ACCME Adopts Changes to Simplify the Accreditation Requirements

The Accreditation Council for Continuing Medical Education (ACCME) announced that its Board of Directors has adopted changes to simplify the accreditation requirements and process. This includes changes to the accreditation criteria for ACCME accredited providers of continuing medical education.

The ACCME had proposed a broad spectrum of changes including changes to the use of logos in disclosing commercial support. At this time has delayed for further discussion changes concerning the use of corporate logos and changes to the criteria for accreditation with commendation.

The purpose of the changes is to streamline the accreditation system while maintaining high standards and continuing to support continuing medical education as a strategic asset to healthcare improvement initiatives. These changes come after the ACCME’s formal call for public comment on the accreditation requirements and process. The results of these comments are clear: a significant majority of the respondents agreed with the ACCME’s proposals to simplify the Accreditation Criteria, policies, and process.

The changes include:

• Simplifying and removing some of the Accreditation Criteria and policy requirements
• Changing terminology from “joint sponsorship” to “joint providership”

• Offering providers an abstract as an ACCME-approved tool to use when verifying performance-in-practice

• Simplifying the process for organizations applying for initial accreditation

These changes are designed to remove redundancies while maintaining the continuous improvement model and the high standards that are essential for designing and implementing independent, effective, and relevant CME. The number of criteria required for accreditation is reduced from 15 to 12, one policy is eliminated, and five policies are modified. The changes will simplify the process for accredited providers and offer greater flexibility, while retaining the Plan-Do-Study-Act cycle which is integral to the ACCME’s expectations.

These changes apply to all CME providers within the ACCME accreditation system, including providers directly accredited by the ACCME and those accredited by ACCME Recognized Accreditors (state or territory medical societies that are recognized by the ACCME as accreditors of intrastate CME providers).

Implementation of Changes

According to the ACCME, the changes are effective immediately:

• Elimination of requirements: Accredited providers will no longer be evaluated for compliance with the requirements that have been eliminated.
• Change in terminology: ACCME does not expect accredited providers to change or reprint any materials that currently exist. ACCME expects accredited providers to use the term “joint providership” for new materials published after January 1, 2015. Please note that this change in terminology applies to accreditation statements for jointly provided activities as well as other materials.

• Accreditation process: Providers will have the option of using an abstract to verify performance-in-practice or to continue using labels. ACCME is in the process of producing the abstract.

• Initial applicants: Organizations applying for Provisional Accreditation will no longer be required to have an on-site survey. Surveys are still required; conference calls are the standard interview format the ACCME currently uses. Initial applicants and accreditors continue to have the option of using other survey formats including televideo and face-to-face, if circumstances warrant it.

Accredited Providers: What This Means for You

Regardless of where you are in the accreditation process, you will no longer be evaluated for compliance with any requirements that have been eliminated:

• If you are in the March 2014 decision cohort, you were not reviewed for compliance with the requirements that have been eliminated and your decisions will not reflect those requirements. For progress reports that had a noncompliance finding in one of the eliminated requirements, ACCME is providing feedback about your effectiveness in meeting those requirements, in support of your continuous improvement and in recognition of the work you did in the progress report process.
• If you have already submitted materials for reaccreditation, you do not need to resubmit or change those materials. The ACCME will ensure that you will not be reviewed for any requirements that have been eliminated.

• If you are preparing for reaccreditation, do not change any of the materials you have already prepared or are in the process of preparing. The ACCME will ensure that you will not be reviewed for any requirements that have been eliminated.

• If you are in a future accreditation cohort, you will not need to submit materials related to compliance for the requirements that have been eliminated.

For more information, please see this Ask ACCME Q&A.

Webinar

The ACCME will hold a free webinar on March 11, from 1-2:30 PM CST, to discuss the changes and answer questions. This webinar is open to all stakeholders; however enrollment is limited. For more information about the webinar, including connection instructions, visit the Event Page on the ACCME website. The webinar will be recorded and published on the website.

Changes to ACCME Requirements and Process

The ACCME has updated its Accreditation Requirements and Descriptions document to reflect these changes and is in the process of updating the ACCME website and other accreditation materials to incorporate these changes.

Accreditation Criteria

The purpose of the changes to the Accreditation Criteria is to remove redundancies and streamline the Criteria while maintaining the continuous improvement model and the high standards that are essential for designing and implementing independent, effective, and relevant CME. These changes reduce the number of criteria required for accreditation from 15 to 12. They will simplify the process for accredited providers, while retaining the Plan-Do-Study-Act cycle, which is integral to the ACCME’s expectations. For the purposes of visually seeing the changes the deleted items are struck out in this article.

