Welcome to the October ‘19 edition of AOE Compliance Connection, AOE’s monthly newsletter. This month, we launch into a new series focused on ACCME Accreditation with Commendation – each month, we’ll feature one of the five commendation categories and the related criteria. Also, in this month’s newsletter, we share a Board of Directors announcement from the ACCME, and updates from the three major accreditation boards, ACCME, ACPE and ANCC. Follow us on Twitter and Facebook for our weekly compliance tip and other timely updates!
New Menu for Accreditation with Commendation: Category #1 – Promotes Team-Based Education
Over the next several months, we’re going to take a deep-dive into each of the five categories that comprise the New Menu of Criteria to obtain Accreditation with Commendation.
This month we’ll begin with Category #1: Promotes Team-Based Education which includes C23, C24 and C25. This category centers on collaboration in the medical profession, a key principle in team-based education.
From the outset, the common denominator across all three criteria in this category is that a provider must attest to meeting the criterion with at least 10% of activities (but no less than two) during the accreditation term and provide evidence of specific examples based on program size (Small: 2; Medium: 4; Large: 6; Extra-Large: 8).
Criterion 23: Members of interprofessional teams are engaged in the planning and delivery of interprofessional continuing education (IPCE).
IPCE is planned by the team for the team. IPCE is not just about designing education for physicians primarily and including nurses, pharmacists and/or other healthcare professionals when applicable, but is truly about approaching education from a team-based view. It’s important to note that the ACCME’s definition of interprofessional is different learner types – physicians, registered nurses, nurse practitioners, pharmacists etc. and not different physician types such as cardiologist, oncologist, internist, etc. IPCE is different than multidisciplinary education.
The professional practice gap(s) and corresponding educational need(s) for IPCE activities should be measured from the standpoint of a healthcare team consisting of two or more professions. To demonstrate compliance with this criterion, a provider must have planners and faculty who are members of the interprofessional target audience. In other words, if physicians and nurses are the target audience, they should be represented as activity planners and presenters.
Criterion 24: Patient/public representatives are engaged in the planning and delivery of CME.
Compliance with this criterion requires a CME provider to improve the well-being of the patients and the public with the accredited CME activities being developed. Patients and the public are often some of the best informants when it comes to validating professional practice gaps and educational needs among healthcare professionals engaging them in teaching can be both powerful and impactful. Examples could include a patient panel with Q&A and/or a presenter who is a patient and/or public representative. As with C23, for C24 patients and/or public representatives must be represented as both planners and faculty. The ACCME permits broad latitude for defining “planner” and “faculty.” Examples could include: planning committee, expert advisor, presenter, panelist and/or participant for a case-based discussion. One last note: CME providers should be mindful that patients, family members and public representatives must provide disclosure as their involvement places them in a position to control the content of an accredited CME activity.
Criterion 25: Students of the health professions are engaged in the planning and delivery of CME.
This criterion refers to residents or fellows who are physicians, students in nursing school, etc. These individuals are frequently very informative and can help accredited providers construct needed education given they have a unique perspective and fresh input. Plus, they’re the future of healthcare! Once again, as with C23 and C24, to achieve compliance with C25, a provider must include students of the health professions as both planners and faculty.
The ACCME does clarify that students of the health professions is broader than just medical students or residents and includes medicine, nursing, pharmacy, physician assistants and others across the continuum of healthcare education and graduate education.
The ACCME has a number of resources available on their website including FAQs and Examples of Compliance.
If you are interested in training and/or strategic planning as related to the New Menu of Criteria for Accreditation with Commendation, please contact AOE Consulting at inquire@aoeconsulting.com.
ACCME: Vacancy for Public Member of the Board of Directors
Last month, the ACCME announced that it is now seeking nominees for individuals who are interested in serving as a public director on its Board of Directors (which consists of 20 members).
The Board of Directors is comprised of two public directors (one of which has the announced vacancy), two nominees from each of the ACCME’s seven member organizations, two directors affiliated with ACCME Recognized Accreditors, and two non-voting representatives from the government.
The available role of Public Director/Member features the same rights and responsibilities as the other directors, and is a full voting member of the Board. The ACCME expects that this role will monitor all Board and committee discussions to facilitate the identification of potential conflicts of interest that might arise.
Details about eligibility can be found in this post containing the ACCME announcement; the deadline for nominations is May 1, 2020.
