Welcome to the AOE Compliance Connection, AOE Consulting’s monthly newsletter. This resource offers accreditation board bulletins for ACCME, ACPE, and ANCC, along with regulatory updates, highlights of AOE’s services, 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! We encourage you to visit www.aoeconsulting.com for more information, including weekly compliance tips and bi-monthly video blogs!
Accreditation Board Bulletin
ACCME: Recently, the ACCME announced changes to acceptable methods of transmission of disclosure to learners. Previously, accredited providers were prohibited from providing disclosure information through a link or a tab within a website. The method of disclosure had to ensure that a learner “passed through” any electronic disclosure information prior to their engagement in the activity. The ACCME has announced that accredited providers are now allowed, beginning immediately, to use tabs, links, or other electronic mechanisms to transmit disclosure information to learners, as required by Standard for Commercial Support 6: Disclosures Relevant to Commercial Bias. Please note that nothing else has changed other than how information can be transmitted; all other requirements related to disclosure remain unchanged. Additionally, ACCME continues to expect that disclosure information will be delivered to learners prior to the beginning of a CME activity, and that the disclosure information will be clearly marked, accessible, and useful for learners. A new FAQ related to this change is available on ACCME’s website here: http://www.accme.org/ask-accme/can-we-use-tabs-links-or-other-electronic-mechanisms-transmit-disclosure-information
The ACCME also recently provided added clarity regarding the role of commercial industry employees in the planning and delivery of accredited CME activities. While the rules surrounding involvement of commercial industry employees in CME activities have not changed, the ACCME has released a tutorial page, which includes links to FAQs, case examples, videos, and other valuable resources, providing added detail around this issue. As a recap, involvement of employees of ACCME-defined commercial interests in a CME activity is prohibited, except in three specific situations (from the ACCME’s website):
- Employees of ACCME-defined commercial interests can control the content of accredited CME activities when the content of the CME activity is not related to the business lines or products of their employer.
- Employees of ACCME-defined commercial interests can control the content of accredited CME activities (e.g., as planners, authors, or speakers [including poster presentations]) when the content of the accredited CME activity is limited to basic science research (e.g., pre-clinical research, drug discovery) or the processes/methodologies of research, themselves unrelated to a specific disease or compound/drug. In these circumstances, the accredited provider must be able to demonstrate that it has implemented processes to ensure employees of ACCME-defined commercial interests have no control of CME activity content that is related to clinical applications of the research/discovery or clinical recommendations concerning the business lines or products of their employer.
- Employees of ACCME-defined commercial interests can participate as technicians in accredited CME activities that teach the safe and proper use of medical devices. In this circumstance, the accredited provider must demonstrate that it implements processes to ensure that employees of ACCME-defined commercial interests have no control of CME activity content that is related to clinical recommendations concerning the business lines or products of their employer.
ANCC: ANCC recently announced at their annual meeting, the ANCC Commission on Accreditation conducted a review of proposed revisions to the 2013 accreditation criteria, along with the requirements for ANCC providers and approver units. The Commission approved a revised and streamlined version of criteria and requirements and solicited feedback from accredited organizations in response to the proposed changes. These revisions were recommended based on feedback received from stakeholders through ANCC’s annual customer satisfaction survey, staff, appraiser and commissioner feedback, and direct conversations that have occurred. These proposed revisions address recurrent concerns regarding the burden of documentation and redundancies found within the 2013 critiera. Additionally, the ANCC has a desire to continue to maintain their alignment with other continuing education accreditors. Accredited organizations are to be informed of final criteria and revisions to the proposed requirements by July 6, 2015.
The following is a brief summary of the proposed changes:
- Reduce the total number of criteria for Accredited Approver Units from 48 items to 28 items
- Reduce the total number of criteria for Accredited or Approved Provider Units from 37 items to 24 items
- Revise the language for geographic range restrictions from “marketing to” to “target audience” (Approver Units only)
- Removing “key personnel” as required defined members of an Accredited (or Approved) Provider or Approver Unit
- Revise purpose to learning outcome
- Remove requirement for objectives at the individual activity level (focus on learning outcome)
- Remove requirement for Accredited (or Approved) Provider to document qualifications (biographical information) of individuals involved in planning or presenting an educational activity (Exception: requirement for biographical information maintained for Nurse Planner and content expert for individual activity applicant to Approver Units only); no changes to documentation related to conflict of interest
- Revising the requirements for Joint Providership as the responsibilities inherent of any Accredited (or Approved Provider) providing ANCC contact hours
- Adding a disclosure requirement for Joint Providership
- Removing requirement that accreditation/approval statement stand on its own line of text
- Removing all requirements related to Sponsorship
Look for full details of the proposed changes in your inbox from ANCC: Director’s Update for Accredited Organizations.
