Although ACCME accreditation requirements change infrequently, the challenges to maintaining compliance become more complex as your program grows and diversifies its audience. In this e-guide, we’ll first examine five key areas which represent the most significant obstacles to achieving and maintaining ACCME compliance in an increasingly challenging landscape. Next, we will show you how to launch a proactive compliance strategy that helps you align program operations with recent ACCME changes to accreditation criterion and prepares you for potential changes to regulatory mandates.
Like any relationship, the way your organization meets the demands of your professional affiliation with the ACCME will change over time. Irrespective of the speed of your program’s expansion, it is essential to have a standards compliance strategy that incorporates a range of growth scenarios and criterion changes that may impact your ability to maintain accreditation. Before we dive in, take this quick self-assessment quiz:
1. Do I have a plan for ensuring that my organization can maintain accurate learner records if my program experiences sudden, significant growth?
2. Do I have the ability to document our efforts to provide equal access to course materials for learners with content accessibility issues?
3. Can I easily present evidence of my organization’s self-directed commercial independence audits?
4. Is my current content easily adapted to the needs of healthcare professionals with diverse learning styles and limited time?
5. Does my organization have a cloud-based system for gaining insight from real-time and historical data?
6. Can I easily generate a report showing incremental improvements in educational results over time?
7. Is my learning management system intuitive and user-friendly at scale?
8. Are ACCME report submissions automated and derived from verified, clean data?
9. Can I get a 360-degree view of my program’s outcomes over time?
10. Can I easily transform my curriculum to meet the needs of my learners when content proves ineffectual or too challenging to achieve educational benchmarks?
If you answered “No” to any of the above questions, then it is likely that your program will face significant challenges in meeting new accreditation criteria for 2019. Thankfully, you can solve each issue above with a single approach to learning management which we will cover further on.
Now, let’s look at the five biggest challenges to meeting 2019 ACCME criteria and how to overcome them.
1. Staying Up-to-Date on ACCME Criteria Changes
Audit your organization’s compliance strategy and develop a flexible approach to standards compliance.
2. Owning the Accreditation or Reaccreditation Process in 2019
Determine if your accreditation application preparatory process is sufficiently comprehensive and resource conscious.
3. Learning the New ACCME Changes and How to Ensure Organization-Wide Compliance
Do organization stakeholders know how ACCME criterion updates apply to the unique compliance challenges facing your organization?
4. Decoding Commercial Independence and Ensuring Ongoing Compliance
Can you easily explain to your team how commercial independence compliance enforcement should unfold as a process across your organization?
5. Reimagining Your CME Operations to Future-Proof Compliance Strategy
Is your entire staff equipped with user-friendly tools that can eliminate productivity-drain and ensure that compliance-related activities can be monitored for quality and amended easily?
While ACCME accreditation standards have changed over recent years, the core values that underscore ACCME mandates remain the same: ensuring that high-quality healthcare continuing education maintain their integrity and innovative qualities over time. That means your organization must be structurally agile enough to adapt to:
Don’t allow the above list to intimidate you. All of the above are easily accomplished with a single strategy, one that only requires you to focus on a few key areas of knowledge.
First, let’s define our terms (feel free to skip if you are already an ACCME regulatory whiz and don’t need a review).
1. ACCME Recognized-Accreditors: These are state and regional medical organizations designated by the ACCME as recognized accreditors of multi-state CME programs.
2. Accreditation criteria: These are the content, structural, and operational requirements that CME providers must fulfill in order to attain accreditation and maintain it over time.
3. Accreditation status: There are five tiers of accreditation status: Provisional Accreditation, Accreditation, Accreditation with Commendation, Probation, and Non-accreditation.
4. Accreditation interview: CME providers must undergo an interview with official ACCME surveyors in order to achieve and maintain accreditation. This interview occurs after the ACCME reviews the Self-Study Report and performance-in-practice data covering the period before the accreditation or reaccreditation designation. The interview allows the CME provider to present and provide clarification of evidence of the organization’s efforts to fulfill ACCME requirements and its ability to produce positive educational outcomes for learners over time.
