Last month, the Academy of Managed Care Pharmacy (AMCP) sent a letter to the Accreditation Council of Continuing Medical Education (ACCME) regarding the recently released ACCME Standards for Integrity and Independence for Accredited Continuing Education. AMCP is an Accreditation Council of Pharmacy Education (ACPE)-accredited provider, and ACPE has adopted the new ACCME standards.
In the letter, Susan A. Cantrell, RPh, CAE, Chief Executive Officer of the AMCP, raised concerns about the new ACCME standards which include pharmacy benefit management (PBM) organizations in the list of ineligible entities. By including PBM organizations as ineligible entities, health professionals employed by those organizations are disqualified from being able to serve as faculty and planners for continuing education activities accredited by ACCME. Cantrell notes that the primary business of PBMs is not “producing, marketing, selling, reselling, or distributing healthcare products used by or on patients,” as stated in the definition for ineligible entities.
Cantrell highlighted that pharmacists, physicians, and others practicing in managed care settings are often the most appropriate teachers to address members of AMCP who are engaging in continuing education. She notes that “excluding clinical experts solely on the basis that they are employed by a pharmacy benefit manager impedes the providers’ ability to provide accredited continuing education that addresses the unique needs of managed care practitioners.”
Cantrell also brings up the “complex, vertically integrated environment” that is our current health system. Mergers and acquisitions have resulted in organizations that are made up of health plans, PBMs, outpatient clinics, and retail pharmacy networks. The ACCME standards are not clear on how such a “multifaceted health care organization” would be viewed.
In the letter, Cantrell also brings up the importance of keeping accredited education free from commercial bias and notes that as an accredited provider, the AMCP program has historically used employees from PBMs as both planners and faculty members. However, AMCP is careful to identify and resolve conflicts of interest and closely monitors activities for evidence of any potential commercial bias. Cantrell also notes that after reviewing their data, there is no indication of there being a higher level of commercial bias (perceived or potential) in those programs when compared to activities with non-PBM faculty.
Far Reaching Implications?
As alluded to above, the inclusion of PBM’s in the list of ineligible entities also affects employees and subsidiaries as ineligible entities. The new ACCME standards could potentially ban employees and organizations from leadership and accreditation roles at CME/CE activities. Some of those potentially affected by the new standards include: CVS Health (an ACPE provider which is owned by CVS/Caremark), Humana (an ACPE provider related to Human Pharmacy Solutions), and some joint accredited providers, including Optum Health Education and OptumCA as their related company OptumRX is a PBM owned by United Health Group, and Kaiser Permanente (considered an integrated delivery network but also serves as a PBM), plus many others.
Many organizations commented on this part of the regulation and perhaps this letter will drive the ACCME to revisit this part of the new standards.
Cynthia Reilly, MS, BS Pharm, Chief Operating Officer, AMCP, issued a statement regarding the letter and new standards, saying, “AMCP will always advocate on behalf of our members” and “AMCP strongly believes that our PBM members are key to developing credible, evidence-based education at our national meetings and other educational activities, and we will continue to include these members on our Educational Affairs Committee and as valued faculty. AMCP will continue its dialog with ACPE—an organization with a deep understanding of the pharmacy landscape and the important role of pharmacy benefit management.”