AMA Insights
Do you have questions related to AMA? Often times, accredited providers search for answers to their CME-related questions on the ACCME’s website, when the answer is actually associated with an AMA policy or guideline. AOE fields many questions that are AMA-specific and we want to share some of the most recent with you:
Q: Can residents earn AMA PRA Category 1 Credit™?
A: Yes, as residents have obtained their MD or DO, they are eligible to claim and be awarded AMA PRA Category 1 Credit™. Whether or not residents need CME is a separate issue and varies from state to state. CME requirements often begin with a full and active license, which may or may not start during the residency period. Most states allow graduate medical education (GME) to meet all or at least some portion of the CME requirement, however. Some states have asked for evidence of CME when residents apply for a license in a state other than which they trained but there is no universal situation in regards to whether or not residents need CME. All in all, if a resident claims CME from your organization, than the organization needs to award it to them.
Q: What other formats are approved to offer CME besides live activities?
A: Formats approved for to AMA PRA Category 1 Credit™ can be referenced starting on page 4 within the AMA PRA Booklet. Most commonly accredited CME activities, beyond live, include: Enduring materials, Journal-based CME, Performance Improvement Continuing Medical Education (PI CME) and Internet Point-of-Care Learning (PoC).
Q: Do I have to italicize the AMA PRA Category 1 Credit™ every time I use it?
A: The phrase “AMA PRA Category 1 Credit™” is a trademark of the AMA. All accredited CME providers must use the complete italicized, trademarked phrase any time they are referring to AMA PRA Category 1 Credit™. The phrase “Category 1 Credit” and never be used in its place, as a condensed reference.
Q: Are there specific activities that are ineligible for AMA PRA credit?
A: Yes, CME credit may not be claimed for learning activities which are related to the normal professional activities or practice of a physician. Specifically, CME credit may not be earned for: clinical experience; charity or mission work; mentoring; surveying; serving on a committee, council, task force, board, house of delegates, or other professional workshop; or passing examinations that are not integrated with a certified CME activity.
AOE Service in the Spotlight
Has your organization received notification of reaccreditation milestones from the ACCME as part of the November 2016 ACCME Re-Accreditation Cohort? Is your organization part of a more distant cohort, but interested in planning ahead? Or, is your organization about to embark on the re-accreditation process with the ANCC or the ACPE? Let AOE put our experience to work for you. Our CME/CE Re-Accreditation Consulting Services. We work with your organization to navigate the ever changing landscape of CME/CE re-accreditation, providing guidance and assistance with services tailored to meet your needs. AOE has been involved in more than 30 successful accreditation/reaccreditations, while the AOE team’s combined experience has improved effectiveness and success within more than 40 societies, hospitals, medical education companies and academic centers.
As a leader in re-accreditation support and management, we provide the following services:
- CME/CE Program Audit and Accreditation Workshop
- CME/CE Policy &Procedure Review, Updates and/or Development
- ACCME, ACPE, and ANCC Self-Study Design, Development, Compliance Review and/or Editing
- Activity File Audit
- Performance-in-Practice Activity Compilation and/or Compliance Review
- Mock Survey
Upcoming Activities/Education Opportunities
- ACCME Accreditor Webinars-June
June 18, 2015, 1:00 PM-2:00 PM, Webinar
http://www.accme.org/events/accreditor-webinars-–-june - ANCC Annual Symposium on Continuing Nursing Education
July 14, 2015, Las Vegas, NV
http://www.nursecredentialing.org/CNE-Symposium - Becoming an ACCME Volunteer Surveyor
July 30, 2015, 1:00 PM-2:00 PM, Webinar
http://www.accme.org/events/becoming-accme-volunteer-surveyor-8 - Self-Study for ACCME Accreditation Session
August 5, 2015, Chicago, IL
http://www.accme.org/events/self-study-accme-accreditation-session-5 - 2015 Alliance Quality Symposium
September 28-30, 2015, Chicago, IL
http://www.acehp.org/p/ca/vi/sid=3 - 2015 CPE Administrator’s Workshop
October 1-2, 2015, Chicago, IL
https://acpe-accredit.formstack.com/forms/untitled_form_copy