5. Accreditation Review Committee (ARC): This committee, like ACCME surveyors, are volunteers who review the Self-Study Report and supporting data submitted by CME providers for evidence of compliance. The committee then makes a recommendation to the ACCME Decision Committee regarding the relevant program’s eligibility for accreditation or reaccreditation.
6. Accreditation with Commendation: This is the most prestigious accreditation status available and provides a six-year term of accreditation rather than the initial four-year period for Accreditation. Only CME providers applying for reaccreditation may receive this designation.
7. Activity review: A central component of the application for Accreditation or Provisional Accreditation. This involves a review of educational activities for overall quality and ACCME criteria compliance.
8. Advertising and exhibits income: Income from advertising and exhibits that is provided by commercial interests are considered by the ACCME to be promotional activities and not CME. This means that income received under this category is not considered to be in violation of the ACCME Standards for Commercial Support: Standards to Ensure Independence in CME Activities SM.
9. AMA core requirements: The AMA requirements that any activity that provides AMA PRA Category 1 Credit™ must fulfill to maintain accreditation. These are presented in detail in the AMA PRA booklet.
10. AMA Direct Credit Activities: These are select activities that are not provided by an accredited CME provider but are nonetheless considered worthy of CME credit by the AMA, which awards the credit directly to the physician. These are presented in detail in the AMA PRA booklet.
11. AMA PRA Category 1 Credit™: CME credit awarded to physicians through completion of certified activities presented by ACCME or ACCME-recognized medical society; or by participation in an educational activity recognized by the AMA which provides direct credit; or by completing select international activities designated by the AMA as credit-bearing by the International Conference Recognition Program.
12. AMA PRA Category 2 Credit™: This is self-documented activity participation that has not been certified by the AMA for the award of AMA PRA Category 1 Credit™ but which aligns in a meaningful way with the AMA’s description of CME, provides demonstrable educational benefit and is not promotional in nature.
13. Annual Report Data: Data that accredited CME organizations must provide to the ACCME annually. This data must include extensive documentation of CME activities, comprising instruction hours, the number of participants, and the educational content of on-going activities, whether online, in-person or hybrid offerings. Statistics regarding the scale and outcomes of all accredited CME providers are published by the ACCME annually, providing members with a clear portrait of the growth of the CME industry year-by-year.
14. CME activity: The design process behind a CME activity is nearly as important as its content when it comes to certification by an accrediting body. A CME activity is considered as an educational exercise or course that has been created in alignment with the ACCME Accreditation Criteria, Standards for Commercial Support, and policies; the AMA Physician’s Recognition Award CME credit system standards; and the AMA Council on Ethical and Judicial Affairs educational opinions.
15. Commercial bias: The ACCME defines commercial bias as content or an educational format present in a CME activity or associated materials that promote a product, service, or business connected to commercial interest as defined by the ACCME.
16. Commercial interest: The ACCME states that a commercial interest is any organization that produces, sells, or markets healthcare goods or services that are used directly by patients. The ACCME excludes from this definition providers of clinical services to patients. An entity that is considered a commercial interest may not receive ACCME accreditation or joint-providership.
17. Commercial support: This is deemed to be money or in-kind contributions that are offered by a commercial interest to pay any portion of the expenses involved in the creation, management, or development of a CME activity.
18. Conflict of interest: The ACCME considers a relationship as a conflict of interest when a member of staff or an individual with a direct influence, control, or managerial authority over CME program content, materials, or development has a standing financial relationship with a commercial interest.
19. Co-provided activity: A CME activity that is provided by two or more accredited providers. One of the participating organizations must take the role of the responsible party which will ensure that provided activity or activities are in full compliance with ACCME and AMA requirements, including all data reporting obligations.
20. Directly provided activity: This is an educational activity that has been created, developed, assessed, and delivered to learners by an accredited CME provider. This definition includes co-provided activities (offered by two accredited providers).
