ACCME: Changes to Complaint Process, Knowledge Based CME, and New Call for Comment

 The Accreditation Council of Continuing Medical Education (ACCME) announced a number of important topics in their recent August newsletter, including an executive summary of its Board of Directors meeting, a summary of ACCME revisions to the Complaints Process, and an explanation of ACCME affirming knowledge-based activities in CME.

The ACCME Board of Directors meeting, which was held July 15 – 16, 2010 at its Chicago offices, accomplished a number of important tasks, as the executive summary reflects.

Key changes include:

· Update to the ACCME complaint process;

· Re-enforcement that knowledge based information is acceptable content for CME activities;

· New call for comment on responsibility to learners on activities found not in compliance with ACCME standards; and

· Opening of its live online program and activity and reporting system (PARS) .

Accreditation Review

With respect to accreditation and recognition, ACCME ratified 56 Accreditation and Reaccreditation decisions based on the 2006 Accreditation Criteria, which included:

   14 providers (25%) that received Accreditation with Commendation, which confers a six-year term of accreditation;


   Thirty-one providers (56%) received Accreditation;


   Two providers (4%) were placed on Probation;


   Seven initial applicants received Provisional Accreditation;


   Two initial applicants received Non-Accreditation; and


   The Board ratified Progress Report decisions for 65 providers, of which, 50 progress reports were accepted and 15 were rejected

ACCME made its first Recognition decision based on the Markers of Equivalency, which they adopted in 2008 through a collaborative process with Recognized Accreditors. ACCME explained that “the Markers of Equivalency help ensure that accreditation decisions are consistent at the state and national levels.” The summary also noted that presently, there are a total of 700 ACCME-accredited providers and 1,496 providers accredited by ACCME Recognized Accreditors (state or territory medical societies that accredit local organizations offering CME).


Call for Comment Actions

Moving along, the Board announced actions on call for comment they issued back in January, regarding Knowledge-based CME Activities and the Complaints and Inquiries Process: Balancing Transparency and Confidentiality.

Revised Complaint Process

With respect to the Complaints Process, the Board approved a revised ACCME Process for Handling Complaints Regarding ACCME Accredited Providers, which includes:

   Keeping confidential the identity of providers that have an activity found in Noncompliance;

   Making public the provider’s accreditation status if it is changed as a result of the process; and

   Posting the revised process, blinded summaries of complaints for educational purposes, and other resources for accredited providers in the near future.

The newly adopted complaint policy sets forth that the statute of limitation of the length of time during which an accredited Provider must be accountable for any Complaint received by the ACCME is twelve (12) months from the date a live activity ended, or in the case of a series, twelve months from the date of the session which is in question. In addition, providers are accountable for an Enduring Material during the period of time it is being offered for CME, and twelve (12) months thereafter. A Complaint may a) refer to single activities/series, or b) the Provider’s entire program of CME. A Complaint can also be initiated by the ACCME.

The procedure for the complaint process gives the provider (45) days from the date of receipt of the Notice of Complaint to respond and either admit the allegations of the Complaint or provide a written rebuttal and any information requested by ACCME. Failure to submit a response in this time may result in a finding of non-compliance. In addition, if a provider is found to be in non-compliance ACCME may:

   Require the Provider to submit documentation of corrective action within thirty (30) days of receipt of the Notice of Non-Compliance;

   Require the Provider to submit a Monitoring Progress Report at a time determined by the ACCME;

   Require an immediate full or focused accreditation survey, including a full or focused self-study report and interview at any point in the Complaint process;

   Change the Provider’s accreditation status to Probation or Non-Accreditation; and

   Change the Provider’s accreditation status to Probation or Non-Accreditation

These changes show the ACCME’s commitment to ensure due process for all parties involved in the complaint.


New Call for Comment on Responsibility to Learners on Activities Found not in Compliance

ACCME also issued a call for comment in accordance with its Rule-Making Policy about whether providers should have obligations to learners if an activity is found Noncompliant during the complaints process. Murray Kopelow, MD, ACCME Chief Executive, has recorded an audio commentary about the call for comment.

ACCME asked stakeholders to read the call for comment and send them feedback by September 27, 2010: Complaints Process: Providers’ Responsibilities to Learners.

