If the mere words “commercial independence” sends shivers down your spine, you aren’t alone. A call for feedback by the ACCME recently produced more than 140 responses, which revealed the concern many CME directors feel about the challenges of commercial standards compliance.
In this post, we will help you lay any doubts to rest about your organization’s ability to achieve and maintain commercial independence with 5 proven tips that are painless and simple to follow.
The Commercial Independence Documentation Checklist: Can You Pass Our Quiz?
Documenting commercial independence can be a daunting challenge, but since it is also an unavoidable one, you should be pleased (yes, pleased!) to learn that it can also be a painless task. Before we show you how to remove the fear factor from ACCME commercial standards compliance (it’s possible, we promise!), let’s take a short quiz to determine how ready your organization is for PARS-compliant documentation.
1) Do you have a central administrative portal to design, generate, and distribute commercial independence reports throughout your organization?
Solution: An enterprise-grade CME management platform would allow you to generate and share compliance-related reports with a few clicks using elegant, customizable templates.
2) Are you able to automate the email of commercial interest disclosure requests to all CME organization stakeholders so that no staff member or affiliate misses an opportunity for accurate, detailed compliance reporting?
Solution: Use a CME platform that automates critical emails and monitors open rates, allowing you to intervene before potential financial disclosure omissions become ongoing non-compliance issues.
3) Are program staff, educators, and affiliates able to receive a customized suite of forms for proper commercial relationship disclosure via instantly upon hire or affiliation?
Solution: Choose a CME management suite that automates time-consuming administrative tasks, permitting staff to receive and download printable forms and view relevant FAQS or Wikis through the same convenient login.
4) Is there a simple, easy to navigate FAQ available online for CME staff seeking clear information on commercial independence standards along with a report on your organization’s existing financial relationship disclosures?
5) When an instance of financial relationship disclosure non-compliance is discovered, can your organization quickly remedy it in an appropriate manner?
Solution: While the steps in your organization’s compliance enforcement process will be unique to each situation, the need for proper documentation is universal. Keep reporting and notification data in a single, cloud-based data management suite rather than a spreadsheet that is likely to contain errors.
But with a systematic approach to data collection and management it is possible for it to be a frictionless experience.
5 Simple Ways to Transform Your Commercial Independence Documentation Process
1.Know Which Data Matters: Declarations, Verifications, Disclosures, and More
When facing a review of commercial independence compliance procedures (whether self-initiated or from the ACCME or a Recognized Accreditor) it is important not to feel discouraged by what may seem like a virtual ocean of required documents. While the standards themselves may seem like a challenge to interpret and apply, you will find plenty of guidance on the ACCME website and excellent examples and instructional videos to help you and your team work through practical applications.
The biggest barrier to compliance is really on your end—preparing for review by having the right data at the ready. In general, the most important documentation to have available on-demand (for your own team or the ACCME) falls into 3 categories: declarations, verifications, and disclosures. Let’s take a quick look at each of these:
Staff and affiliates with influence upon CME curriculum, design, or development must declare any relevant financial relationships to the CME provider.
According to the ACCME:
“A relevant financial relationship is a financial relationship which may or has benefited the concerned party by any amount, and which occurred in the twelve-month period preceding the time that an individual was asked to assume a role controlling content of the CME activity.”
Document the sending of the request for a declaration through your LMS or your data management suite and use a template to ensure that relevant information is requested of all recipients.
“The provider must be able to show that everyone who is in a position to control the content of an education activity has disclosed all relevant financial relationships with any commercial interest to the provider.“
Stay compliant by using a commercial relationship disclosure template letter and document the distribution of each notice through your learning management system and CME data analytics suite. When disclosures and learner receipt of notifications are documented and can be shared on demand, you will have saved your team hours of work and ensured that the ACCME can quickly view your compliance status.
Commercial relationship independence verifications are essentially a data management issue. Ensure that your data is backed-up in the cloud and secure, even if you are “old school” and have a literal paper trail of documents printed from an email chain. Use a single platform to store evidence of any investigations of financial relationships or correspondence regarding disclosures. View a sample letter here.
2. You Can’t “Wash” Dirty Data— Complete a Historical Data Checkup
This checkup is a quick one. Answer these five questions before moving on.
1) Can you search locate the self-reported financial disclosure documentation for any staff member or affiliate with direct influence on CME programming?
2) Are names, contact info, and correspondence records up-to-date for all affiliates and staff members who create, manage, or distribute CME content?
3) Can you locate detailed records of all commercial support (both in-kind and direct contributions) within minutes?
4) Are you certain that all correspondence regarding financial disclosure compliance and current ACCME standards enforcement were emailed and received in a timely manner?
5) Can you easily identify and remedy any gaps in your compliance record keeping across your entire organization through an admin dashboard?
“Dirty” data is inaccurate or incomplete. Often it is the fault of an entry error into a spreadsheet or a change in status that was not updated. Regardless of the reason, missing data can lead to a non-compliance finding. If your data management practices can’t pass our checkup, then it is likely a document tracking or storage issue that can be easily fixed by switching to a system that allows you to manage your data from a single dashboard.
3. Master Current Standards: Learn How the ACCME Defines Commercial Independence: The Cheat Sheet
While commercial independence challenges will change as your organization grows, it is essential to know how the ACCME defines key terms. Download their official summary here.
4. Commercial Independence 101: Ensuring Organization-Wide Compliance
So how can you ensure that your entire organization is on the same page when it comes to commercial standards compliance and document management? The easiest way is to streamline all organizational communications through a single system that automates notifications, data reporting and submissions, and documents management.
Use one system to eliminate:
- Requests for financial disclosure email chains that can be lost in the inbox;
- Data entry errors in financial disclosure timeline documentation;
- Documentation stored on multiple spreadsheets or sent to duplicate email addresses;
- Staff notifications being sent to spam;
- Manual commercial independence report creation that is time-consuming and often difficult to integrate with digital verification.
5. Select a technology partner that will streamline the compliance documentation process and ACCME document submissions.
EthosCE makes data collection, staff communications, and ACCME documents management frictionless. With EthosCE, the generation of disclosure reports and the documentation of commercial independence is simple and handled through a user-friendly dashboard. EthosCE offers stellar, ongoing support as your organization grows, helping you get the most out of your software by making it simple to tailor your platform use to your program’s requirements. Follow the link to watch EthosCE in action.
EthosCE believes CME technology solutions should be designed to improve healthcare professionals’ user experience, comply with ACCME guidelines, reduce administrative costs, and demonstrate measurable outcomes.
To learn how EthosCE can enhance the continuing education of your medical professionals, request a free 1-on-1 demo with one of our specialists today.