Welcome to the November edition of AOE Compliance Connection, AOE’s monthly newsletter. This month’s newsletter features a “Special Edition” of our traditional board updates as we focus on the ACCME’s new commendation criteria. Also included, news regarding PPSA and more news about ACCME and MOC registration. There’s a lot happening in the world of CME!
This monthly publication is just one of the many ways we support our clients as they navigate CME/CE compliance success. We encourage you to visit www.aoeconsulting.com for more information, including a library of guidelines and weekly compliance tips!
Accreditation Board Bulletin: Special Edition
Accreditation Board Bulletin: Special Edition
ACCME: New Commendation Criteria Overview In late September, the ACCME released 16 new commendation criteria divided into five categories. In order to achieve compliance with the new criteria, providers must demonstrate compliance with at least seven criteria from any category plus one criterion from the Achieves Outcome category for a total of eight criteria.
Let’s take a look at each of the five categories and corresponding criteria:
1. Promotes Team-Based Education (C23-25)
The Promotes Team-Based Education category centers on collaboration in the medical profession, a key principle which is also reflected in CME team-based education. Criterion 23 is directed at involving interprofessional colleagues not just on the CME planning committee, but also in the delivery of the education. Consider the target audience and ensure inclusion of interprofessional colleagues not only in teaching the subject matter, but also in the planning of the education. The basis of Criterion 24 is acknowledgement that the goal of CME is to improve the well-being of the patients and the public. A powerful way to create engagement is to involve patients and the public in the teaching of physicians and interprofessional colleagues, which could include planning committee interaction, but also providing context during education delivery. Similarly, Criterion 25 encourages the involvement of students in CME planning and delivery. Students can be informative and invaluable in constructing educational programs, particularly for younger generations of learners.
2. Addresses Public Health Priorities (C26-28)
The Addresses Public Health Priorities category puts a focus on those who have the opportunity to use their CME programs to leverage improvements in public health. An organization can achieve Criterion 26 by using EMR (electronic medical record) data or registry information to understand and improve individual or group practices. Criterion 27 addresses factors beyond clinical care such as changing the public health or community environment, or creating implementation plans to support patient engagement. The ACCME cited an example of creating an implementation plan that encourages patients to participate in healthy lifestyle behaviors. Criterion 28 is all about collaboration. Creating meaningful collaborations with other organizations, such as public health societies or departments, using CME to help the community evolve.
3. Enhances Skills (C29-32)
The Enhances Skills category is focused on supplementary education and tools to support learners. Criterion 29 requires providers to develop CME that improves communication skills and provide observation, evaluation, and formative feedback to learners. Similarly, Criterion 30 requires providers to deliver CME addressing technical and/or procedural skills while once again building in observation, evaluation, and formative feedback. Criterion 31 is focused on individualized learning plans that allow learners to slow or accelerate their learning over a period of time. Finally, Criterion 32 is a reworking of the current Criterion 17 (C17) that requires providers to utilize support strategies to enhance change and analyze the effectiveness of such support strategies.
4. Demonstrates Educational Leadership (C33-35)
This category is best summarized as advancing CME. To be compliant with Criterion 33, a provider must be engaged in scholarly pursuits relevant to CME which includes submitting, presenting, or publishing a poster, abstract, or manuscript to, or in, a peer-reviewed forum. Criterion 34 could be described as a CME program within a CME program as this criterion requires providers to create and implement a professional development plan for the CME team that is based on documented needs. Finally, Criterion 35 compliance requires providers to submit four examples of an innovation in the CME program that improves the provider’s ability to meet its mission.
5. Achieves Outcomes (C36-38)
All providers must demonstrate compliance with at least one criterion in the Achieves Outcomes category. The criteria in this category are all about data and, more specifically, improvements in data. While Criterion 36 is focused on data that demonstrates improvements in learners’ performance, Criterion 37 is focused on demonstrated improvements in healthcare quality, and Criterion 38 is concerned with improvements in patient or community outcomes.
Lastly, please note that providers in the November 2017 – November 2019 cohorts may choose between existing commendation criteria (C16 – C22) or the new commendation criteria (C23 – C38). After November 2019, providers must use the new criteria (C23-C38).
PPSA Pulse: Language Clarification
Recently, the Center for Medicaid and Medicare (CMS) provided language clarification on the final ruling for transfers of value reporting requirements at accredited CME activities in the Physician Payment Sunshine Act. Since August 2013, when the final ruling went into effect, this has been a constant source of confusion for CME stakeholders. CMS revised FAQ #8165 and clarified the reporting requirements for most transfers of value at accredited CME activities. This excerpt from the full text explains that:
As explained in the Calendar Year 2015 Physician Fee Schedule Final Rule, when an applicable manufacturer or GPO provides funding to a continuing education provider, but does not: (1) select or pay the covered recipient speaker directly, or (2) provide the continuing education provider with a distinct, identifiable set of covered recipients to be considered as speakers for the continuing education program, CMS will consider those payments to be excluded from reporting under § 403.904(i)(1) [revised as § 403.904(h)(i)]. This approach is consistent with our discussion in the preamble to the final rule, where we explained that if an applicable manufacturer conveys ”full discretion” to the continuing education provider, those payments are outside the scope of the rule (79 Fed. Reg. 67759).
This effectively removes the reporting requirements for transfer of value at accredited CME activities, and should ease the burden of reporting for most CME events.
CME for MOC in the Spotlight: ABA and ABP Update
Earlier this year, the ACCME announced new partnerships with the American Board of Anesthesiology (ABA) and the American Board of Pediatrics (ABP).
Last week, the ACCME announced that registration is open to CME accredited providers who want to register their activities for the ABA Maintenance of Certification in Anesthesiology Program® MOCA 2.0® Part 2 (Lifelong Learning and Self-Assessment) and the ABP Lifelong Learning and Self-Assessment for MOC Part 2. Activities are eligible for registration only if they meet the requirements of the ABA or ABP.
Previously, the ACCME partnered with the American Board of Internal Medicine (ABIM) for MOC credit, but has expressed interest in expanding the collaboration to other boards, like the ABA and ABP. With these collaborations, CME providers are able to expand the number and diversity of accredited CME activities that count for MOC.
For more information, join the webinar on November 16th at 2:30 pm (Central).
Upcoming Activities/Education Opportunities
- Webinar: CME that Counts for ABA MOCA 2.0 and ABP MOC
November 16, 2016
Read More >> - MAACME 6th Annual Conference
November 17, 2016, Allentown, PA
Read More >> - CMSS Patient Reported Outcomes Conference
November 17, 2016, Washington DC
Read More >> - Global CME Impact Award Deadline EXTENDED
November 18, 2016
Read More >> - 42nd Annual Alliance for Continuing Education in the Health Professions
January 26-29, 2017, San Francisco, CA
Read More >> - ACCME 2017 Meeting: Evolution, Innovation, and Alignment
April 24-27, 2017, Chicago, IL
Read More >>
