Coming Into Compliance
The first thing providers need to do to bring their programs into compliance is to understand what is being required of them, Kopelow stresses. Either Kopelow orDeputy Chief Executive and Chief Operating Officer Kate Regnier, MA, MBA, holds a phone call with the leadership of every organization that goes on probation, and ACCME holds group calls with every organization that is required to do a progress report.
“They need to attend those calls and understand what the requirements are, then they have to go do it right, and be able to show it. Those are the three things they have to do to get into compliance,” says Kopelow.
CME providers need to develop a plan and outline the specific tactics and action plan they intend to take to modify their CME program to meet ACCME's expectations, said Richetti and McFadden in their session. And, they said, providers should take advantage of this opportunity to measure what is and isn’t working as they go through the process using the Plan-Do-Study-Act, or PDSA model to chart their progress. Implementing this plan can also support their compliance with Criteria 12 through 15. Begin the process with the end in mind, Richetti and McFadden emphasized.
Criterion 15, which requires the provider to demonstrate that it is measuring the impacts of the needed program improvements, must be addressed as part of the improvement process and not as an afterthought. Describe what you’re doing to improve your program, and provide evidence that you’re doing it. As Kopelow says, “Ask yourself what you’re doing to show that you’ve made the improvements. Most providers already have the necessary paper trails built into their process; they just have to show us.”