Conversations With The ACCME: Needs Assessments, Collaboration And Independence

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.

Conversations With The ACCME: Incentivizing Surveys

You’re in for a special treat today! Not only do I have another conversation with the ACCME for you, but this one come with a special bonus conversation with the AMA! Two for the price of one! Woo hoo! (I’ll stop using “!’s” now…)

A common method for assessing the effect of a CME activity on a participant’s practice is to survey the participant at an interim time after the completion of the activity (3-months, 6-months, etc.) These follow-up surveys are nice in theory, but the execution can often times be a struggle. Pardon the cliche, but getting participants to complete a follow-up survey can be like “pulling teeth.”

As a possible method for boosting participation in my follow-up surveys, I explored the possibility of offering incentives for survey participation. I started by talking with friends in the CME world, but got a mixed bag of opinions as to whether it was OK to do incentives. Nor could I find anything in the ACCME’s or AMA’s literature that directly referenced the issue of incentives for surveys. So I sent e-mails to both of them. Below is my question and their answers.

I am investigating the possibility of offering incentives to participants for completing follow-up surveys. The time spent on completing the follow-up surveys is not factored into the overall credits issued for the activity. Would the ACCME/AMA take issue with any of the following potential incentive offerings?

1. $75 gift certificate to an online medical bookstore
2. $25 gift certificate to an online medical bookstore
3. $5 Starbucks coupon
4. Complete the survey and have your name entered into a raffle to win a free iPad

ACCME
ACCME has no rules that prohibit your examples, since this occurs after the CME activity, is not awarded CME, and is beyond/not part of the CME content.

AMA
We have received similar questions regarding whether it is acceptable to offer incentives to physicians for completing surveys.  AMA Ethics policy 8.061 on Gifts to Physicians from Industry does not offer any specific guidance on the completion of surveys.  Providing a physician with a modest (which I believe your offerings are) incentive to complete a survey is a fairly common practice and ok as far as the AMA’s policy goes. 

Now, for this to be complete I really should have an opinion from PhRMA. I ended up not doing this because I decided that if I would go the route of incentives for surveys, I would do it sans commercial support.  As it is, neither the ACCME nor AMA seems to have an issue with offering a modest incentive for completing a follow-up survey that is not part of the CME content.

Conversations With The ACCME: Accreditation Language

For an explanation as to why I’m doing these Conversations With The ACCME, go here.

Contrary to popular opinion, being a CME Director is not all glitz and glamour (It’s true!). Sometimes we have to roll up our sleeves and dig in deep to the mucky details. This particular question I posed to the ACCME is about the accreditation language used on a brochure or in the front matter of a syllabus/program book when there are multiple partners involved. I literally got into an argument with someone about this one. It was vicious; we almost attacked each other with our “GET THE FACTS!” pins.

Here’s the question:

I have a program with 6 different partners involved. Their roles are as follows:

Partner 1: CME Provider
Partner 2: Med Ed company handling logistics (also CME accredited)
Partner 3: ANCC Provider
Partner 4: ACPE Provider
Partner 5: Content expertise (also CME accredited)
Partner 6: Content expertise (NOT CME accredited)

What accreditation statement should I use and how should the partners be listed?

The ACCME’s answer:

Use the jointly sponsored accreditation statement and list all your partners.

So the accreditation statement would be written thusly:

“This activity has been planned and implemented in accordance with the Essential Areas and policies of the Accreditation Council for Continuing Medical Education through the joint sponsorship of Partner 1, Partner 2, Partner 3, Partner 4, Partner 5, and Partner 6. The Partner 1 is accredited by the ACCME to provide continuing medical education for physicians.”

And not that it matters, since I would never be so petty and vain as to bring it up, but…I was right.

Conversations With The ACCME: Defining Commercial Interest

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 postmaster@accme.org 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?

No.

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?

No.

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?

Nope.

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.