The Society of Academic Continuing Medical Education (SACME) recently published their responses to the ACCME and AMA CEJA.
Overall both documents reflected a call for a uniform system of CME and not to have two separate systems of CME based on commercial support. They are also both supportive towards commercial support of CME activities.
To the ACCME they wrote:
· There should be one standard for CME accreditation. Creating a system where there are two categories has the potential to create the impression that commercially supported CME is somehow inferior to that receiving no commercial support. As such, it would then inappropriately imply that commercially supported CME is biased.
· A dual system of accreditation would add confusion, complication and additional bureaucracy to an already cumbersome system.
· There are currently providers who do not accept any commercial support or who have programs that do not accept commercial support. These activities can be promoted as such without the need for another accreditation standard.
· Under the existing Standards for Commercial Support, high quality CME activities are produced everyday by providers that accept unrestricted educational grants.
To the CEJA Committee they wrote:
· Much of the discussion on bias in CME and the influence of CME on a physician's prescribing patterns is drawn from analyses of CME activities that occurred prior to significant changes in the regulatory landscape of CME.
· There is no mention of the June 2008 report commissioned by the ACCME, The
Relationship between Commercial Support and Bias in Continuing Medical Education Activities: A Review of the Literature which found that there is no empirical evidence to support or refute the hypothesis that CME activities are biased".
· There is no discussion of how the field of CME has evolved. The very issues cited by the outdated research led to the implementation of the first ACCME Standards of Commercial Support in 1992, and development of the CEJA Opinion 8.061 Gifts to Physicians from Industry. Since then, the current ACCME Standards for Commercial Support™ 2004, coupled with FDA restrictions (7), guidance from the OIG , the new codes of conduct from PhRMA, AdvaMed, and stricter institutional policies on faculty interaction with industry, have further strengthened the environment in which CME is produced.
· Based on the issues raised above, the CEJA recommendation of a framework of "ethically preferable" and "ethically permissible" continuing medical education activities creates a false dichotomy between providers that accept commercial support and those who do not. Implicit in this dichotomy is the perception that commercially supported CME is inherently biased.
· The term "ethically permissible" is in error. The 2004 SCS, Standard 3 indicates that a provider "cannot be required to by a commercial interest to accept advice or services concerning teachers, authors, or participants or other education matters, including content, from a commercial interest as conditions of contributing funds or services." If there is any language in a LOA that even suggests industry input or control of content, accredited providers are prohibited from signing that LOA. Further elaboration by the ACCME has indicated that CME providers may not even solicit suggestions on content or speakers from a commercial supporter nor ask a supporter to verify whether scientific content in a CME activity is accurate.
· Additionally, within the recommendation of what is "ethically permissible", there is language that is vague and confusing. For instance, how can a physician determine which CME provider is "overly reliant" on commercial support and which is not?
Overall both statements are firm that academic medical systems prefer to work under the current system of CME as opposed to setting up dual CME systems. The amount of paperwork that is required is now enormous and there is a frustration with all these proposed changes which are taking place while still trying to implement the current changes in the rules.
CEJA was rejected by the AMA House of Delegates and we will know more in the fall on the ACCME call for comment.
Society of Academic Continuing Medical Education