1.       Edit Criterion 1: Mission Statement

2.       Eliminate Criterion 4: The provider generates activities/educational interventions around content that matches the learners’ current or potential scope of professional activities.

3.       Eliminate Criterion 14:  The provider demonstrates that identified program changes or improvements, that are required to improve on the provider’s ability to meet the CME mission, are underway or completed.

4.      Eliminate Criterion 15 The provider demonstrates that the impacts of program improvements, that are required to improve on the provider’s ability to meet the CME mission, are measured.

Policies

These changes remove requirements that predate the current accreditation criteria and are no longer necessary due to the evolution of CME and technology.

5.       Eliminate Organizational Mission and Framework: The accredited provider must have an organizational framework for the CME unit that provides the necessary resources to support its mission including support by the parent organization, if a parent organization exists.

6.       Eliminate some special requirements for enduring materials

Because there is no direct interaction between the provider and/or faculty and the learner, the provider must communicate the following information to participants so that they are aware of this in-formation prior to starting the educational activity

1. Principal faculty and their credentials;

2. Medium or combination of media used;

3. Method of physician participation in the learning process;

4. Estimated time to complete the educational activity (same as number of designated credit hours);

5. Dates of original release and most recent review or update; and

6. Termination date (date after which enduring material is no longer certified for credit).

Providers that produce enduring materials must review each enduring material at least once every three years or more frequently if indicated by new scientific developments. So, while providers can review and re-release an enduring material every three years (or more frequently), the enduring material cannot be offered as an accredited activity for more than three years without some review on the part of the provider to ensure that the content is still up-to-date and accurate. That review date must be included on the enduring material, along with the original release date and a termination date.

Sometimes providers will create an enduring material from a live CME activity. When this occurs, ACCME considers the provider to have created two separate activities – one live activity and one enduring material activity. Both activities must comply with all ACCME requirements, and the enduring material activity must comply additionally with all ACCME policies that relate specifically to enduring materials.

7.       Eliminate some special requirements for Internet CME (retaining 3 that support the Standards for Commercial Support)

There are special requirements for Internet CME because of the nature of the activities:

Activity Location: ACCME-accredited providers may not place their CME activities on a Web site owned or controlled by a commercial interest.

Links to Product Web sites: With clear notification that the learner is leaving the educational Web site, links from the Web site of an ACCME accredited provider to pharmaceutical and device manufacturers’ product Web sites are permitted before or after the educational content of a CME activity, but shall not be embedded in the educational content of a CME activity.

Transmission of information: For CME activities in which the learner participates electronically (e.g., via Internet, CD-ROM, satellite broadcasts), all required ACCME information must be communicated to the learner prior to the learner beginning the CME activity.

Advertising: Advertising of any type is prohibited within the educational content of CME activities on the Internet including, but not limited to, banner ads, subliminal ads, and pop-up window ads. For computer based CME activities, advertisements and promotional materials may not be visible on the screen at the same time as the CME content and not interleafed between computer windows or screens of the CME content.

Hardware/Software Requirements: The accredited provider must indicate, at the start of each Inter-net CME activity, the hardware and software required for the learner to participate.

Provider Contact Information: The accredited provider must have a mechanism in place for the learner to be able to contact the provider if there are questions about the Internet CME activity.

Policy on Privacy and Confidentiality: The accredited provider must have, adhere to, and inform the learner about its policy on privacy and confidentiality that relates to the CME activities it provides on the Internet.

Copyright: The accredited provider must be able to document that it owns the copyright for, or has received permissions for use of, or is otherwise permitted to use copyrighted materials within a CME activity on the Internet.

8.       Eliminate some special requirements for journal-based CME

A journal-based CME activity includes the reading of an article (or adapted formats for special needs), a provider stipulated/learner directed phase (that may include reflection, discussion, or debate about the material contained in the article(s), and a requirement for the completion by the learner of a pre-determined set of questions or tasks relating to the content of the material as part of the learning process.

The ACCME considers information required to be communicated before an activity (e.g., disclosure information, disclosure of commercial support, objectives), CME content (e.g., articles, lectures, handouts, and slide copies), content-specific post-tests, and education evaluation all to be elements of a journal-based CME activity.

