This week the ACCME published the responses to their call for comment and they are almost universally suggesting that the ACCME go back to the drawing board. After reading through all the comments one would be hard pressed to find almost anyone in favor of the proposals put forth this summer by the ACCME.
Several themes ran throughout all the responses:
A) The current system is relatively new and we are seeing it work
B) Elimination of commercial support is a bad idea
C) Health care providers see the elimination of commercial support as one more payment they can’t afford
D) The proposal to eliminate commercial support will adversely effect rural and community physicians
E) The proposal will be especially harmful to medical specialty societies and community hospitals to provide quality education to their members.
The listing of the responses is very long on the ACCME website so we have arranged the organization responses by organization and the comments submitted on the internet:
Organization Responses:
Manufactures and their Organizations
Bio Technology Industry Organization (BIO)
Provider-Stakeholder Organizations
Council for Medical Specialty Societies (CMSS)
The Association for Hospital Continuing Medical Education (AHCME)
The Society for Academic Continuing Medical Education (SACME)
North American Association of Medical Education and Communication Companies (NAAMECC)
American College of Chest Physicians
American Society of Anesthesiology
American Society of Hematology
American Academy of Family Physicians (AAFP)
Potomac Center for Medical Education
Editorial in Journal of American College of Cardiology (JACC)
American Medical Writers Association
The Coalition for Healthcare Communication
Other Comments
Washington Legal Foundation (WLF)
In addition the ACCME released non originator identified comments sent in through the ACCME’s online system online system:
Responses on the topic, "The ACCME will ensure the current processes of attaining commercial support will not undermine the independence of continuing medical education." (2,070 KB)
· Responses on the topic, "The ACCME believes that due consideration be given to the elimination of commercial support of continuing medical education activities." (917 KB)
· Responses on the topic, "Persons paid to create, or present, promotional materials on behalf of commercial interests cannot control the content of accredited continuing medical eucation on that same content." (1,695 KB)
Some of my favorite responses are from real people:
On the topic of elimination of commercial support:
To Whom It May Concern: I do not believe it will be a benefit to anyone eliminate commercial support for continuing medical education. Who is proposing such a short sighted limitation on doctors anyway? Surely we physicians can use all the help we can get to keep us up-to-date with information that can benefit our patients. We are not millionaires contrary to what the general public, lawyers, and the business world seems to think. Government for instance clobbers the average family physician with all sorts of regulations, taxes, and now mandates for an electronic medical record. There are many that will not be able to afford to continue…. In short I want to say that it has been a blessing for the medical profession to have these contributions toward medical education and in my humble opinion if cutting off help is proposed it can only be coming from someone who doesn't know it’s like to be in the trenches and walk the walk. I'm all for the ensuring of quality content…. but it doesn't make sense to limit the aid with which to achieve improvements in such quality.
