Welcome to the July edition of AOE Compliance Connection, AOE’s monthly newsletter! This resource offers accreditation board bulletins for ACCME, ACPE and ANCC, along with industry updates and highlights, and information on upcoming activities and educational opportunities.
Navigating Education Excellence is our work. Our combined experience has improved effectiveness and success for more than 50 education providers, pharmaceutical CME/IME teams, hospitals, academic centers, and associations. Aristotle said, “We are what we repeatedly do. Excellence, therefore, is not an act, but a habit.” At AOE, excellence is more than a habit—it’s our business.
Enjoy this month’s edition of AOE Compliance Connection! Please visit www.aoeconsulting.com for even more information, including a library of guidelines and weekly compliance tips.
Accreditation Board Bulletin
ACCME
What is the largest area of noncompliance amongst ACCME-accredited providers? If you guessed Criterion 7, you’re right! Criterion 7 is inclusive of Standards for Commercial Support (SCS) 1, 2 and 6, and if found noncompliant with SCS 2, generally noncompliance with SCS 6 is also found.
Criterion 7 states that “The provider develops activities/educational interventions independent of commercial interests.” While this sounds simple, many accredited providers struggle to fully address the requirements of this criterion, particularly as it relates to SCS 2 and 6.
Some keys to compliance with Criterion 7 and SCS 2 and 6 include:
- Show that everyone in a position to control the content of activity (including their spouse/partner) has disclosed all relevant financial relationships, or the lack thereof, with an ACCME-defined commercial interest. This includes planners, managers, reviewers, faculty, etc. – anyone who can edit, modify, influence or create content. Disclosure must include the name of the individual, the name of the commercial interest(s) and the nature of the relationship the person has with each commercial interest. The ACCME considers a financial relationship to be relevant and thus create an actual conflict of interest when the individual has both a financial relationship with a commercial interest and the opportunity to affect the content of CME, which relates to the products or services of that commercial interest.
- Secondly, the provider must implement a mechanism to identify and resolve all conflicts of interest prior to the beginning of the educational activity. Documentation around the identification process in terms of ruling what financial disclosures pose a relevant conflict of interest, per the ACCME’s definition, is required.
- After a relevant conflict of interest(s) has been identified, an appropriate resolution mechanism must be implemented. Documentation regarding the resolution mechanism employed and the results of resolution is also required.
Recently, the ACCME created a helpful tool: “Flowchart for the Identification and Resolution of Personal Conflicts of Interest.” This tool is a step-by-step guide to help accredited providers meet the expectations of Criterion 7, SCS 2 and 6. In step D of the tool, several resolution mechanisms are discussed that providers can use for resolution that meet the ACCME’s expectations. For more information on Criterion 7, see provider examples of noncompliance and compliance here.
ACPE:
Awarding partial credit is a topic that causes many providers confusion. When is it allowed? When is it not allowed?
For ACPE-accredited providers, considering partial credit isn’t necessary. In Section V of the ACPE’s Policies and Procedures Manual, policy 5.0c stipulates that providers may not offer partial credit for CPE activities. Instead, the learner receives full credit for completing the activity successfully, and no credit for non-completion.
In the situation of a conference, or a multi-activity event, this requires a slightly different approach than with an ACCME-oriented event. To ensure learners receive credit for each session attended, if they are unable to attend all sessions associated with the conference, each individual session must be registered as an individual activity, complete with its own Universal Activity Number (UAN) and supporting documentation. This month, the ACPE announced plans to introduce new upload software for these circumstances when many UANs are requested at the same time.
By way of contrast, ACCME-accredited providers who are awarding AMA PRA Category 1 Credit™ for live activities can allow physicians to “claim credit based on their individual participation time”, as long as it doesn’t exceed the maximum credit being awarded for the activity. When claiming partial credit, physicians need to do so in 15 minute (or 0.25 credit) increments.
For ACCME enduring activities, the answer is similar to the ACPE’s policy: When a physician completes the activity (successfully), they may claim the full amount of credit for which the activity is designated, no matter how long it actually took to complete.
ANCC:
ANCC’s Primary Accreditation Criterion 3, Quality Outcomes (QO), requires the CNE Provider Unit engage in ongoing evaluation to analyze the degree to which it is meeting established goals at both the Provider Unit level and the Nursing Professional Development level. For each of these levels there are specific requirements set forth by the ANCC.
Provider Unit level:
QO1. Describe the process utilized for evaluating effectiveness of the Provider Unit in delivering quality CNE.
QO2. Describe how the evaluation process for the Provider Unit resulted in the development or improvement of an identified quality outcome measure for the Provider Unit.
