AOE Compliance Connection – March 2022 Newsletter

Welcome to the March edition of AOE Compliance Connection, AOE’s monthly newsletter. In this month’s newsletter, we continue our series called “Did You Know?” featuring some helpful FAQs about Standard 2 from the Standards for Integrity and Independence in Accredited Continuing Education. Additionally, we offer some tips about wrapping up Annual Reporting later this month for ACCME and ANCC. We also give you a sneak peek of AOE’s involvement at ACCME’s Annual Meeting in April (hint: we’ll be presenting!). Finally, we unpack how AOE can help you work through a progress report or probation period! Follow our weekly compliance tips on Twitter and Facebook or email us at inquire@aoeconsulting.com with any questions. We look forward to supporting you and your CE team!

This month, we near the end of our series featuring some of the ACCME’s most helpful FAQs. Some of the most helpful information on the ACCME website is tucked into the FAQ section and we’ve been hard at work uncovering some gems of wisdom specific to the new Standards.

We began with questions related to stock ownership and patent holders, continued with a few questions related to the collection of disclosures and the mitigation of relevant financial relationships, added on last month with three questions targeted to Standard 5 regarding the new requirement of 30-minutes between accredited and non-accredited educational sessions in the same educational space. This month we’ll continue with a look at some FAQs surrounding Standard 2 including learner consent and advertising boundaries.

1) What is meant by “explicit consent of the learner”?

This language just means that before you share learner contact information with an ineligible company, the learners must consent. As an accredited provider, the responsibility is yours to communicate this clearly. Some providers do this at registrations, but the learner must have an opportunity to “opt out” of that communication and still attend the activity. Consent statements must be clearly visible (and not hidden in a long list of text).

2) Does an accredited provider have to give a list of its participants to its commercial supporters?

No – this is not a requirement. If a provider decides to do this, however, they must obtain “explicit consent of the learner” (as detailed in the previous question).

3) Can we include advertising in a printed or digital handout that contains abstracts if we don’t provide CME credit for the abstracts?

The answer to this depends on the nature of the printed or digital handout. Consider: What is the handout used for in relation to the accredited CE activity? If the abstracts are used as a portion of the accredited CE activity or are referenced during that activity as part of the content, then the answer is “no” – there can be no advertising in that handout. However, if the abstracts do not fill this role, and simply appear in the handout with what the ACCME calls “logistical” information about the activity, then advertising is allowed.

4) Where CAN advertising for ineligible companies appear related to educational events?

The short answer:  Nowhere together. The separation of education from all promotional activities is required by the ACCME. This applies to all materials and messages. Any text-based document that goes along with the activity (and provides supplementary information) must be free of all advertising, logos, trade names, etc., that is from ineligible companies.

Annual Reporting Reminder:

The ACCME’s deadline for 2021 year-end reporting is fast approaching: March 31, 2022. As in previous years, data gathered between January 1, 2021 and December 31, 2021 should be entered into the ACCME’s Program and Activity Reporting System (PARS). State-accredited providers should check with their specific accreditor for reporting requirements and deadlines.

A full tutorial for annual reporting, in addition to many other helpful PARS resources, can be found here. Please note, the ACCME recently updated PARS so ensure you allow time to familiarize yourself with the updated platform.

Annual reporting is completed via the ANCC Nursing Activity and Reporting System (NARS) and will be due April 1, 2022. All ANCC Accredited Providers are required to submit an annual report to the ANCC inclusive of activity data from January 1, 2021, through December 31, 2021. To access ANCC Annual Reporting Requirements, click here (ANCC notes that there are no major changes from last year’s requirements). Additionally, an FAQ page that includes NARS topics can be found here.

In just a few weeks, the ACCME Annual Meeting will take place in Chicago (April 25-28). This year’s theme, Learn to Thrive reflects the goal of this meeting: to address the challenges and opportunities surrounding the CE community and to “ascend through action, reflection, and continuous growth”. As always, these annual meetings are designed to facilitate networking within the CE community, to acknowledge professional achievements, and to look together towards the future.

This year’s meeting will feature three keynotes, two plenary sessions, four Inspire & Teach sessions, homeroom sessions, a public health forum, a welcome reception, a research exchange with a “Meet the Researchers” reception, breakfast and lunch each day, access to the ACCME 2022 Meeting app, and the option to participate in ACCME Working Groups (for an additional fee). In-person (register here) and virtual (register here) educational opportunities are available, as well.

AOE staff will be participating in the larger CE conversation by presenting in multiple forums. Here’s the scoop on where to find us at the ACCME Annual Meeting in April:

• AOE Director of Operations, Carlye Armstrong, CHCP and AOE Program Manager, Renea Marin, CHCP will present Wednesday, April 27 from 10 – 11:15 am CDT. Their in-person presentation, Best Practices in Management of a Hybrid Meeting, will include case examples and lessons learned from this new frontier of hybrid learning. This format offers both new opportunities and new challenges but is most likely here to stay! Organizations would do well to embrace it and learn to manage it well.

• Armstrong will also be presenting virtually in collaboration with Global Education’s Vice President of Education, Andrea Funk, on Thursday April 28, 8:30 – 9:30 am CDT. Their presentation, Better Together: The Top 5 Best-Practices for Working in Joint Providership, will unpack the nuts, bolts, and strategies that go into creating quality educational experiences with an educational partner. This session is for those who are considering joint providership but need some guidance on where to begin and/or how to effectively manage such partnerships.

• Finally, AOE Program Manager Renea Marin, CHCP will co-present virtually with Charles R. Drew University of Medicine and Science’s (CDU) Ronald Edelstein, EdD, Senior Associate Dean, Academic Affairs, Thursday, April 28, 8:30 – 9:30 am CDT. Their presentation, Focusing on Inclusion and Leading to Great Change, will feature CDU’s strategy of addressing healthcare disparities through educational initiatives. CDU’s longitudinal approach to integrate partners from various internal departments and external partners from South Los Angeles County has resulted in their regularly scheduled series entitled “Friday Noon Lecture Series”.