As a solo practicing MD struggling to negotiate arcane insurance company denials AND pay my student loans, I sometimes think about just quitting. I enjoy the online CME I get from —— and ——–, and I couldn't make it if I had to find an extra few thousand bucks a year to get my required CMEs. ——————
Gentlemen: I am writing in response to the recent "Call for Comment" by the Accreditation Council for
Continuing Medical Education (ACCME) proposing the alteration or elimination of commercial support for
continuing medical education (CME) activities. I do not favor making changes to a system which is providing opportunities for me to gain additional information with minimal direct cost to me. This is especially important to those of us who do not reside in major metro areas or near medical schools. As a board-certified medical sub-specialist, I am fully able to sift commercial (and academic) bias. My colleagues seem equally well suited to this task. The consequences of altering the manner in which CME activities are presently funded would have significant effects on learners like me, ultimately resulting in fewer options for learning. Unfortunately, this makes it look as if the major portion of available education would ultimately be of a promotional nature from the pharmaceutical and device companies. Physicians deserve to have a full range of options available to them to maintain currency. Even medical academia is biased, so making this sort of change merely shifts the bias. Additionally, the decision could also limit the availability of activities to address the requirements of Maintenance of Certification and Maintenance of Licensure. I believe this decision could have a significant impact on patient health outcomes in my practice. With more limited CME activities to choose from, especially in smaller communities such as mine, we will have substantially increased difficulty accessing information regarding evidence-based treatment options in disease states where newer interventions may involve off-label uses, or where the science behind novel therapies may soon fit into our patient treatment plans. The decision to eliminate or restrict commercial support could have a great impact both on the quality and quantity of CME available to practicing healthcare professionals, and also on patients, ESPECIALLY IN SMALLER COMMUNITIES where CME is probably more needed than anywhere else. The same can be said for the "new paradigm" under which commercial support would be allowed to continue. I encourage the ACCME to leave a good thing alone! Allow commercial support of CME to remain an acceptable funding mechanism. Allow the free market place of ideas to remain open. Respectfully submitted, —————————
Sirs: I respectfully disagree with the proposed changes to the ACCME policies for accreditation. As noted in the proposal, "some conflicts of interest are irreconcilable". The most concerning episodes of bias in both research and CME activities of late have been due to either blatant dishonesty (lack of candor in reporting data or in reporting potential conflicts of interest) or simple error. Neither of these causes will be corrected by the proposed policy. The solution to the issue is to continue to require complete transparency in the development and presentation of CME accredited programs. The current policy defines potential causes of conflict of interest and sources of bias, but this should be expanded to include the examples given in the policy explanation as well as all other sources of bias (eg funded research, vanity publications etc.). Allow physicians to sort out the reliability of the information based on the source rather than further limiting the sources. Bias, per se, does not mean that the information is incorrect.
As a clinician and educator I find it rather disturbing that the ACCME would consider that, elimination of
industry support for CME may improve the end product i.e. dissemination of unbiased medical education. If this misguided regulation of medical education comes to pass, we will then be left with pharmaceutical company sponsored programs to educate the vast majority of community based physicians. Over the years as in any industry I have an opportunity to work with many CME companies which receive support from the pharmaceutical industry. The majority of these providers have delivered valuable unbiased CME programs to many community clinicians whom have little opportunity to leave their small practices to attend weekday CME venues. I would propose that a more appropriate consideration would be for the ACCME to develop a working relationship rather than an adversarial relationship with both industry and CME providers. In the end the most important outcome should be to education our providers of care regardless of the source of support. As a physician responsible for accrediting CME content, I wish to comment on your “new paradigm.” 1)How can you imagine that “government agencies” (and academia as well, for that matter) are “free of financial relationships”?!!? Our industry has already given a green light to direct providers of medical care (hospitals and clinics) for similar fanciful ideas. Believe me, there is no philosopher-king out there who is above Congressional accusations, unless it is Congress itself. Shall we hand the entire industry over to the Senate Finance Committee? 2)Is the mechanism in place to transfer all needs assessments to a small group of “bona fide” performance measurers such as the National Quality Forum (Your article says “Form”) and assure that they are and remain unsullied? 3)Are the “bona fide” entities you list prepared to “specify,” in a timely fashion, the content of every CME curriculum presented to them? I thought this was the function of the ACCME. And how will their integrity be verified? Does this requirement subsume a dramatic reduction in the quantity of CME activities? 