AOE Compliance Connection – June 2019 Newsletter

Welcome to the June ’19 edition of AOE Compliance Connection, AOE’s monthly newsletter. As summer begins, allow AOE to keep you updated on the latest news throughout the CME enterprise. In addition to the buzz about the ACCME’s new tiered fee schedule, this month we’ll be covering the responses to the ACCME’s call for feedback, the ACPE’s new mobile app for pharmacists, the ANCC’s take on Independence in activity planning, and the basics of ACCME Initial Accreditation to any provider new to the world of CME! (Welcome!)

AOE strives to serve you and your CME/CE team with excellence. Our website has helpful tools like compliance tips, CME/CE news and information about the AOE team – visit aoeconsulting.com to see what’s all available!

Is your organization considering or has it considered becoming accredited through the ACCME in order to be able to provide AMA PRA Category 1 Credits™ to physicians? Seeking ACCME accreditation takes time, energy and investment and can often feel overwhelming. Below we’ve outlined the key information and highlighted some considerations for organizations to weigh.

The ACCME has set forth the following eligibility requirements an organization must meet, in order to apply for and receive initial ACCME accreditation:

• The organization cannot be a commercial interest.
• It must be developing and/or presenting a program of CME for physicians on a regular and recurring basis.
• The organization cannot be developing and/or presenting a program of CME that is, in the judgment of the ACCME, devoted to advocacy on unscientific modalities of diagnosis or therapy.
• Activities must have “valid” content which is to say that activities must promote recommendations, treatment or manners of practicing medicine that are within the definition of CME. Organizations are not eligible for ACCME accreditation if they present activities that promote treatments that are known to have risks or dangers that outweigh the benefits or are known to be ineffective in the treatment of patients.

Obtaining ACCME accreditation is a two-phase process that, according to the ACCME, takes between twelve to eighteen months.

Phase I: The first phase is completion of a Pre-Application. Organizations must request a Pre-Application from the ACCME. The ACCME has provided a Sample Pre-Application which outlines the information that must be submitted. Prior to requesting the Pre-Application, it is important that an organization has a clear understanding of the ACCME accreditation requirements including the ACCME Accreditation Criteria, ACCME Standards for Commercial Support^SM and ACCME policies. Submission of the Pre-Application does include a $1,500 fee (as of the date this article was published). Once submitted, the ACCME will review the Pre-Application materials to determine an organization’s eligibility to move forward. Through this review, the ACCME is seeking to determine if an organization has mechanisms in place to meet the requirements. The review takes approximately four weeks from receipt of the Pre-Application. If the ACCME approves an organization to move forward, the organization moves on to Phase II.

Phase II: Once approved to move forward, an organization has up to nine months to complete Phase II, which includes conducting and submitting a Self-Study Report, submitting Performance-in-Practice evidence, and engaging in an Accreditation Interview. The second phase of the process requires payment of the Initial Accreditation Fee of $9,000 (as of the date this article was published).

Upon conclusion of the Accreditation Interview, an organization will be notified as to the Accreditation Decision. Provisional Accreditation is a two-year term awarded to initial applicants that demonstrate compliance with Accreditation Criteria 1-3 and 7-12.

Ultimately, ACCME accreditation can benefit an organization and specifically, its educational program. However, as with all major endeavors, organizations must weigh all factors to determine if seeking initial ACCME accreditation is an advantageous move.

In January, the ACCME put out a call for feedback to the CME community at large, with the intent of using the feedback in their review of the rules related to the protection of the integrity and independence of accredited CME/CE. All respondents were asked for specific recommendations about the Standards for Commercial Support.

Of the 141 responses received, 75% came from accredited CE providers, mostly (65%) ACCME-accredited. This figure, published in the ACCME’s latest report, represents the types of organizations that responded to the call for feedback:

The responses received are listed verbatim in the published report and reflect opinions from across the spectrum or respondents. One respondent stated that an existing challenge to Standard 1 is that “it is becoming increasingly challenging to determine whether the new types of organizations meet the definition of a commercial interest” while other respondents cited challenges in defining organizations as commercial interests when they “relate to health technology companies (e.g. wearables, artificial intelligence) as well as digital platforms”. Multiple respondents indicated frustration at not being able to use employees of commercial interests as faculty members as they are often the “experts who are doing the most current research”.

All responses to the challenges and recommendations sections can be viewed online here.

This call for feedback was just one of many steps being taken by the ACCME and the Task Force on Protecting the Integrity of Accredited CE as they continue to engage in dialogue with stakeholders with the purpose of issuing a revised version of the Standards of Commercial Support early next year.

Recently, the ACPE collaborated with the National Association of Boards of Pharmacy (NABP) to help pharmacists more easily monitor their CPE compliance. Together, the groups developed “CPE Monitor Plus”, which is a subscription service that allows pharmacists to go beyond the basic CPE Monitor functions and do the following:

• Receive email alerts when CPE deadlines are coming up
• Search for ACPE CE activities listed on ACPE P.L.A.N. (Pharmacists’ Learning Assistance Network)
• View CPE credit status by state to quickly verify license renewal requirements
• Upload certificates from non-ACPE CPE courses and apply them to relevant state licenses
• View all transcripts and individual courses and generate simplified, automated reports
• Connect to “My CPD”, which assists all learners in the achievement of their career goals

This additional service, CPE Monitor Plus, is available to pharmacists for an annual fee of $29.95, no matter how many licenses a pharmacist has or adds. CPE Monitor Plus can be purchased through NABP’s new mobile app, via the NABP e-Profile in Google Play Store (Android) or the App Store (iPhone).

Read more about the latest ACPE updates in their most recent CPE Provider Update.