ACCME Call for Comment — Inform the Learners

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Recently the ACCME issued a call for public comment on their proposed changes to the standards for commercial support.  Proposed Changes  June 2008 , Proposed Changes August 2008.

The changes include:

A)   Not allowing communications between the CME provider and supporter on topics of interest or selection criteria

B)   Meeting all the following criteria for a program:

a.    When educational needs are identified and verified by organizations that do not receive commercial support and are free of financial relationships with industry (e.g. US Government agencies), and  

b.    If the CME addresses a professional practice gap of a particular group of learners that is corroborated by bona fide performance measurements (e.g. National Quality Forum) of the learners’ own practice, and

c.    When the CME content is from a continuing education curriculum specified by a bona fide organization, or entity (e.g. AMA, AHRQ, ABMS, FSMB), and

d.     When the CME is verified as free of commercial bias.

(If section this confuses you, no worries, everyone I have spoken to has the same problem)

C)   Speakers and free lance writers are not involved in any way with giving promotional talks or preparing promotional literature.

The ACCME’s recent call for comment seems to be an overreaction to criticism from the Congress.  My understanding of the Senate Report and other communications is that Congress is interested in seeing what the ACCME is doing to enforce their existing rules, not necessarily create a whole bunch of new rules.

Several Medical Education Companies have informed their participants how these new rules may affect them; one Professional Post Graduate Services made them available on their website.

PPS Letter:

Dear Colleague,

 As a participant in one or more of our continuing medical education (CME) activities, you are well aware of the value of independent medical education. And we at Professional Postgraduate Services® (PPS) are proud of feedback we’ve received from you and your colleagues telling us that 95%-98% of you believe our activity content is fair-balanced and free of commercial bias. Today, we want to alert you to the fact that independent medical education is under attack.

A recent proposal by the Accreditation Council for Continuing Medical Education (ACCME) includes three scenarios:

A. The status quo, where commercial support remains an acceptable funding mechanism

B. The complete elimination of commercial support

C. A new “paradigm” that puts forth four criteria that must be met in order for commercial support to continue; This paradigm would remove medical education companies like PPS from any role in content development.

 In its Call for Comment, the ACCME said it will take input until September 12. We believe it is critical that learners such as yourself make your voices heard in support of continued commercial funding for independent medical education. To facilitate your response, we have prepared the basis of a letter; click here to access it. Feel free to copy or change it, as you deem appropriate, and submit your response to: https://accme.wufoo.com/forms/call-for-comment-2/

Respondents to the calls for comments who want to specify their profession, degree, organizational affiliation, or any other identifying information may do so by including a "by-line" in the body of their comments.

It is vitally important that the ACCME hears from you! Further, we appreciate you alerting your colleagues to this matter.

Thank you,

The Professional Postgraduate Services® Management Team

Marianne Koch, Mark Schaffer, Sylvia Razzo, Steve Rifkind, Lou Passador, Caroline Tredway

PS: Your professional and medical societies are also interested in this issue.  Please share your thoughts with them via email, fax, or letter.

Sample letter to ACCME:

To whom it may concern,

I am writing in response to the recently issued "Call for Comment" by the Accreditation Council for Continuing Medical Education (ACCME) proposing the elimination of commercial support for continuing medical education (CME) activities.

In the document, the ACCME includes three scenarios:

·         the status quo with commercial support of CME an acceptable funding mechanism;

·         the complete elimination of commercial support;

·         a new paradigm that puts forth four criteria that must be met in order for commercial support to continue to be allowed.

 

The consequences of altering the manner in which CME activities are presently funded would have a profound effect on learners like myself. Limiting providers’ ability to develop effective CME activities will mean that fewer options for learning will be available. Further, the major portion of available education would be only of a promotional nature from the pharmaceutical and device companies. Lastly, the decision could also limit the availability of activities to address the requirements of Maintenance of Certification and Maintenance of Licensure.

In the end, however, I believe this decision will have an even more profound impact on patient health outcomes. With limited CME activities to choose from, learners like myself will be hard-pressed to understand evidence-based treatment options in disease states where cutting-edge interventions involve off-label usages, or the science behind novel therapies that may soon fit into our treatment armamentarium.

In short, the decision to eliminate commercial support could have a great impact both on the quality and quantity of CME available to practicing healthcare professionals, and also on patients. The same can be said for the new paradigm scenarios under which commercial support would be allowed to continue.

While I recognize that the current system can be improved through minor adjustments, I encourage the ACCME to maintain the status quo, with commercial support of CME remaining an acceptable funding mechanism.

Yours truly,

More and more organizations are letting their faculty and participants know the potential impact of the ACCME’s proposed news actions, we encourage everyone to do the same….

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