We recently posted about the Accreditation Council for Continuing Medical Education (ACCME) decision to ban corporate logos on any educational materials. In addition, the ACCME announced a couple of other proposals at their last Board of Directors Meeting.
CMS Open Payments: Communicating the Equivalency of the ACCME and SMS Systems
The Centers for Medicare & Medicaid Services (CMS) Open Payments rule includes an exemption for activities produced by CME providers accredited by the ACCME. In order to help support the inclusion of intrastate providers in this exemption, the ACCME has published and communicated the equivalency of the ACCME and Recognized Accreditor systems. (Recognized Accreditors are state or territory medical societies that are recognized by the ACCME as accreditors of intrastate CME providers.) The ACCME’s communication is shown here:
Within the ACCME system, all accredited providers meet one set of standards and are accredited using an ACCME-determined process. All the accredited CME generated by a provider within the ACCME system (i.e., ACCME-accredited CME) meets the same requirements and standards. Operationally, within the ACCME system, there is a distribution of responsibility for accreditation between the ACCME and its recognized state and territorial accreditors, based on the target audience of the providers (i.e., the ACCME conducts the accreditation of providers that have a national audience and the state medical societies conduct the accreditation of providers of CME for their state or contiguous states). The accreditor is the only difference between ACCME-accredited providers and state medical society accredited providers. All the accredited CME events/activities presented by these providers are ACCME-accredited CME, and all ACCME-accredited CME is required to meet the same ACCME requirements. The ACCME has processes in place to ensure this identity and has data that verifies this identity. Each CME provider in the ACCME system can be identified by an ACCME Provider Number. All CME providers in the ACCME system are listed on www.accme.org.
ACCME Process for Verifying Accreditors Adhere to Standards for Commercial Support
The Board determined that the ACCME will institute a process for verifying that eligible domestic and international continuing education (CE) accreditors in the health professions adhere to the Standards for Commercial Support℠: Standards to Ensure Independence in CME Activities (SCS). The verification model will be based on the long-established ACCME system for recognizing state/territory medical societies. The ACCME will apply the relevant Markers of Equivalency to determine the accreditors’ equivalency. The verification process will be overseen by the ACCME’s Decision Committee of the Board of Directors. The verification process builds on existing ACCME services, including the recognition process for state medical societies, the process the ACCME used to license the SCS to the Accreditation Council for Pharmacy Education, and the Substantial Equivalency process for international accreditors. The ACCME is instituting the verification process in response to requests from CE accreditors in the health professions.
The ACCME also acknowledged the continuing medical exemption within the Physician Payments Sunshine Act:
Analysis
Though there is little actual information from reading this, it is our interpretation that ACCME is setting up a system to certify other accreditation systems to offer ACCME credit to equivalent accreditation systems that adopt the ACCME Standards for Commercial Support℠. For instance provider’s pharmacy and nursing credit may be able to offer ACCME credit to their activities, and thus the programs would qualify for the CME exemption under the Open Payments reporting. This would eliminate the requirement to report payments to physician faculty at those activities
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Currently, the Sunshine Act exempts from reporting continuing medical education that is accredited by five specific bodies: the Accreditation Council for Continuing Medical Education, the American Academy of Family Physicians, the American Dental Association’s Continuing Education Recognition Program, the American Medical Association, and the American Osteopathic Association. In January of this year, we argued that ACCME state-accredited CME activities are clearly exempt under Sunshine. The ACCME has confirmed that this is the way they are approaching the matter as well. We also hope that ACCME’s intent to examine other accrediting bodies for adherence to their Standards for Commercial Support will help in the push to get Congress to expand the list of accreditors covered by the Sunshine Act’s CME exemption.