What follows is an exact replication of my questions to the ACCME about needs assessments, collaboration, and independence, and their response. Please keep in mind that this information is applicable only in the context of specific facts and circumstances provided to the ACCME.
If a commercial supporter includes in their RFP “data that [they’ve] been able to gather through a variety of methodologies and mechanisms that look at various potential learner needs and practice gaps,” would an ACCME accredited organization be considered out of compliance with SCS 1.1a if they used the given data as a part of their needs assessment for a CME-certified activity?
The ACCME would not find a provider in noncompliance for utilizing publicly available gap data. However, the ACCME would expect that the provider independently determines what educational needs underlie those gaps for their own learners.
If a commercial supporter requested an ACCME accredited organization work with another specific organization (e.g. the provider responds to an RFP that requests they work with their QI department to develop CME-QI projects) would they be considered out of compliance with SCS 1.1d?
The ACCME would not find a provider in noncompliance if it responded to an RFP for commercial support that requested that interested providers work with their QI departments to develop CME-QI projects. The commercial supporter would be funding activities that are CME-QI projects of the institution.