Accreditation Board Bulletin
Part of the service that AOE provides to readers are weekly compliance tips and monthly CME/CE community news for ACCME, ANCC and ACPE.
ACCME
Many CME programs solicit commercial promotion in conjunction with their educational activities. Whether or not your organization is on this list, there are a few things to keep in mind when it comes to commercial promotion and educational activities.
In order to remain compliant with Criterion 9, Standard for Commercial Support 4, consider the following three items:
- If an exhibit hall will be present during the activity, it must be separated from the accredited CME activity. This means that exhibitors and vendors cannot be in the same space or room and they cannot be in competition with the accredited CME activity.
- The accredited CME space must remain free of any promotion or advertisement of any kind. Commercial interest representatives are prohibited from administering any kind or form of promotion in the educational space. This includes displaying and/or distributing promotional materials immediately before, during or after the educational activity. Further, speakers should not utilize logos or trade names of commercial interests within their presentations.
- It is important to remember that promotion occurs in many forms, not just via face-to-face interaction but also through print, online, audio/video and journal-based CME as well. Many providers print program books or utilize mobile apps to communicate the required CME elements and possibly some advertising. It is important to remember that the CME materials must remain separate from promotion.
In a nutshell, whenever there is promotion present in conjunction with an accredited CME activity, it must be clearly separated from the education being provided. You should not be able to see or hear both at the same time, whether in the live setting, print, online or any other format accredited.
ANCC
Often, continuing nursing education (CNE) providers solicit and secure funding and/or in-kind donations from commercial interest organizations to support an educational activity. The ANCC has adopted the ACCME’s Standards for Commercial Support, so when this occurs, the provider must ensure that two strict fundamental principles are upheld; 1) commercial support must not influence any aspect of the activity including planning, development, content, implementation or evaluation; and 2) any receipt of commercial support must be disclosed to learners prior to their engagement in the activity. If the commercial support is in-kind, the nature of the support must be included in the disclosure to learners.
In order to ensure the two stated principles are followed, the provider must follow additional requirements upon acceptance of commercial support:
- A written agreement, signed by both the commercial interest organization and the accredited provider, must be in fully executed prior to launch of the activity to outline the terms of the relationship (roles and responsibilities of the accredited provider and the commercial interest organization) and the support that will be provided. The following two requirements are also to be identified within the written agreement.
- Commercial support funding may only be used to support expenses directly related to the educational activity and any payments made must be paid directly by the provider. The provider is responsible for tracking the use of the commercial support funds and maintaining an accounting of expenses related to the commercial support.
- A commercial interest organization may not work as a joint provider for educational activities.
Regardless of whether the commercial support received is in-kind or monetary, the accredited provider must ensure to follow the above principles and requirements. The lead nurse planner as head of the provider unit, is in charge of guaranteeing these aspects are followed to ensure activity and content integrity.
ACPE
Awarding partial credit continues to be a topic that causes many providers a degree of confusion. How do we know when it is allowed and when it is not allowed?
Considering partial credit for a CPE activity isn’t necessary for ACPE-accredited providers. In Section V of the ACPE’s Policies and Procedures Manual, policy 5.0c explains that providers may not offer partial credit for CPE activities. Instead, the learner receives full credit for completing the activity successfully, and no credit for non-completion.
In the situation of a conference, or a multi-activity event, this requires a slightly different approach. To ensure that learners receive credit for each session attended, if they are unable to attend all sessions associated with the conference, each individual session must be registered as an individual activity, complete with its own Universal Activity Number (UAN) and supporting documentation. The ACPE has developed upload software for those circumstances when many UANs are requested at the same time.
Upcoming Activities/Education Opportunities
- Advanced CME for MOC: Ask Your Questions Webinar
November 19, 2019, Online
Read More >> - CPE Accreditation Commission Meeting
November 19-21, 2019, Chicago, IL
Read More >> - 2019 MAACME 9th Annual Conference
November 20-21, 2019, Harrisburg, PA
Read More >> - Alliance 2020 Annual Conference (ACEHP)
January 8-11, 2020, San Francisco, CA
Read More >> - ANCC Annual Symposium on CNE
April 24, 2020, Orlando, FL
Read More >> - ACCME 2020 Meeting: Driving Change: Map Your Route to Educational Leadership
May 6-8, 2020, Chicago, IL
Read More >> - ANCC Pathway to Excellence Conference
May 13-15, 2020, West Palm Beach, FL
Read More >>