A little while back, I wrote up a theoretical social media strategy for the ACCME (you can read it here). I did so in part because I feel it is important that everyone in the CME community have access to the same information provided by the ACCME, and I believe social media is an excellent resource form making this happen. My main concern is that the current process of Q&A with the ACCME is decidedly “un-social” (non-social? de-social? anti-social?): you e-mail them a question, they e-mail you an answer. Or maybe it’s a phone call. Either way, valuable nuggets of information, interpretation, and/or clarification are often passed on that would prove to be valuable to many more than just the individual asking the question. It would be great if there was a way for everyone to share what they learn from the ACCME during this Q&A process.
All of this is a long winded way of me saying…I had a conversation with the ACCME. I learned something that others might find valuable. I have a blog. I’m going to share my info here.
I was having a conversation with a few of my CME colleagues and the discussion turned to the ACCME’s definition of a commercial interest (CI). Someone would throw out a hypothetical scenario and then ask, “OK, if you did this, would you be considered a CI?” (Yes, this is considered “fun” in the CME world. I’m going to go cry in my pillow now.) After doing this for a while, I started to realize that maybe I wasn’t as sure about the definition of a CI as I thought I was. So, I put out the ACCME bat-signal and fired off an e-mail to the ACCME’s trusty email@example.com for a little clarification. Two more e-mails and a phone call later and I think I have a handle on it.
There were two specific points I was looking for some sort of confirmation or clarification on. They are very broad in focus, but for me, took an area that was full of shades of gray and made it much more black and white. Question 1 in particular is something I was pretty sure I knew the answer to, but really wanted to have someone tell me “Yes, that is absolutely correct.”
Below are my questions in bold and in italics is the ACCME’s response. Please keep in mind that I have paraphrased the ACCME’s response for the sake of brevity, but believe I have remained faithful to the totality of their answer.
Is there any situation in which an accredited provider can receive financial renumeration from a CI other than commercial support?
Seriously, that’s all you need to know. An accredited provider can only receive money from a CI via the LOA/commercial support route, even for non-certified, non-accredited, non-CME activities. If they do, they could be considered a CI. Maybe 99% of you already new this, but I’m not positive that I did. Certainly I understood it for certified CME activities, but since I’ve never really been in a situation where I needed to consider it for a non-CME activity, I never gave it much thought. I did a little digging on the ACCME’s website and found it was laid out pretty clearly (see #4: “…5) receives any funds from a commercial interest only as commercial support.“)
Can an accredited provider every truly collaborate with a CI on the planning and content of an educational activity, even one that is non-CME?
See? I told you they made it pretty black and white. Collaborate on the content of any type of educational activity with a CI and you could be considered a CI, as well. Specifically, I was told that you should approach the planning process for a non-CME activity the same was as you would with a CME activity…and that means no input from CI’s. Similar to the first question, I’ve never been in a position where I had to give this much thought with regards to non-CME. When I first considered the question, my first instinct was to think that there must be some situation in which a provider and a CI could collaborate. Maybe not with the marketing department, but possibly with the medical affairs department?
Hopefully this little exercise was informative for some of you. Quite possibly, I only succeeded in showing just how dumb I really am. If anyone else has anything they learned from a conversation with the ACCME that they would like to share, I’d be happy to post it here. Just send me an e-mail at theCMEguy@gmail.com or tweet me at @theCMEguy.