In April, the Accreditation Council on Continuing Medical Education (ACCME) issued a call for comments in four areas:
- Rule making process;
- Designation of commercial free Continuing Medical Education (CME);
- Designation of promotional speaker and author free CME; and
- Setting up a fund to raise commercial funds for CME.
Several organizations who responded have released their comments to the public, including the Coalition for Healthcare Communication (the Coalition), the Council of Medical Specialty Societies (CMSS) and the North American Association of Medical Education and Communications Companies (NAAMECC).
- Overall, it looks as though organizations applaud ACCME for adopting an open system of comments prior to decisions on ACCME Standards;
- Generally disagree with the designations of commercial free CME, and promotional and author free CME designations; and
- On the issue of starting a separate CME fund, most parties are confused by the purpose of those proposals.
The Coalition for Health Care Communication
The Coalition applauds ACCME for opening this rule making proceeding. We also recommend that ACCME post all proposed rules before they go into effect, and provide an opportunity to comment before final implementation.
A new category designation not be developed for commercial support–free certified CME. However to address the concerns of users to any potential impact of commercial support, ACCME could adopt enhanced identification standards that would enable users to easily determine if a CME activity has commercial support.
Enhanced identification could include:
- Specific, standardized ACCME verbiage alerting users to the use of, or not of, commercial support, or
- A standardized statement identifying no commercial support where appropriate, including specific rules on how and where the statement should appear within the CME activity.
Coalition’s Response to ACCME Calls for Comment May 2009
ACCME urged to Post “Final Rules” for additional comment
View Coalition Comment
No “Commercial Free” designation needed
View Coalition Comment
No “Promotional Speaker and Author Free” designation needed
View Coalition Comment
Formation of an Independent Funding Entity
View Coalition Comment
Council for Medical Specialty Societies (CMSS)
CMSS applauded ACCME for not taking action to end commercial support, but was skeptical of the proposed changes, especially the designation of commercial free, promotional, and teacher free designations. They also saw that there was no reason for the proposed fund for CME.
CMSS supports ACCME’s decision to not take any action to end the commercial support of accredited CME.
CMSS does not support the proposed new ACCME designation and review process, nor the proposed new trademarks.
Branding CME as “commercial support free” implies that the accreditor believes, and wishes to send the message that CME that is not commercially supported is better than CME that is commercially supported.
ACCME’s own commissioned meta-analysis by Cervero did not support this position. Moreover, ACCME would be sending an inconsistent message by affixing a special brand to CME that is not commercially supported, but not to CME that conforms completely to the ACCME Standards for Commercial Support.
CMSS does not support plans by ACCME to create a non-profit foundation to serve as central granting agency for commercial support.