21. Enduring material: This is an activity that occurs for a specific time period but which may be carried out at any time or location. Examples may be an online course, podcast, or interactive video.
22. Focused accreditation interview: This is an interview held with an ACCME/Recognized Accreditor and an accredited CME provider to discuss remedies for areas of ongoing noncompliance.
23. Hours of instruction: Hours of instruction may represent total hours a learner may spend to complete an activity, but they do not necessarily represent the same amount of AMA PRA Category 1 Credits™ granted for the activity.
24. In-kind commercial support: According to the ACCME’s Standards for Commercial Support, “in-kind” support is a non-monetary goods, service, or other resource received from a commercial interest for the benefit of the organization that is responsible for a CME activity, with the aim of supporting the activity. This support might include technical equipment of the use of facilities.
25. Jointly provided activity: An activity that has been launched, developed, and evaluated by an accredited provider and one or more non-accredited organizations.
26. Monitoring: The ACCME continues to monitor and assess accredited CME providers’ content, organizational, and strategic development at least once per year before accreditation or reaccreditation applications.
27. New procedures and skills training: An activity created by an accredited CME provider that trains physicians on topics that may grant them new clinical practice privileges as professionals. These activities exist in four levels of graduated intensity and complexity.
28. Performance: The ACCME defines performance as the level of demonstrable success that an organization can present, in terms of intended healthcare outcomes as a result of CME programming.
29. Performance Improvement CME (PI CME): This is an educational activity that is designed as a three-part process wherein doctors discover desirable performance benchmarks, review their own practices based on these new standards and then adopt new methodologies to reach these standards.
30. Performance-in-Practice Review: During an accreditation, reaccreditation, or progress report period, the ACCME or Recognized Accreditor will select a roster of activities to assess for ACCME standards compliance. This requires significant record-keeping over time along with the ability to easily give evidence of improving educational outcomes.
31. Probation Accreditation: This status indicates that the ACCME/Recognized Accreditor has determined that an accredited CME provider has failed to maintain ACCME requirement compliance and must commit to specific steps to reaching ACCME-accredited program standards. The CME provider may not jointly provide any CME activities during the probationary period.
32. Progress Report: An accredited provider that has received a noncompliance designation based on Accreditation Criteria must submit a progress report giving evidence that compliance has been achieved. If the ACCME/Recognized Accreditor accepts the progress report then the CME provider may continue the accreditation term with the full privileges of an accredited organization. If the report does not sufficiently demonstrate compliance to the satisfaction of the ACCME/Recognized Accreditor then the provider must submit a second progress report and participate in an accreditation interview with the accreditor to attempt to remedy the issues that are causing noncompliance.
33. Program and Activity Reporting System (PARS): A web-based portal from the ACCME designed to streamline and support the collection of program and activity data from accredited CME providers. PARS is also used by accredited providers to register CME activities that will count for Maintenance of CertificationTM and other uses, such as the Food and Drug Administration’s Risk Evaluation and Mitigation Strategies (REMS).
34. Relevant financial relationships: ACCME regulations require that any individual with direct influence over the creation, development, or presentation of CME content disclose relevant financial relationships to the CME provider. Individuals must also disclose any relevant financial relationships maintained by their spouse or partner. A relevant financial relationship is defined by the ACCME as any financial relationships occurring within the past 12 months that offers any tangible financial benefit or may offer a tangible financial benefit in the future. According to the ACCME, the amount of current or potential financial benefit is immaterial. A tangible financial benefit may include the transfer of intellectual property rights, the use of facilities, trips, honorariums, or other potential in-kind payments.
35. Standards for Commercial Support: The ACCME Standards for Commercial Support were designed to provide guidance to CME providers in the prevention of the influence of commercial bias. The Standards comprise six standards: independence, resolution of personal conflicts of interest, appropriate use of commercial support, appropriate management of associated commercial promotion, content, and format without commercial bias, and disclosures relevant to potential commercial bias.
