FIRST, HAVE FAITH that the American Medical Association, the American Hospital Association, the Council of Medical Specialty Societies, the Alliance for CME, the Association of American Medical Colleges, and others will have the wisdom and the clout to convince the the Centers for Medicare and Medicaid Services staff that they were mistaken to determine that CME is primarily of value to physicians rather than to patients. Failing that, the other option would be to lobby the U.S. Congress to amend the Stark Law. You should be able to expect the organizations that are responsible for accrediting CME programs to work with you on the interplay between Stark II and accreditation.

What you personally can do is to help establish once and for all that CME primarily benefits patients, not doctors. The core of the error that the CMS staff has made is the presumption that the benefit of CME activities accrues primarily to physicians. By holding to this assumption the CMS staff are throwing the “better patient care” baby out with the “fraud and abuse” bath water. Ironically, by foreclosing the ability of hospitals to teach physicians how to improve patient care, CMS is at odds with the interests of the aged, weak, and sick whose welfare they exist to protect.

All of us need to work to establish the principle that the primary beneficiaries of CME activities are the patients who receive better care because doctors are better educated. We can do this by assuring that CME is concerned primarily with the gaps between what is and what should be in healthcare practice. The rewards that physicians receive from participating in gap-oriented CME are not measured by the value of free meals or higher income per patient admitted, but by satisfaction from seeing patients returned to good health more quickly and efficiently.

Here's how:

  1. Gap problems must be made credible through the use of hard data that clearly defines the problem and provides a baseline against which progress through education can be measured.

  2. Gap problems can rarely be solved by a single educational activity. If the lag time between the admission of myocardial infarction patients and the administration of anti-coagulation therapy is to be significantly reduced, all of the several groups of healthcare professionals and managers who encounter such patients must be involved in planning and delivering corrective measures. Such an effort takes on the character of a campaign, with many kinds of initiatives that reach all who may affect the amount of time that elapses between admission and therapy.

    Educational campaigns require strong liaisons among all involved groups to identify contributing problems and to plan and deliver corrective measures.

  3. The gap approach to CME requires a continuous flow of clinical data. Not only must there be baseline data to define the problem; there must also be monitoring of progress in solving the problem, and ultimately data that clearly defines for all to see that the gap has been closed. Ten years ago the state of clinical data systems made the reporting of progress in meeting clinical goals difficult. Today clinical data systems that function virtually in real time make such reporting much more possible. One of the effects of Stark II may be to pressure hospitals that have been slow to upgrade their clinical data systems to do so immediately so they can demonstrate clearly the impact of their efforts to improve quality of care.

  4. CME professionals need to develop leadership skills in reporting the progress that results from their efforts. One reason that Stark II has been so threatening to CME is that too many senior administrators see CME as a benefit provided by the hospital to “keep the docs happy” — they see it as a cost center that never produces enough income.



CME leaders should report the hard data of clinical progress in quality of patient care quarterly to their CME committees, and through them to their administrators and boards. Those who do this will surely put the lie to the illusion that CME is primarily for the personal aggrandizement of physicians.

Further, they will endear themselves to hospital administrators at all levels. Who wouldn't welcome the news that the average time between an MI admission and start of anti-coagulation therapy has gone from eight hours to 45 minutes; or that satisfactory pain control, as reported by patients, has gone from 20 percent to 80 percent; or that diabetic blood pressures controlled to a level of 120 systolic have gone from 20 percent to 92 percent?




Kevin Bunnell, EdD, is a CME consultant based in Boulder, Colo., and former Alliance for CME president.