The Accreditation Council for Continuing Medical Education (ACCME) recently announced a public call for comment about its proposal to simplify the accreditation requirements and process. Comments will be accepted through January 31, 2014.
Among the proposals, the ACCME is planning to implement the policy change “prohibiting the use of logos of ACCME-defined commercial interests in commercial support acknowledgments.” Policy and Medicine has written about ACCME’s proposed updates to its Standards for Commercial Support. The full proposal for “Simplifying and Evolving the Accreditation Requirements and Process,” published May 21, 2013, is available here. Specifically, the ACCME is proposing the following changes to sections 4.3 and 6.4:
SCS 4.3: Educational materials that are part of a CME activity, such as slides, abstracts and handouts, cannot contain any advertising, corporate logo, trade name or a product-group message of an ACCME-defined commercial interest.
SCS 6.4: ‘Disclosure’ must never include the use of a corporate logo, trade name or a product-group message of an ACCME-defined commercial interest.
According to Murray Kopelow, MD, CEO of the ACCME “The issue is not new and we do not believe it requires further explanation. We described the principles of this policy in the 2011 call for comment.” At that time the ACCME recieved input from stakeholders but they delayed action on this until a later time. Now the ACCME is bringing back this issue. From the description, it is not clear what motivates them to bring this issue up again at this time.
Alternative Solution
In response to these proposals and amended changes, the CME Coalition recently created “Responsible Logo Use Guidelines” for CME providers. In announcing the guidelines, the Coalition stated its belief that “the use of corporate logos provides transparency and disclosure to learners on educational grants obtained from commercial interests (CI) in support of an educational activity.” The CME Coalition proposes the following guidelines to help providers:
- Accredited providers are responsible for ensuring the disclosure and acknowledgement of commercial support, including the appropriate use of corporate logos in activity materials.
- Disclosure of support from a CI through the use of a commercial supporter corporate logo must be accompanied by the provider’s logo in the appropriately designated area of the activity materials.
- Disclosure of support from a CI including (or with) the use of a corporate logo should occur only once in the appropriate section of the activity materials (e.g. brochure, handout, printed piece, or digital medium). Providers may also elect to acknowledge commercial support elsewhere by listing the CI name without the accompanying corporate logo.
- CI corporate logos may not exceed the size of the provider’s logo(s).
- To ensure that logos are not inadvertently over-emphasized due to layout or design features, providers should be consistent in appearance with the color used in the disclosure of commercial support section of the activity (e.g., if a print piece is 4-color then all logos should also be 4-color, if the print piece is in black and white then all logos need to be in black and white). Logos from commercial supporters will not supersede those of the providers.
- Acknowledgement of exhibitors using logos is permitted.
The CME Coalition’s voluntary industry guidelines for responsible logo use are intended to offer a best practices code of conduct for the responsible use of logos at accredited CME events. A list of organizations that have pledged to adopt these voluntary guidelines is available here.
ACCME’s complete list of proposed changes includes:
- Simplifying and removing some of the Accreditation Criteria and policy requirements
- Changing terminology from “joint sponsorship” to “joint providership”
- Implementing the policy change prohibiting the use of logos of ACCME-defined commercial interests in commercial support acknowledgments
- Offering providers an abstract as an ACCME-approved tool to use when verifying performance-in-practice
- Simplifying the process for organizations applying for initial accreditation
Discussion
The concept of simplifying the process should be applauded. There are many smaller providers who have given up on attempting to keep up with the paperwork. In some states such as Arkansas there is only one CME provider for the entire state.
Organizations should be prepared to respond to this call for comment by January 31st. We believe that banning logos will have the exact opposite affect that what we think ACCME is hoping for which is greater transparency. That the learner will be less aware of who the supporter is which will mean less not greater transparency.
For more information on the call for comment, here is the ACCME announcement.