AOE Compliance Connection – October 2017 Newsletter

Welcome to the October edition of AOE Compliance Connection, AOE’s monthly newsletter! We are excited to share our monthly ACCME, ACPE and ANCC board updates along with news from the world of CME/CE. This newsletter is one of the many ways we stay in touch with our clients, providing educational resources to help you achieve compliance and success in your CME/CE endeavors.

This month, AOE is thrilled to welcome its newest member to our Managing Director, Annika, and her husband, Justin – it’s a boy!  Soren Blair Borvansky was born Saturday, October 7th at 11:03am weighing in at 6lbs 11oz and 20 inches. Annika and baby are doing very well!

We hope you enjoy this month’s edition of AOE Compliance Connection! Visit www.aoeconsulting.com for additional information, weekly compliance tips, guideline updates and more!

An important part of the educational design process for ANCC Accredited Providers is the determination of the criteria that learners must meet to earn contact hours as well as correctly calculating the amount to award for an accredited CNE activity.

Criteria for awarding contact hours should be based on the desired learning outcomes (i.e. knowledge, skills, and/or performance) and determined in a logical and defensible manner. Examples of criteria often includes, but are not limited to:

• Participation in the activity
• Attendance for a specified period of time
• Successful completion of a post-test
• Completion of an evaluation form
• Successful completion of a return demonstration

Contact hours are awarded to learners for the portions of a CNE activity that are devoted to the learning experience and evaluation/assessment time spent at an activity. If an activity lasts sixty minutes, and meets the standards, then one contact hour may be approved. The ANCC does allow contact hours to be rounded, but only to the nearest 0.1 or 0.01.

For a live CNE activity, the timeframes must support the contact hour calculation. Examples of evidence to document the timeframes may be shown via the agenda for the activity, outline of content to be delivered in the activity and/or other marketing materials as appropriate. When breaks and meals occur, there should be a clear allocation and this time is not to be included in the total contact hours awarded.

Enduring CNE activities should have a clear method for calculating contact hours identified prior to activity launch. Methods implemented for calculating contact hours for enduring material may include a pilot study or historical data.

The AMA and ACCME have released additional resources to support the recent alignment of their expectations for CME certified for AMA PRA Category 1 Credit™. The two new resources include a FAQ about the alignment and a revised AMA PRA booklet. The revised section of the booklet is specific to the “Requirements for educational activities eligible for AMA PRA Category 1 Credit™”.

The FAQ about the AMA/ACCME alignment webpage addresses frequently asked questions in the categories of:

• Core Requirements
• Enduring Materials
• Journal-based CME
• Test-item Writing
• Manuscript Review
• PI CME
• Internet point-of-care

It includes a designated section for additional questions, along with a summary table tool for calculating and designating credit.

The AMA PRA booklet includes the recent updates, in addition to AMA core requirements, format-specific requirements, requirements for designating and awarding credit, and instructions about the credit designation statement.

The ACCME and AMA have long been vocal about this simplification and alignment reflecting a desire for increased innovation and flexibility. Providers can now use the designation “other” for activities that reflect a blended approach and do not fit into an established learning format. The ACCME has explained that they are, “using the label “other” because we do not want to imply any restrictions on this category and to encourage providers to develop new, creative, and blended educational approaches. As providers design and describe innovative approaches to education, we expect to identify a descriptor that better represents the evolution of CME.”

For more information, please visit the AMA/ACCME Alignment webpage.

When it comes to resolving conflicts-of-interest for faculty and presenters, the most common mechanism of resolution is a clinical content review. Most providers utilize a standard form for reviewing content and rely upon the expertise of individuals with a clinical background. This typically includes members of a CME or Education Committee or healthcare providers within an organization.

But is completion of a clinical content review sufficient to demonstrate resolution for a conflicted presenter?

It depends on a few variables:

• Did the clinical content reviewer indicate that the content was fair and balanced, free from commercial bias, evidence-based and did not require any changes to the content? Then completion of the form is sufficient documentation to show resolution.
• If, however, the clinical content reviewer indicated that there were concerns regarding fair balance, commercial bias, evidence-based recommendations and/or required changes to the content, then, no, completion of the form is not sufficient documentation. It is incumbent upon the CME provider to take the following next steps:
  • Correspond with the presenter regarding required content changes.
  • Request resubmission of the updated content and complete a re-review to ensure that required changes were implemented. In some cases, a presenter might provide justification for not implementing a required change. If the CME provider is in agreement, it should be documented on the review form and saved to the activity file.

Remember: The key to resolution with a clinical content review is to fully close the loop.