4)What exactly is a “continuing education curriculum”? Is it an MedEd company that has been accredited by the ACCME, or is the entire ACCME accreditation process to be scrapped and rebuilt under some other initials? Or perhaps it is every single activity that must be “verified as free of commercial bias” by yet another gaggle of bureaucracies with impressive initials. Certainly the entire industry is running scared from Senator Grassley, but should we commit suicide to avoid death by bureaucracy? As our representatives, the ACCME and associated initials have an obligation to negotiate as little change in our direction as will keep the “omnipotent moral busybodies” off our backs. What you need is an honest and open discussion (behind closed doors) with the commercial supporters. Go where the money is. How far back do they intend to pull to deflect Congressional scrutiny? How can we more exactly focus on their needs, which should be to educate when they have a better product and advertise when they have a “me, too” product? What is their stake in objective CME (like the Merck Manual)? How important (in dollars) is the goodwill they generate from unbiased educational activities? You cannot just imagine solutions on your own. Collaborate with the drug and device industry; do a needs assessment; ask your lawyers how to bamboozle Congress; budget out a solution in dollars and cents; buy a few politicians. Ending commercial support for CME is throwing the baby out with the bath water, and it is the death of the ACCME as well as many MedEd companies. (The opinions expressed here are solely those of the writer and do not necessarily represent the company for which he works.) Regards
As a practicing clinical physician, Director of Medical Education at my local community hospital and a
member of several speaker bureaus, I have a unique perspective on Commercial Support issues. I believe Commercial Support does have its place in CME activities. The proposals would have unintended consequences and, beginning with # 1, do not seem like a good idea to me. What specifically am I concerned about? 1) Use of government agencies to regulate CME on a micromanagment or approval level is a terrible idea. Think about it, do you really want a third party to regulate what consistutes CME? The same way a thrid party already regulates payment and delivery of medical services? This would add more bureaucracy and distance clinicians from information needed to care for their patients. We see how efficient the government already is at solving healthcare issues and we invite them to do more??? 2) The money for CME has to come from somewhere. Given the efficiency of corruption developing in our government, I would think that somewhere in the government chain of regulation may be an inroad for undue influence on CME, ie., someone in the agency overseeing CME may be paid by a lobbying group for pharma or by specific pharma companies to allow exceptions to support or to allow support to occur in hidden ways. The FDA has already been under investigation for undue influences by pharma in their rate of drug approvals before the Cox-2 debacle. 3) Imagine how the government will have to approve your CME program… ie., I cannot think of any good outcome for this to allow a local community hospital to substitute a last minute CME program change when there is a cancellation of speakers. I know how long it takes our state medicaid to process a Prior Authorization for a medication — do we want the same headache for CME approval when we have to make changes in plans??? No, this never occurs in a CME Grand Rounds program, right??? 4) Letting the government agency decide CME basically abdicates our responsibility to our patients. If we do this, I fear the consequences will be similar to letting a third party decide what tests are necessary for patient care and what drugs may be given… I have many other thoughts on this matter, but the above will suffice for now, thanks Please note that opinions expressed are NOT on behalf of my affiliated community hospital (an accredited CME provider), only for myself.
As a semi retired physician the cost of CME's can be prohibitive but I still need them to stay licensed. I have been using ——– and found the articles to be fair and balanced, unlike Fox News. They do their own screening and we submit comments as to the objectivity of the learning. I do not want to lose this support and as other independent teaching companies will take over and change exorbitant fees for their CMES as they have in the past. I used to spend upwards of $1000.00 per year to get these credits. If one is not near a teaching institution than they have to pay big time for credits. Thank you.
August 22, 2008 Dear ACCME: In this time of declining funding for CME's, I find it very strange that there is movement to eliminate a potential source. The government certainly is not going to increase its funding. There has been and there will always be commercial bias in CME activities. I think I speak for my colleagues that we are not children. We all have independent thoughts regardless of any commercial bias in any CME's, real or perceived. Besides we need to see and work with pharmaceuticals as friends and colleagues, not as enemies kept at a far distance. After all both of us cannot survive without the other. I most strongly oppose any proposal to eliminate commercial support for CME's.
the consensus was that removing commercial support from the CME enterprise would do
little to promote the health of the country.
The list goes on, and I have to get back to my real job. I would encourage you to read the responses….
If you would like to post your attributed comments to the ACCME, please send them via email to tsullivan@rockpointe.com