ACCME Call for Comment (Spring 09)

As summer is to baseball, so is Summer/Spring to the Accreditation Council for Continuing Medical Education (ACCME).

According to the ACCME:

·         The ACCME will periodically be requesting public feedback on new accreditation policy that is under consideration by the ACCME;  

·         Organizations or individuals interested in providing written feedback may do so only during the open comment period, and only using the electronic form provided; this will be the sole route for sharing comments with the ACCME – (I am certain that will go over well with the larger member organizations of ACCME – NOT!);

·         Normally, the comment period will be for 30 days (to limit the number of comments);

·         The ACCME will be limiting comments to 500 words, and will not consider anonymous submissions (to limit the time it takes to read the comments); and

·         The ACCME considers the comments it receives, and the names of those authoring the comments, to be public information that may be published on the ACCME's website (that is fine, it eliminates hit and run comments).

This time, they have issued a call to comment on four issues:

ACCME Rule Making.

The ACCME is proposing a rule making process that includes:

·         Comment Procedures;

·         Application;

·         Publishing for Comment;

·         Timing (30+days), though they can shorten or eliminate public comments; and

·         Be submitted to board with recommendation

It makes sense for the ACCME to have a rule making policy in place.  Though 30 days is a relatively short time frame and not sure that any issues that the ACCME will cover will be that time sensitive.

A special ACCME-defined designation of Commercial Support-Free ^TM Accredited Continuing Medical Education.

The ACCME will consider creating a new designation and review process for providers who wish to identify their program of continuing medical education (CME) as one that does not utilize funds from commercial interests that have been donated to support continuing medical education, i.e., Commercial Support-Free.^TM

I am not certain what the objective is in this call for comment (they do not outline a problem, so you are not certain what problem they are trying to solve);

Who is going to ensure that the CME is actually Commercial Support-Free, if I hold a meeting where there are booths and promotional programs adjacent to the program, is this considered Commercial Support Free?

Commercial Support-Free™ – implies that this brand is better than commercially-supported CME which is not branded.   In which the ACCME clearly has stated in their research that there is no evidence of one being better than the other, in fact, commercially-supported CME, has significantly more resources going into the course to ensure that they actually cover the learning objectives; and

Also, what is with the trademarks and ACCME, descriptor words like Commercial Support-Free™ are descriptors and not generally accepted as trademarks by the U.S. Patent and Trademark Office.

A special ACCME-defined designation of Promotional Teacher and Author-Free^TM Accredited Continuing Medical Education.

The ACCME proposes that these programs would not allow persons with ACCME-defined relevant financial relationships derived from marketing and promotional activities to teach–in, or write for, any part of a CME program that carries this designation.

In essence, compliance with Standard 2, Resolution of Personal Conflicts of Interest, of the ACCME Standards for Commercial Support^SM would be fulfilled by recusal.

This designation sets up a subclass of those speakers/authors who do not do work with industry to develop and market products are somehow less than those who do.  I would say the contrary is more in line with reality.  Industry seeks out relationships with the best doctors, and there is really no better place than the private markets for determining worth and value to society.

It is unclear on how these designations would be enforced, for instance, if I gave a promotional talk in 2004, would I still be considered a promotional speaker?

Overall, these last two (Commercial Support-Free, promotional teacher and author-free) designations only feed the flames of the protractors of commercial support, those who would like to see all money leave medicine and physicians to work for government salaries of less than $100K/year.

Independent CME Funding Entity.

The ACCME will consider creating a granting entity – independent of ACCME – that will accept unrestricted donations that will be designated for the special purpose of funding accredited continuing medical education.  The funds would be distributed to ACCME Recognized and Accredited organizations to be used for the development and presentation of ACCME-compliant continuing professional medical education.

This is a fund where the ACCME decides who gets monies for medical education.  Pooled funding sound altruistic, in reality, no one gives to pool funds, especially those where there is no clear objective or outcome.  So I would say this idea is a non-starter.

Everyone is encouraged to submit their comments by the due date of May 21^st, 2009.  Comments are encouraged and highly recommended..