliance. It made me think of a saying my mentor from back when I was first starting in CME was fond of repeating: “We are not the CME police.”
Or are we?
Is it enough effort for me to obtain Disclosure of Relevant Commercial Relationships forms from my faculty and accept them at face value? Or should I dig a little deeper? How much of the onus for accurate disclosure information is on the presenter and how much is on the CME provider? Is it 100% on the presenter or is there a small percentage on the provider? What would the OIG, DOJ, or our dear friend Senator Grassley say if one of your speakers fell into their crosshairs?
Another example: how far are we expected to go when tracking participant attendance at a live meeting? Again, who bears the brunt of responsibility for accurately reporting the amount of time a participant spent in a meeting? Is it OK to give out certificates for the full amount of credit at the end of a conference and expect the guy who took a 3 hour lunch at the Cheesecake Factory to self-adjust his credits accordingly? Or is it better to do as some of my CME colleagues do and record “time-in” and “time-out” for each participant, a daunting task for sure?
Given the amount of scrutiny the CME community is under, should there be a greater emphasis on being the CME police?
I’ve asked a lot of questions and I don’t have a lot of answers. I have opinions, but I honestly don’t know if they’re “right”. No surprise, I’m sure, that I tend to be an advocate of the “We are not the CME police” philosophy. I’ve been known to say it a time or two around the office. Sure, there are times when I need to “crack the whip” so to speak and there is a certain amount of “policing” that’s required, especially when it comes to the Standards for Commercial Support, but there are limits.
My general philosophy is this: I will follow all compliance criteria to the best of my abilities and work to produce the best possible educational activity I can. In return, I expect my faculty and participants to provide me with complete and accurate information and to teach and learn as professionals. Naive? Maybe.
Are we the CME police? To some extent, I guess we are. I really really want to give an emphatic “no” here, because I want CME to be about education, not about about compliance, rules, and regulations. The reality is, those areas still make up a large portion of what we do. We are the CME police because it’s required of us. How much you police is up to you.