The Self-Study is a classic “elephant in the room” present from the birth of your CME program through its maturity: unavoidable, commanding, and a bit scary. It is perhaps one of the most intimidating elements of ACCME changes to the accreditation process—necessitating the kind of introspection and detailed evaluation that would be uncomfortable amongst intimate friends, let alone an entire professional organization. But the Self-Study is actually a friendly beast, designed to help you focus your attention on what matters most to your organization: your vision, learner results, and your ability to transform educational outcomes into tangible improvements to community healthcare.
Here are 3 ways to take control of the process:
Step 1: Master Your Data
Whether you are tackling the Self-Study for the first time or entering a reaccreditation period, your biggest challenge is likely to be data management. Directors of large CME programs may face obstacles in collecting and warehousing large data stores. CME directors for smaller programs may face barriers to verifying data hygiene and coordinating the constant flow of new information as program rosters grow. In both cases, the Self-Study remains a core component of the ACCME accreditation approval process that cannot be overestimated in its importance to the success of your program.
Perform a Quick Self-Audit
Although the word “audit” may conjure up an image of a stern IRS agent raising an eyebrow as they scroll through spreadsheets, in reality, a thorough review of your data management practices can be a quick and painless way to take control of the Self-Study process. How quick?
Answer these 5 questions:
1) Can I easily access, sort, and review educational outcomes for a select demographic group, individual courses, or specific learners from the start of the CME program to present?
2) Can I compile and share a detailed data visualization presenting evidence of improved learner outcomes over time in just a few minutes?
3) Are PARS-compliant data report submissions automated, with real-time and historical data derived directly from the source/s?
4) Is it simple to use your existing data management tool to isolate and review educational content that may be at the root cause of poor learner outcomes?
5) Can you automate the most challenging aspects of your Self-Study process?
Even if most of your answers were “No” to questions 1-4, you can answer “Yes” to number 5, and we’re about to show you how to get the most out of your data.
When assessing your data management practices, focus on:
Even if you’ve managed to build an enterprise-grade data management platform from scratch in your spare time, even the most comprehensive database will be useless to your team if insights are hard to glean and share.
Your CME data is your most valuable asset for growth strategy creation and content development. You will want as much historical reach and as many levels of insight guiding your decisions as possible. That means historical and real-time data should be easily searchable. (Learn how to get to your data fast through streamlined data management)
For your data’s relevance to remain evergreen, you will need to be able to place granular insights into the context of your CME program’s “Big Picture”. That means your data management capabilities should include mapping relationships between data sets, such as shifts in assessment scores and an influx of student support ticket requests regarding a new content format. Regardless of the method that you use to manage your data, you should be able to slice your data as you wish to predict patterns in educational outcomes and adjust or content as required. (Learn about how to identify patterns in your data and glean actionable insights)
One of the easiest ways to manage your data is to automate the entire process through an enterprise-grade data management suite.
Step 2: Rethink the Reporting Process
When we talk about PARS-compliant reporting, the Self-Study or the Performance-in-Practice review, we are essentially discussing the collection, organization, and storage of “clean” data; information that is (hopefully) derived directly from the source (like the learning management system) and is not stored using a method (like a spreadsheet) that is prone to human error.
Without a solid strategy for avoiding data entry and editing mishaps, maintaining “clean” and accessible data files, and sharing those files with organizational stakeholders on-demand, you will be facing a significant managerial and task management challenge during every review period.
For your Self-Study:
· Implement a data handling approach that promotes good data hygiene as the norm in your organization.
· Be certain that your information processing plan is not wholly dependent on data volume remaining static.
· Develop a data-collection process that is focused on scalability.
A sudden uptick in new learner registrations should not compromise data quality or tax your staff with additional administrative duties.
Step 3: Use Tech Tools That Save Time
While the content of your activities may change, the critical insights that ACCME/Accredited Reviewers will want to see will remain the same: educational outcomes, demonstrable professional development, and learner feedback will always be referenced.