The educational content of journal CME must be within the ACCME’s Definition of CME. ACCME Accreditation Requirements

Journal CME activities must comply with all ACCME accreditation requirements. Because of the nature of the activity, there are two additional requirements that journal CME must meet:

The ACCME does not consider a journal-based CME activity to have been completed until the learner documents participation in that activity to the provider.

None of the elements of journal-based CME can contain any advertising or product group messages of commercial interests. Disclosure information cannot contain trade names. The learner must not encounter advertising within the pages of the article or within the pages of the related questions or evaluation materials.

9.       Eliminate some special requirements for Regularly Scheduled Series (RSS)

The ACCME defines a regularly scheduled series (RSS) as a course that is planned as a series with multiple, ongoing sessions, e.g., offered weekly, monthly, or quarterly; and is primarily planned by and presented to the accredited organization’s professional staff. Examples include grand rounds, tumor boards, and morbidity and mortality conferences. ACCME-accredited providers that offer regularly scheduled series must describe and verify that they have a system in place monitor these activities’ compliance with ACCME accreditation requirements. The monitoring system must:

1. Be based on real performance data and information derived from the RSS’s that describes compliance (in support of Accreditation Criteria 2-11), and

2. Result in improvements when called for by this compliance data (in support of ACCME Criteria 12-15), and

3. Ensure that appropriate ACCME Letters of Agreement are in place whenever funds are contributed in support of CME (in support of the ACCME Standards for Commercial Support: Standards to Ensure Independence in CME Activities).

Also, the provider is required to make available and accessible to the learners a system through which data and information on a learner’s participation can be recorded and retrieved. The critical data and information elements include: learner identifier, name/topic of activity, date of activity, hours of credit designated or actually claimed. The ACCME limits the provider’s responsibility in this regard to “access, availability and retrieval.” Learners are free to choose not to use this available and accessible system.

10.   Edit “joint sponsorship” to “joint providership” throughout the requirements, including in the accreditation statement, as shown in the examples below. The purpose of the change is to support consistency within our own terminology and with the terminology used by other accreditors.

Accreditation Statement for Jointly Provided Activities

“This activity has been planned and implemented in accordance with the accreditation requirements and policies of the Accreditation Council for Continuing Medical Education through the joint providership of (name of accredited provider) and (name of nonaccredited provider). The (name of accredited provider) is accredited by the ACCME to provide continuing medical education for physicians.”

Joint Providership Policy

“The ACCME defines joint providership as the providership of a CME activity by one accredited and one nonaccredited organization Please note: the ACCME does not intend to imply that a joint providership relationship is an actual legal partnership. Therefore, the ACCME does not include the words partnership or partners in its definition of joint providership. One accredited provider must take responsibility for a CME activity when it is presented in cooperation with other accredited providers or with a nonaccredited organization and must use the appropriate accreditation statement. ”

Accreditation Process

These changes are designed to simplify the process and increase flexibility.

11.   Add a Performance-In-Practice Structured Abstract as a tool for documentation review.

12.   Eliminate the requirement for on-site interviews for initial applicants.

Public Comments

On December 17, 2013, the ACCME issued a formal call for public comment about its proposal to simplify the accreditation requirements and process, in accordance with its Rule-Making Policy. The comment period ended January 31, 2014. Overall, the responses to the formal call for comment were consistent with the responses to the spring 2013 survey. Most of the respondents agreed with the ACCME’s proposals to simplify the Accreditation Criteria, policies, and process.

Formal Call for Comment Data

Respondents agreed with the changes to the Accreditation Criteria by an overwhelming margin of 214-11. This set of changes includes simplifying Criterion 1 and removing Criteria 4, 14, and 15.

The respondents who agreed with the changes to the Accreditation Criteria said that the changes reduce redundancy, enhance clarity, increase flexibility, and will allow providers to focus more on continuous improvement. The respondents who disagreed were concerned that providers might need more direction and offered suggestions on how expectations for fulfilling the mission should be even more explicitly emphasized.

Respondents were mixed on the proposed Changes to Standards for Commercial Support, 142-85, but those organizations who commented the numbers were significantly different 29 supporting the change and 77 against. This set of changes is about changing the Standards for Commercial Support so as to prevent the use of commercial interest logos in the disclosure of commercial support.

Those in support said the changes would minimize any possibility of conflict of interest, eliminate any ambiguity, decrease participants’ perception of real or perceived bias, and strengthen the perception of the value of the Standards for Commercial Support. Those opposed to the changes said that the current Standards were sufficient and expressed concerns that prohibiting commercial interest logos would decrease transparency and disclosure, and make it more difficult to distinguish between commercially supported CME and CME that is not commercially supported.