Consequently, the Board continued its discussions regarding providers’ obligations to provide corrective information to learners, planners and faculty if an activity is found to be Noncompliant with Standard for Commercial Support 1 (Independence), Standard for Commercial Support 5 (Content and Format without Commercial Bias), or the Content Validation Value Statements. The ACCME announced that it will release a call for comment to seek input about this issue from accredited providers, other stakeholders and the public.  

Knowledge Based CME Activities

In discussing knowledge-based CME activities, the Board reviewed the feedback received during the call for comment and preliminary input from its Accreditation Requirements Task Force. The Board affirmed its position that knowledge-based CME activities are acceptable in accredited CME. They also noted that having completed the review of six (6) cohorts of providers under the 2006 Criteria, ACCME is now conducting a comprehensive review of the accreditation requirements and as a result, are seeking feedback from the CME community. Accordingly, ACCME announced that it will wait until this review is completed to take final action on the wording of the Criteria.

Regardless, the Board affirmed that “knowledge” is acceptable content for accredited CME. Additionally, with respect to Criteria 3 and 11, the Board asserted that even if the preponderance of a provider’s activities is focused solely on changing knowledge, the provider must still show how these activities contribute to the overall program’s efforts to change learners’ competence, or performance or patient outcomes.

This confirms the value of the dissemination of new science including basic science in CME activities.

Program & Activity Reporting System (PARS) Opens for Live Data Entry

ACCME announced that since opening the Program & Activity Reporting System (PARS) for live data entry on July 22, staff from 117 accredited organizations has accessed PARS, which is designed to streamline and support the collection of program and activity data from ACCME-accredited CME providers. The ACCME has also issued a joint news release about the PARS launch with MedBiquitous.

Accredited CME providers can login to PARS from the PARS Information Page or by visiting the ACCME Web site homepage and clicking on the Accredited Provider Login or the Program & Reporting System (PARS) link in the “For CME Providers” menu on the left hand side of the screen. ACCME encouraged that providers begin using PARS as soon as possible, to become familiar with it and to begin answering any questions or concerns. They asked that all activity data for 2010 be entered by March 31, 2011, to allow for the calculation of the ACCME 2010 Annual Report Data.

Working with the Joint Commission

In addition to their accreditation and recognition work, ACCME also heard from member organizations and accreditors, which included Paul M. Schyve, MD, Senior Vice President of The Joint Commission. Dr. Schyve discussed with the board ways continuing medical education (CME) can support The Joint Commission in meeting its mission and the missions of the hospitals and health systems it accredits. Dr. Schyve explained The Joint Commission’s quality and safety improvement initiatives and the role CME can play in achieving those goals. In response, the Board expressed its appreciation for the valuable dialogue.

ACCME Joins the AOA House of Delegates

It was also noted that the Board accepted an invitation from the American Osteopathic Association for the ACCME to join its House of Delegates, which will help expand an already cooperative relationship.


ACCME to Assist AMA in Monitoring PRA

The Board also discussed an initial proposal regarding ways that ACCME can assist the American Medical Association (AMA) in monitoring providers’ compliance with AMA Physician Recognition Award (PRA) requirements during the accreditation review process and established a Board task force to explore implementing the proposal.


Team Accreditation

Next, the Board announced that it had ratified accreditation decisions for two providers under the “Accreditation of Continuing Education Planned by the Team for the Team.” This program was started in March 2009 by ACCME, the Accreditation Council for Pharmacy Education and the American Nurses Credentialing Center Accreditation Program. ACPE and ANCC also ratified the same decisions.


This month’s newsletter also discussed how ACCME gave a presentation to an Advisory Committee of the Food and Drug Administration’s Center for Drug Evaluation and Research during a meeting on Risk Evaluation and Mitigation Strategies (REMS) for extended-release and long-acting opioid analgesics. Murray Kopelow, MD, ACCME Chief Executive, who gave the presentation, explained how accredited CME could be a strategic asset to REMS initiatives. He also added that CME can have a demonstrable impact on improving physician expertise and patient safety in this area.”


Ultimately, as the numerous activities and initiatives listed above show, it is clear that the ACCME is leading the way in providing opportunities for CME providers to continue offering high quality programs that help close gaps in care across the country, while keeping physicians and other health care providers up to date on the most recent breakthroughs and innovation in medicine and technology. 

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