While the digital age has rid us of much of the paper that may have piled on an earlier generation’s desk, many of us are still drowning in data. No one should have to fight their way through their own data to get a clear picture of their organization’s success.
Use the right tech tools to streamline the Self-Study preparation and development process.
· A powerful learning management system (LMS) that automates data collection from learner registrations, activities, and feedback.
· A comprehensive analytics suite that creates user-friendly graphical models of your data that can be generated on the fly to discover insights across your program’s entire timeline.
· A report templating system that shaves days of the report-creation process by automating design and incorporating data visualizations that can be created with a few clicks.
Learn about how enterprise-grade LMS features simplify compliance.
By the Numbers: A Step-by-Step Guide for the Latest ACCME Criterion
It isn’t all that bad. In fact, updates to ACCME criteria are rarely sweeping, dramatic overhauls—simply because the ACCME’s core principles remain the same over time. The yearly challenge facing CME directors is adhering to ACCME standards of practice in view of the unique circumstances, resources, and audience of their individual programs.
So what’s new for 2020?
Here’s a brief overview of the basics:
First-time applicants applying for the two-year Provisional Accreditation must demonstrate compliance with Criteria 1, 2, 3, and 7–12.
Accreditation or Reaccreditation
Applicants applying for the four-year Accreditation or Reaccreditation term for a must give evidence of compliance with Criteria 1–13.
Accreditation with Commendation
Providers may also apply for Accreditation with Commendation, a six-year term. Providers seeking commendation must comply with Criteria 1-13 and choose one of the following two options.
· Providers awaiting accreditation decisions through November 2019 have the choice of using either Option A: Commendation Criteria (C16-C22) or Option B: Menu of Commendation Criteria (C23-C38) to seek Accreditation with Commendation.
· Providers awaiting accreditation decisions after November 2019 must use Option B: Menu of Commendation Criteria (C23-C38) to seek Accreditation with Commendation.
Find the full text here.
Criterion 1. The provider has a CME mission statement that includes expected results articulated in terms of changes in competence, performance, or patient outcomes that will be the result of the program.
You mission statement should be detailed, yet concise. Make sure it provides specific goals that are reasonable given your current resources and demonstrable at each stage of your program’s development.
Criterion 2. The provider incorporates into CME activities the educational needs (knowledge, competence, or performance) that underlie the professional practice gaps of their own learners.
For efficacy and for the purposes of the Self-Study, your educational programming should be data-driven at each stage of its creation. That means your curriculum development and review process should be based on insights based on historical data and incorporate findings from recent educational outcomes. This also means that easy access to your data is essential.
Criterion 3. The provider generates activities/educational interventions that are designed to change competence, performance, or patient outcomes as described in its mission statement.
There is an important assumption in this criterion that should not be overlooked. Your learning management system and data management platform must enable your organization to not only identify areas of learner competence, professional performance, or patient healthcare experience that merit improvement, but also effectively demonstrate results.
Criterion 4 was eliminated in February 2014.
Criterion 5. A CME provider must choose educational formats for activities/interventions that are appropriate to the present setting and stated objectives of the activity.
Criterion 6. The provider develops activities/educational interventions in the context of desirable physician attributes eg, Institute of Medicine.
Criterion 5 and 6 are interconnected and can be looked at as two parts of a whole. As a CME director, your program data serves as a window into the true status of your organization’s progress towards accomplishing its educational mission. An essential step in achieving your organizational goals is mastering context when developing programming and updating course content.
Use your data management platform to capture granular insights that can be used to adjust content formats (such as adding video tutorials to a course where students are struggling with complex concepts) or the curriculum itself as needed. With the right data management platform, you can demonstrate to the ACCME how your organization proactively address the needs of its learners based on a responsive, data-driven strategy. Learn more about data-driven insights.
Fortunately, the ACCME is exceptionally clear on commercial independence. As the ACCME strengthened its commercial independence strategy recently, it also published numerous resources about its latest approach to ensuring educational quality. A response to industry feedback provides a great roundup of trending concerns in the CME community about how the changes may impact day-to-day management. Here are some of the top challenges that accredited CME providers mentioned:
Before we get to some great ACCME resources, let’s take a quick look at the recently updated ACCME regulations:
Criterion 7. The provider develops activities/educational interventions independent of commercial interests. (SCS 1, 2, and 6).
