ACCME Call for Comment 2011: Logos or No Logos That is the Question

Logos                                        No Logos (well one in the corner)

Logos, Logos we see them everywhere, especially when we open the refrigerator, or attend a sporting event.  Walk around looking for logos, they are everywhere.  Occasionally we may see one in a syllabus or invitation for a continuing medical education (CME) activity.  I personally cannot remember the last time I saw corporate logos in lecture halls or on presenter slides.  As far as I know CME has for a while, been pretty much a logo free zone. 

So why this month is the Accreditation Council for Continuing Medical Education (ACCME) Board of Directors announcing a call for comment about a proposed change in policy regarding the acknowledgement of commercial support? 

The proposed policy states that providers can communicate the names of commercial supporters in text format only, and cannot include corporate logos or any mention or description of other units within the commercial interest corporate structure. As Murray Kopelow, MD, ACCME Chief Executive, explained in his commentary, this means that the disclosure of commercial support could not include a company’s logo, could not include a slogan, could not include a tagline, and could not include a reference to any of a company’s corporate units, such as its medical education division. 

The ACCME has issued this call for comment in accordance with its 2009 Rule Making Policy, which commits the ACCME to providing notice of change in policies as well as to provide an opportunity for the CME community to comment on the proposal—before the ACCME adopts rules or policies which affect the way CME providers do their business.  

Comments are due by June 6, 2011 and can be submitted here. 

The current ACCME policy related to Standard 6 from 2004 says that providers must disclose to learners the sources of commercial support.  However, Standard 6 presently allows providers to use corporate logos and slogans in their communications regarding commercial support, as long as the slogans and logos do not promote specific products.  ACCME policy does not prohibit providers from using corporate logos in their communications regarding commercial support.   

Dr. Kopelow noted in his commentary that the ACCME Standards for Commercial Support and related policies ensure that accredited CME activities are independent of the influence from commercial interests and serve the public interest. The Standards for Commercial Support create a firewall between accredited continuing medical education and industry promotion.  He asserted that the new proposed policy “will reinforce the firewall between accredited continuing medical education and industry.” 

Discussion 

In this call for comment, as in all previous calls for comments from the ACCME, there is no reference as to why ACCME wants to make the change.  They simply state that the proposal is in “response to provider feedback and to strengthen the firewall between CME and promotion.”  But where is the evidence that the “firewall” is ineffective or weak?  Did ACCME conduct any surveys or studies asking participants at accredited CME events the impact corporate logos had on their education?  We are unaware of any such studies. 

Where is the data that shows that corporate logos weaken the firewall?  Moreover, what kinds of stakeholders provided feedback?  How many stakeholders?   None of this information was provided by ACCME.  Just vague references.  Accordingly, CME stakeholders are left asking, what circumstances surround this proposed change? 

Has the ACCME considered that references to units within a commercials interest corporate structure may in fact lead to less transparency as in larger corporations knowing where the money is actually coming from may be important to the learner?   

For example the XYZ Parent Company may have several pharmaceutical and device divisions which commercially operate as separate entities.  If those entities are not listed there may be no understanding from the learner as to who actually supported the activity. 

Personally, I don’t particularly like logos and would love to live in a world free of logos (maybe not, how would one know the soda they were buying was really Coke?). But one is torn, if they support the free speech right to see logos.  I also find logos quite useful differentiating one company from the next.  

My kids hate brussels sprouts and they would support a movement to ban serving brussels spout at our family table perhaps even the entire world.  But it would be wrong to ban brussels sprout simply because we don’t like them.  Some others like them, I like them.  We live in a “free” society and it is important that we don’t go overboard to create bans just to protect the occasional doctor who may not like a particular logo in a brochure. What about the rest of us who may benefit from the full disclosure. Logos are quite useful differentiating one company from the next. 

Is there any research on the “harm caused by logos”? When I typed in google “harm caused by logos” nothing came up or at least nothing that seamed relevant.  Perhaps there is a movement to “free the world from logos” that I am not aware exists.  If not perhaps in my retirement  in 20 years or so, I may start one “Free Logos”…. 

In the absence of any evidence that anyone has been harmed by the use of a corporate logo, we find it hard to imagine why ACCME at this time would want to make this change.  Such a proposal is also concerning because at the same time ACCME is proposing opioid REMS programs using CME, which may be better disclosed if the logo of companies were used.  It is odd that on one hand, ACCME is encouraging company participation in CME through REMS, and at the same time discouraging corporate acknowledgement and good will through the use of logos.  What net benefit does the ACCME hope to accomplish from eliminating the use of logos? 

Comments are due by June 6, 2011 and can be submitted here.