Respondents agreed by a significant margin, 183-24, in favor of changes that remove some of the policy requirements for CME activity types, introduces the term “joint providership” to replace “joint sponsorship,” and removes an organizational structure policy that pre-dates the current requirements.

The respondents who agreed said that the policy changes would simplify the process and accurately reflect the current CME environment and the evolution of technology. They also suggested that the change in terminology should alleviate the misunderstanding created by the use of the word sponsorship and create a more consistent nomenclature. The respondents who disagreed said that the policy requirements were still important for promoting good practices and providing a framework for compliance.

Finally, by a large margin, 185-17, respondents supported two changes including the elimination of on-site survey requirements for organizations seeking initial accreditation, and introducing an abstract for accredited providers to use when verifying performance-in-practice.

The respondents who agreed said the change to the initial applicants’ process would provide greater flexibility and reduce cost and burden without degrading the process. Those who disagreed said that the requirement for on-site surveys provided value that other survey formats could not replace. Respondents said the abstract would greatly simplify the process; some who agreed and who disagreed provided important suggestions for improvements.

Several organization letters were included in the comments.

Council of Medical Specialty Societies (CMSS) letter to ACCME

Norman Kahn, MD, Executive Vice President & CEO of CMSS addressing corporate logos:

“The issue of the use of corporate logos is a complex one. Corporate logos are clearly associated with the company providing the support. That’s both bad and good news. If the ACCME’s intent is to decrease the appearance of a relationship between the commercial supporter and the CME activity, then prohibiting the use of corporate logos may make sense. If the priority, however, is clearly communicating to learners that the event has received commercial support, then prohibiting the use of corporate logos may be counterproductive. Identifying corporate supporters in regular type font may very well get lost in the administrivia associated with announcements of CME activities, and thus be functionally invisible to learners. Learners look for the corporate logos to see if there is commercial support.

CMSS values open and transparent disclosure. Given the binary options between corporate logos or not, we recommend that open and transparent disclosure to learners of the corporate support is best achieved by including corporate logos which will be immediately recognizable by learners. At the same time, we agree with prohibiting corporate slogans, product group message, tag lines, trade name, areas of therapeutic focus, or any other message that appears promotional on the part of the company.

Finally, there is the issue of timing. ACCME has been successful in obtaining national recognition for the Standards for Commercial Support, particularly by CMS through the new Open Payments program, the current iteration of the Physician Payments Sunshine Act. As the Open Payments program is in its first year, now is not the time to make any changes in this critical set of standards that have been adopted as is by CMS. It is not time to threaten the whole by tinkering with a part. It’s just too risky right now.

We strongly recommend not changing the CME community’s self-regulatory standards right now, which could put the standards and the CME community at risk in the current political environment.”

Society for Academic Continuing Medical Education (SACME) letter to ACCME

Deborah A. Samuel, MBA, FACEHP, President, Society for Academic CME writing in support of simplifying the accreditation requirements and process:

“SACME wholeheartedly endorses the idea of simplifying the accreditation requirements and process. We believe simplification will benefit everyone and will facilitate accredited CME offices’ efforts to apply their resources to enhance the performance of physicians and other healthcare providers, while still ensuring the scientific integrity of CME activities.

We are pleased to inform you that the responses reported from our member survey, as well as those developed in the Board’s discussion, reflected overwhelming approval of every item submitted for comment. The responses reached or exceeded 90% on items 1, 2, 3, 6, 7, 8, and 12. The positive response on the rest of the items exceed 80% with the sole exception of item 11 (eliminating the requirement to have on-site initial accreditation interviews), which received approval by 75%.”

Regarding corporate logos:

“There was a significant minority opinion expressed by some of our members regarding the use of Corporate Logos that we believe is worthy of your consideration. Their position was as follows:

‘The ACCME position should ‘reflect the principles outlined in the CME Coalition’s Responsible Logo Use Guidelines, rather than eliminate ACCME-defined commercial interest logos as outlined in the proposed changes.’ As another member stated, ‘When commercial support is acknowledged to participants, greater transparency can be shown by showing the corporate logos, which are recognizable, with size limitations and restraint.’ ”

Analysis

The ACCME has taken a strong leadership role in helping to streamline the accreditation system and adopting to criteria that is important. It is also encouraging that they are going through a deliberative process before making any additional changes.