As the Accreditation Council for Continuing Medical Education refines the requirements for meeting the Standards for Commercial Support and Criteria 1-22, many accredited providers struggle with how to interpret the Criteria and then how to demonstrate compliance. Since Denise Doyle, CCMEP, consultant for Steve Passin and Associates, deals with this on a daily basis, it made sense to invite her to join us for this month’s exchange.

From: Cathy
To: Denise, Scott

I recently was contacted by a colleague who is in the process of preparing her self-study for re-accreditation purposes. Knowing that we are in the midst of doing the same, I suppose she felt I would take pity and help her interpret just what Criterion 18 means to me and how we are handling it in our CME program. Criterion 18 deals with identifying factors outside the provider's control that have an impact on patient outcomes. One would argue that much of what we do as educators falls under this category. But I think what the ACCME wants us to demonstrate is how we uncover the barriers that our learners face in daily practice and how we help them overcome these barriers. Importantly, this is not to be confused with Criterion 19,which deals with overcoming the barriers to physician change (another discussion for another time). 

Denise, you must deal with this confusion regularly. How do you advise your clients?

From: Denise
To: Cathy, Scott

We are asked to clarify the difference between C18 and C19 (as you describe) all the time. The advice we offer consistently is to ask the learners! When planning an activity, part of the gap analysis process involves delving into the scope of practice of the targeted learners and finding what barriers they face when dealing with particular clinical issues. The job of the planning committee then is to think about how to impart knowledge and skills to help the learner overcome these barriers. Generally, these barriers can be grouped into categories of financial factors, human factors, or state-of-science factors.

From: Cathy
To: Denise, Scott

So, for example, we’ve been doing a fair amount of education on glaucoma, and when we asked the learners what the barriers were, the top answer was almost always patient adherence. After delving a little deeper we came to find out that patients weren’t adhering because they were having issues with administering the medication. Those little eye-drop bottles are tough for elderly patients who have arthritis, and they were afraid to tell the doctor they hadn’t followed her advice. Since we couldn’t send a spry young nurse’s aide to every household in America, we wanted to somehow make the physicians more empathetic toward the plight of their patients and foster a better line of communication. So we had specially designed ergonomic gloves made that simulated the challenges some patients face and asked for learners to attempt to put drops in their eyes while wearing the gloves. It worked. It made them all more aware and therefore, we hope, able to have better communication with their patients.    

From: Scott
To: Denise, Cathy

One of the nice things about my job is that I have a chance to interact pretty regularly with healthcare providers in the field, and it is often in those casual conversations that you hear about what these individuals face on a daily basis. Blind “needs assessment” surveys can be challenging for so many reasons, so it’s really vital to take advantage of opportunities to talk to your learners to hear about what is happening in their world. Of course, from an ACCME perspective, the important step is to document those conversations and to draw reasonable conclusions that inform future planning. You find patterns more often than you’d expect.

From: Cathy
To: Scott, Denise

Scott, have you been able to have any substantive conversations with any docs while on vacation in Curaçao this week? But seriously, I think that’s really at the heart of what the ACCME is looking for. Don’t you agree, Denise?

From: Denise
To: Cathy, Scott

Exactly! By asking learners about barriers, the provider can identify factors from the real world. Many times, the activity evaluation is an additional means of uncovering barriers or even additional suggestions to overcome a barrier. Then you can analyze those evaluations using the "SWOT" (strengths-weaknesses-opportunities-threats) method to find additional factors that may impact outcomes and are related to the clinical content of the activity.

From: Scott
To: Denise, Cathy

I personally don’t generally find a lot of value in activity evaluations—everyone always says their biggest barriers are lack of time and reimbursement issues. But if you can get more specific information than that, that’s another way to get at it. It’s also good to listen to what sorts of questions people have during activities, though you have to be cautious about getting too excited about what one or two people express as their challenges. We have to look for patterns, not outliers.

As to my vacation, it’s amazing how many strawberry daiquiris these “doctors” I have been talking to can consume on the beach every day. I have meticulously kept my receipts for each one.

From: Cathy
To: Scott, Denise

Safe travels, Scott. We’ll talk about those receipts when you’re back in the office!

Cathy Pagano, CCMEP, is president and Scott Kober, MBA, CCMEP, is director of content development at the Institute for Continuing Healthcare Education in Philadelphia. Their e-mails are cpagano@iche.edu and skober@iche.edu. Denise Doyle, CCMEP, is a consultant for Steve Passin and Associates. E-mail her at doyle@passinassociates.com.

More of Scott and Cathy's columns:

Too Many Slides, Not Enough Time

Transparency and Industry Funding

Avoiding the Shiny New Toy Syndrome When Introducing New Technology in CME

How to Handle Scope Changes

What to Do When Marketing and Education Meet