Criterion 8. The provider appropriately manages commercial support (if applicable, SCS 3 of the ACCME Standards for Commercial SupportSM).
Criterion 9. The provider maintains a separation of promotion from education (SCS 4). Criterion 10. The provider actively promotes improvements in health care and NOT proprietary interests of a commercial interest (SCS 5).
Criterion 11. The provider analyzes changes in learners (competence, performance, or patient outcomes) achieved as a result of the overall program’s activities/educational interventions.
Criterion 12. The provider gathers data or information and conducts a program-based analysis on the degree to which the CME mission of the provider has been met through the conduct of CME activities/educational interventions.
Criterion 13. The provider identifies, plans and implements the needed or desired changes in the overall program (eg, planners, teachers, infrastructure, methods, resources, facilities, interventions) that are required to improve on the ability to meet the CME mission.
Great! You are now up-to-date on the latest ACCME updates to commercial support standards. So, what do you do now? Just a bit more reading. Here are some great answers for frequently asked questions about commercial independence straight from ACCME.
Does an accredited provider have to report commercial support that is paid directly to a joint provider for an activity?
How do we report in-kind support?
How can I determine if my organization is a commercial interest?
Can a provider include terms about both commercial support and promotional fees in the same written agreement?
What is a “relevant financial relationship” described in Standard 2 of the ACCME Standards for Commercial Support?
For more, go directly to the ACCME website.
The ACCME has a great library of resources giving you some excellent examples of general compliance and non-compliance, as well as videos that offer a deep dive into the details of common challenges to standards maintenance. Here are some of the best that we’ve found:
Policies Supplementing the Standards for Commercial Support
· Definition of a Commercial Interest
· Financial Relationships and Conflicts of Interest
· Disclosure of Financial Relationships to the Accredited Provider
· Commercial Support: Definition and Guidance Regarding Written Agreements
· Verbal Disclosure to Learners
· Commercial Support: Acknowledgments
· Commercial Exhibits and Advertisements
Frequently Asked Questions
· Standards for Commercial Support FAQ
Examples of Compliance and Noncompliance
Here are more examples of Accreditation Criteria cases that reference the Standards for Commercial Support:
Overview of ACCME’s Standards for Commercial Support: Standards to Ensure Independence in CME Activities
· What is “Commercial Interest”?
· What creates a Conflict of Interest?
· How can I best identify relevant financial relationships?
· Who is in control of CME Content?
· What are relevant financial relationships?
· Managing Commercial Support: Understanding Criterion 8
· Separating Promotion from Education: Addressing Criterion 9
· Protecting the Integrity of CME for Learners and the Public: Criterion 10
Tips and Tools
Compliance Reminder: Identifying and Resolving Conflicts of Interest for CME Planners,
Highlights Blog Post, 2017
· ACCME Offers Guidance for CME Providers Related to Revised Industry Codes in Europe and Asia, Highlights Blog Post, 2017
· Flowchart for the Identification and Resolution of Personal Conflicts of Interest, Publication, 2017
· Using ACCME’s Flowchart for Identifying and Resolving Personal Conflicts of Interest, Tutorial, 2017
· Dealing with Controversial Topics in Your CME Program, Highlights Blog Post, 2017
· Message from the CEO: Strategies and Reminders for Ensuring Compliance with the Standards for Commercial Support, Highlights Blog Post, 2016
· Letter from the CEO: Strategies and Reminders for Ensuring Compliance with the Standards for Commercial Support, Letter from Graham McMahon, MD, MMSc, President and CEO, ACCME, 2016
· Sample Letter to Identify Relevant Financial Relationships (Form Embedded) (Word Document)
· Sample Letter of Expectations Following Faculty Disclosure to Provider (Word Document)