In another solid effort to confront the necessary and important role industry places in continuing medical education (CME), The Alliance for Continuing Medical Education (The Alliance) submitted this response to the to the ACCME 2009 Call for Comment.
1. ACCME Rule Making
While the Alliance acknowledges ACCME for adopting a formal notice and comment policy, they are concerned that the policy suggests that the call for comment period could be limited to as few as 30 days. As a result, this time frame was deemed insufficient time for organizations to secure appropriate internal feedback and governing body approval, if necessary, on their comments. Instead ACCME should adopt a policy that provides at least 60 days for review and response so as to facilitate involvement by all participants in an organization’s CME program.
The Alliance also does not comprehend what circumstance could arise that would be so urgent as to not allow for a call for comment or time frame. They assert that this exception is unnecessary, and if ACCME were to do this they should provide examples that illustrate the type of relevant issues that would be so urgent as to mitigate an opportunity for public comment.
2. Commercial Support-Free Accredited CME
The Alliance does not support the proposed new ACCME designation for “Commercial Support-Free Accredited CME” review process or the proposed new trademarks.
– The proposed designation of credit implies that a commercially supported activity or program is inherently compromised with regard to independence, and that programs that are not commercially supported are inherently unbiased. Both implications are unfounded.
– The Alliance recommends that organizations that receive funds from advertising or promotion establish firewalls between the promotional and education departments and not “bundle” education activities with promotional fees.
In addition, because many CME provider organizations receive funds from ACCME-defined commercial interests for advertising and/or promotion, receiving this source of funding could prohibit a CME provider organization from seeking designation as being “Commercial Support-Free™” when it does not seek nor accept industry donations in the form of grant support for its CME program and activities.
3. Promotional Teacher and Author-Free Accredited CME
The Alliance does not support the proposed new ACCME designation of a promotional and author free accredited CME, nor the proposed trademarks.
– There is no rationale for establishing a “class system” for authors and speakers.
– The Alliance believes that when accredited providers comply with the ACCME's Essentials, Elements, Policies, and Standards there are sufficient safeguards to ensure that certified CME activities are developed in a fair and balanced manner, upholding the standard of providing the best available evidence in a manner that will positively impact patient care.
– There is no such evidence to support that clinical research presented by faculty with industry relationships is inherently compromised in contrast to research presented by faculty with no such relationships.
– Policy development should be driven by sound, evidence-based data and that this proposed change to the accreditation system should not be made in the absence of relative supporting data.
4. Independent CME Funding Entity
The Alliance does not support ACCME’s proposal to establish an independent CME funding entity because it goes beyond the scope or authority of ACCME.
– No single entity should be in the position of controlling which organizations receive funding, thereby steering the agenda of continuing education offered in the US.
– This organization would directly compete with the fundraising initiatives of providers, unless the ACCME establishes policy that precludes an organization from using any funding source other than this new entity.
– Since many organizations have foundations in place that serve this same function, this new entity would operate in direct competition with these foundations, which is counterproductive.
– This independent organization would create a cumbersome grant process, in which small CME provider organizations would not have sufficient staff to support grant writing initiatives. This process would make funding educational initiatives less nimble – leading providers to take far longer to develop and implement cutting edge education as they wait for approval for a grant.
In the end, the Alliance along with PhRMA and other organizations such as IOM believe that there is no need to eliminate or change current funding mechanisms. In fact, the Alliance strongly recommends that if ACCME wants to engage in this discussion, ACCME should work with accredited providers to identify realizable funding sources. As a result, ACCME must realize that attempts to undermine the current process of CME funding will only result in a depletion of health care and outcomes for patients, which is the exact opposite goal of all medicine. Hopefully, these comments along with those from similar organizations will begin to ring loudly enough in ACCME’s ears for them to recognize that not all conflicts are corrupt, and not all interests are conflicts.