A few weeks ago, the CME Guy served up an interesting post on his blog about “Finding Your CME Community.” In it, he mentioned a situation when he was at a MECC in which he was going through reaccreditation and was wondering if the surveyor could remain unbiased. I realize it’s a dog eat dog CME world out there sometimes, but the idea of competition between CME providers had not been something I encountered before.
I started thinking about this again when I was preparing for a presentation on planning forms for the Alliance for CEHP Annual Meeting- I couldn’t believe how many planning mechanisms are out there (and how many of them look the same) and when I got an email from a state-accredited provider- it reminded me of the days when I used to work with said state-accredited provider and how different things are from the large organizations I’ve encountered.
I’ve always been a strong advocate for the state-accredited providers- many of whom aren’t afforded the same CME luxuries as the rest of us- those who wear multiple hats (credentialing coordinator, medical staff coordinator, medical librarian AND CME coordinator), who see what big medical center is doing and get overwhelmed by the fact that they don’t have the resources to do it. Or the big medical specialty society who talk like everyone has a CME staff of 12.
The bottom line is that for the most part, we all want to provide excellent CME to improve patient care, but how we do it is vastly different (but not necessarily wrong). So this week when some of us meet new peers and friends, remember that they may not be doing the same things as you but may have a really cool thing that they ARE doing well. For those of us who are unable to go, keep in touch (and reach out to people) through Twitter with the hashtag #acehp13.
Submitted question: Fact or Fiction: If an event does not receive any commercial support, that must be disclosed in the event brochure.
Answer: Fiction! If you don’t accept commercial support for an activity, there is no requirement that you must disclose the absence.
Although Standard 6.2 under Standard 6 of the Standards for Commercial Support requires the disclosure of no relative financial relationships to the audience, Standard 6.3 only requires the disclosure of support.
A wonderful peer recently posed this question to the blog:
I think there’s still confusion out here about the distinction between how we design an activity and what we’re supposed to be trying to measure (coming out of that individual activity). It’s difficult to measure or demonstrate change in competence as the result of an activity where the learners are from a broad community instead of being on your own staff where you can integrate systems changes and follow outcomes over time for example.
If I understand correctly, it’s fine to design activities primarily to close a knowlege gap, but these activities should be contributing to a program level effort to change competence, performance, or patient outcomes. The closest I come to trying to measure competence from a one-time knowledge based activity is in asking learners to respond to case presentations before and after the information is delivered (trying to show intention to apply the new knowledge), or asking if they intend to change anything about their practice in light of the new information (which doesn’t usualy get me much information).
So my question is, for an individual activity, is it sufficient to measure change in knowlege, i.e., a pre-test/post-test?
WOW. This is a loaded question. Looking at Criterion 3 ”The provider generates activities/educational interventions that are designed to change competence, performance, or patient outcomes as described in its mission statement” and the further clarification on the subject, activities can be designed to change knowledge as long as the overall CME program is designed to change competence, performance or patient outcomes.
Here’s what the ACCME had to say about it in a video with Dr. Kopelow.
Personally, I think there are two issues at play here. One being that you have to plan CME activities to change competence, performance or patient outcomes, but you don’t necessarily have to be successful. There is no rule that you have to bat 1.000 with each and every CME activity.
Also, as a patient, if I go to my doctor and describe XYZ symptoms, I don’t want him/her to say “I know what that is.” I want him/her to say “I know how to treat it” (competence) or “I can treat it” (performance). Or if they need more information on how to treat it, at least it goes beyond knowing what it is (which is why I’m a big fan of internet point-of-care even though it hasn’t caught on yet).
I think we need to get creative when we develop pre/post tests. Case studies are certainly effective in analyzing changes in competence, but we can also ask more questions that are applicable to practice. Instead of asking what something is, we can ask how it would be treated, even having more than one right answer. In addition, having a definitive answer, as opposed to “all of the above” or “none of the above” can help us identify additional practice gaps. Self-reported changes are perfectly acceptable, and can also help us gather some great new information!
Physicians hopefully will learn something new from a CME activity. What they do with that information is what we should be trying to analyze…self-reported or otherwise.
My friend The CME Guy recently posted this question on Facebook:
“A program director wants to do away with charging exhibit fees. Instead, he wants to implement a tiered commercial support structure where an exhibit table is included with higher levels of support (Platinum, Gold), but not with lower levels (Silver, Bronze). Is that OK to do?”
Not in the least.
