AOE Compliance Connection

Welcome to AOE’s first monthly newsletter of 2025! This January edition of AOE Compliance Connection features a recap of some of the most helpful compliance tips of last year (from ACCME and AOE, both!) and a look at an important conversation recently continued in the ACEHP Almanac about the need for CME reform in the future.

As you and your CE team dive into the new year, make sure to add our weekly social media posts to your regular rhythm to make the most of our compliance tips and updates.

The ACCME wrapped up 2024 with a look back at the top five compliance tips of the year from Dion Richetti, ACCME’s Vice President of Accreditation and Recognition.

Richetti points to these as helpful reminders for all accredited providers:

1. Providers are NOT required to identify, mitigate, or disclose financial relationships when it comes to non-clinical education. (Click here for more information!)
2. Collect only the disclosure information you need by using the ACCME’s disclosure form template as a guide.
3. Standard 3 makes an exception for spontaneous case conversations, but conversations at any planned activity do not qualify (including case conferences, RSS, grand rounds, and board conversations).
4. Beware the opportunities for bias in sneaky places! And remember that the CME content itself doesn’t have to promote an ineligible company’s business lines or products for there to be an opportunity for bias.
5. Just ask your learners to provide examples of changes they already made OR plan to make in order to analyze learner change.

Did you know that AOE posts weekly compliance tips on our website homepage and social media accounts? 52 posts each year to steer providers in the right direction and provide answers to the trickiest compliance questions.

Below, we share a few of our top compliance tips to ensure you and your team launch into 2025 on the best foot possible!

We delved into online/social media activity FAQs with questions like this one:

• Q: Are there special rules for preventing commercial bias when it comes to online/social media activities?
• A: The same requirements apply (all of Standard 2) but there are additional guidelines to help providers craft their activities to be posted online and via social media platforms. For example, looking at the platform host, the discussion forum, and the way in which materials will be handled. (Accredited Education Delivered via Online and Social Media Platforms)

We explored MIPS (Merit-Based Incentive Payment System) Improvement Activities:

• Q: Should we use quantitative or qualitative data to count for the MIPS Improvement Activity Programs?
• A: To count for the Merit-Based Incentive Payment System (MIPS) Improvement Activity: Completion of an Accredited Safety or Quality Improvement Program, the CMS expects activities to “include data collection and analysis of performance data to assess the impact of the interventions”. The providers are free to decide and choose the approach they’d like to use to measure the impact of the activity. Quantitative and/or qualitative may be used!

We unpacked each of the Standards, focusing on areas that frequently trip up providers:

• Q: Is it allowable for marketing/promotion to appear in a sidebar outside of the window where my online CE activity is viewed?
• A: No. According to Standard 5.2b, when offering online activities, providers need to make sure that ANY marketing for the products of ineligible companies is NOT presented to learners before, during, or after an accredited activity (and this would include a visible sidebar).

And we delved into MOC throughout the year:

• Q: For our MOC activities, how should we give the learners feedback?
• A: For MOC activities, as with other activities, feedback can be provided in many different ways. Some providers successfully use evaluation results (like quizzes, statement reviews, etc.) by correcting learner misconceptions/responses, showing the correct responses, and providing an explanation. This method can be done live or after the activity (asynchronously). Some providers include a case discussion during a live activity in which the faculty share with learners the decisions made and the case outcome. The ACCME also provides this evaluation guide to share different feedback examples for MOC activities.

You can view the weekly tip here, and lots of gems in the archive list. Follow AOE on social media (here or here) to be the first to see each week’s tip!

Last month, Tom Sullivan of the Policy & Medicine blog shined light on an important conversation in the CME enterprise. A recent ACEHP Almanac article, “Necessary Disruption 2.0: A Continuing Education Call to Action” take an honest look at the historical progress of CE and the “urgent need for ongoing reform”. Authors Ginny Jacobs, PhD, M.Ed., MLS, CHCP, FSACME; Brian McGowan, PhD; Nancy Paynter, MBA; and others point to the dramatically changing field of medicine in light of the recent advances in available tools and technology. Sullivan states that, “The article serves as a rallying cry for the Alliance for Continuing Education in the Health Professions community to lead transformative change in how healthcare professionals learn and adapt to technological advancements.”

The authors point to Alliance’s inception as a reaction to the same kind of conversations taking place nearly half a century ago. Now, the conversation details have changed (hello, AI!), but the heartbeat remains the same: CE must adapt along with the medical field.

The article does more than point out the shortcomings of our current system; it issues a call to action involving embracing digital tools and providing the education necessary to adequately train clinicians in these areas. It argues that educational designs must align with the actual experience of modern medical practice and “move towards more dynamic and responsive learning models that cater to the evolving needs of healthcare professionals”. The call to action also addresses the need for interdisciplinary collaboration, a conversation about ethical issues, and a new focus on personal health technology tools.

You can read the article in full here or catch the live session at the ACEHP Annual Meeting.

• Alliance 2025 Annual Conference
  January 8-11, 2025, Orlando, FL
  Read More >>
• NCPD 2025 Accreditation Workshop
  February 4-5, 2025, Virtual
  Read More >>
• Learn to Thrive 2025
  April 23-25, 2025, Chicago, IL
  Read More >>