Nursing Professional Development level:
QO3. Describe how, over the past twelve months, the Provider Unit has enhanced nursing professional development.
To ensure compliance across ANCC’s Criterion 3, some points to consider, include:
- Determine how your organization will evaluate the quality outcome measure(s) in specific terms.
- Decide how data will be collected to demonstrate evaluation of the quality outcome measure(s).
- Once data is collected, how will it be analyzed?
- Once analyzed how will your CNE Provider Unit evaluate the results to determine if goals have been met, or to establish new goals?
For additional inquiries, information and resources from the ANCC, access the ANCC website or contact AOE.
CME in the News: CME and Opioid Analgesics
Late this Spring, the FDA held a public meeting to discuss the training of health care providers regarding pain management and the (safe) use of opioid analgesics. Last month, the CME Coalition was featured in a Policy and Medicine article regarding its participation in that meeting.
Tom Sullivan and Andrew Rosenberg, of CME Coalition, contributed comments at the meeting to reinforce education’s (and specifically CME’s) valuable role in fighting the opioid epidemic and in reducing overdose deaths related to opioids. The summary article in Policy and Medicine stated that “to encourage clinician’s to participate in the Opioid REMS, the CME Coalition recommended that FDA work with CMS to include Opioid REMS CME as an improvement activity in the Quality Payment Program.”
Part of the FDA meeting agenda included proposing a broader Education Blueprint for Prescriber Education for Extended-Release and Long-Acting Opioids. The expanded version would include information on pain management, non-pharmacologic and pharmacologic treatments for pain. Electronic or written comments to the blueprint were requested and accepted until the middle of this month.
As the Opioid REMS conversation unfolds, CME and education will continue to prove itself a valuable tool in the battle to reduce opioid deaths.
AOE in the Spotlight: Grant Submission 101
CME programs vary widely in their funding mechanism(s). Commercial grants help to fund many accredited CME activities. Whether your program is well-versed in securing commercial support or only beginning to explore potential commercial funding opportunities, the following tenants will provide guidance to ensure efficiency and maximization of resources.
Timeline: First, determine whether you have sufficient time to solicit commercial support. Each commercial funder has a minimum deadline by when a grant request must be submitted, based on launch of your accredited activity, but to be most competitive, submitting well ahead of those deadlines is recommended. Depending upon the type of activity and size of the grant request, submitting your grant six months in advance of a CME activity is a good plan. For large grant request, submitting your grant 8 to 12 months in advance may be more advantageous.
Funding Availability: Before committing resources to grant development, identify the commercial interest(s) that you will submit to. Determine which companies are funding grants in the disease state/therapeutic area that your CME activity will address. Only submit grants to those commercial interests who clearly indicate that funding is available in the specific area therapeutic area your accredited activity will be addressing.
Needs Assessment: This critical component should position your CME activity to stand out amongst hundreds of competing applications/proposals. Ensure that it is detailed, well referenced, and clearly articulates the professional practice gap(s) and underlying educational need(s) of your target audience.
Budget: Each commercial funder will have their own budget template that must be completed, but AOE recommends creating a detailed budget template that can then be translated to a specific funder’s preferred template.
Grant Application: If soliciting funds from multiple funders, for the sake of efficiency, consider compiling a general grant application which can be easily modified to fit each funder’s unique grant portal requirements. Minimum elements for the grant application to include are the needs assessment, learning objectives, detailed information about the target audience, location information (if live), the agenda, and information regarding education outcomes methods.
Key Documents: Before you start registering in each grant portal and begin the application process, ensure that you have key documents on hand. This includes your organization’s W9, tax status documentation, and accreditation certificate. You should also confirm who has legal signing authority for your organization.
Ultimately, up-front planning can prepare your CME program to smoothly and efficiently submit grants across multiple funders.
Upcoming Activities/Education Opportunities
- ANCC CNE Symposium
July 18, 2017, New Orleans, LA
Read More >> - Association for Nursing Professional Development Annual Convention
July 18-21, 2017, New Orleans, LA
Read More >> - Self-Study for ACCME Accreditation Webinar
July 25, 2017, Online
Read More >> - ACCME August 2017 Accreditation Workshop
August 2-4, 2017, Chicago, IL
Read More >> - ANCC Practice Transition Accreditation Program Introductory Workshop
August 4-5, 2017, Los Angeles, CA
Read More >> - ANCC Primary Accreditation Workshops
August 16-18, 2017, Silver Spring, MD
Read More >> - “CME for MOC: Ask Your Questions” Webinar
September 13, 2017, Online
Read More >>