Granted, this is a bit confusing because the ACCME DOES allow for levels of support, but under SCS 4.1, exhibits and advertising can not be a condition of commercial support (there’s actually an FAQ about this). As The CME Guy pointed out, his question wasn’t specific to the written agreement, but an agreement is an agreement. If you allow exhibits to be a part of the package for commercial support, then that would be considered non-compliance.
Exhibits and advertising are separate from commercial support, period. That’s not to say that the funds for the commercial support and exhibit can’t come in the same check, but one can’t be a condition of the other. You can’t force a commercial supporter to exhibit, and you can’t force an exhibitor to provide commercial support. Under the example above, it could be seen that the provider is strong arming the commercial interest into a higher level in order to exhibit.
As I’ve mentioned on a number of occasions, the Standards for Commercial Support Are Not So Standard.
As always, contact the ACCME with questions.
Oh wow! This is such a great question- thank you for submitting it.
Quick answer- NO. Not all programs have to give credit. Say, for example, you have a great educational program that would benefit your learners, but does not fit the definition of CME (what immediately comes to mind is discussing mission work), then do it…just don’t give credit.
Or if your faculty (not employees of a commercial interest) have been a part of the research of a product or device and want to talk about it…do it, just don’t give credit.
Credit doesn’t have to be an all or nothing, either. You can give partial credit to an educational activity- you can include sessions like those above but just not give credit for those sessions (perhaps as an early morning or lunch session).
Your education is what you make it!
I’ve seen (and heard) that providers assume if they joint- or co- sponsor an educational activity with another provider, they meet the requirements for Criterion 20. I’ve even seen “co-sponsorship” as an exchange of organizational logos without any real collaboration.
While it’s great that CME providers are working with other CME providers, rubber-stamping a CME activity for credit is NOT building “bridges with other stakeholders through collaboration and cooperation.” Thankfully the ACCME provided clarification on this within their note on the Criterion, but as providers, we should ask ourselves how we can work meaningfully with other providers to improve the education for the learners, and consider that throughout the planning process. We should also look beyond CME providers alone, and collaborate with other professional healthcare associations.
Admittedly, this is one of the easiest ways to demonstrate compliance with Criterion 3, but there is no requirement to have learning objectives.
One thing to consider- you still must show how your activities are designed to change competence, performance or patient outcomes, and learning objectives are just part of that process. When creating learning objectives, think about how the learner will actually change their practice (is it attainable? is it reasonable? is it measurable? is it even plausible- such as training physicians to treat the zombie apocalypse?). How will the activity close the professional practice gap?
As always, look at the ACCME’s compendium of case examples, not just for areas of compliance, but for areas of non-compliance.
(Not a rumor, just an FYI)
For July 2013 Cohorts and later, the ACCME is now requiring that the provider describe in the self-study if/how employees of a commercial interest participate in CME activities.
It’s on page 2- start preparing.
Thanks to Sue Pelletier for this one!
The first thing I have to say is OUCH. That ouch is for when the binder inevitably drops on my toe due to gravity and 20 lbs of paper.
When you’re getting your stuff together, think like a surveyor. Would YOU want to read through 400 pages of words to find how you address practice gaps, how you identify and resolve COI, and how you analyze your overall program (to name a few)? Your CME program may be doing some amazing education, but when you tell your story, be concise. Be direct. Tell what you’re doing, not a Beowulf-length epic novel.
Tell your story, and then back it up with your evidence. If your evidence is on one page of your planning form, there is no need to include your entire planning form (as an example). If you have a policy attached to your disclosure form, just include the signed disclosure part.
Same thing goes for your activity files- include what you need for the labels- there is no duplication. More doesn’t necessarily mean better.
Take your time, and if you need help- ask the ACCME, go to one of their workshops, or if you need it, hire someone!
The SCS strike again! This question keeps coming up over and over- either through written comments or hallway discussions like at the 23rd Annual Conference of the National Task Force on CME Provider/Industry Collaboration meeting (some of us only made it to the hallway). Unlike that meeting, the space and place issue is often a back and forth between providers and industry.
The ACCME provided some guidance about space or place related to SCS 4.2, and more in the compendium about what I can only assume were poster abstracts (but I could be wrong).
My understanding- educational space = no promotion. Anywhere outside of that = promotion. Sounds very simple, but there’s no “50 feet from entrance” rule.
I think as CME providers, there’s the tacky aspect and the non-compliance aspect. It’s up to us to decide how high we want to set the bar.