Setting Your Sights on Level 3 Compliance

The Accreditation Council for CME made it very clear at the 2007 Alliance for CME annual meeting that it may not be possible for providers to achieve Level 3 compliance with the updated accreditation criteria by the November 2008 deadline. However, we suggest you begin preparing for this level of compliance now, so that you have time to develop your strategies for implementation. Complying with these criteria will also serve to distinguish you in the eyes of leading commercial supporters, which is in your best interest if you are seeking educational grants.

Here are some suggestions for how to begin:

  • Criterion 16 states that the provider must operate in a manner that integrates CME into improving professional practice. How do you demonstrate compliance? Establish a relationship with specialty boards to understand the skill areas for which they will hold physicians accountable and to qualify to become an authorized provider of the boards' practice-improvement and self-assessment modules. Conduct focus groups and/or interviews with learners in the target audience for a better understanding of the nuances of the practice environment.

    (To download slides from the American Board of Medical Specialties about the relationship between CME and maintenance of certification, visit www.passinassociates.com.)

  • Criterion 17 requires the provider to demonstrate the use of noneducation strategies. Consider using qualitative patient focus groups or quantitative surveys for information and ideas about these activities. This can help you develop tools for physicians to give patients to help promote better outcomes from the CME activity. This information also becomes evidence of your compliance with Criterion 17. Other ways you can demonstrate compliance with this criterion are by using chart reminders, pocket guidelines for physicians, peer-to-peer feedback tools, and learner contracts.

  • Criterion 18 requires the identification of factors outside the provider's control that affect patient outcomes. It addresses barriers that prevent physicians from making changes in their practices. Encourage your planners to ask: Are there barriers that learners are likely to encounter that will derail them from achieving the intended result of this activity? You can then facilitate a discussion about how the activity can address these obstacles.

  • Criterion 19, tied directly to criterion 18, says providers must implement educational strategies to deal with barriers to physician change. Identifying a barrier is the first step in overcoming it. This is the strategy involved, but it is equally important to document your success in helping learners overcome identified barriers.

Plan for Partnerships

  • Criterion 20 was the theme of the 2007 Alliance meeting: collaboration. CME today values sharing ideas and best practices, and structuring educational partner relationships that enhance the learning experience for physicians.

  • Criterion 21 requires that the work of the provider exist within a framework of quality and patient safety, which links directly back to the planning process. During planning, you need to examine quality improvement and safety issues associated with the intervention, identify potential partners that can collaborate on these issues, and/or develop complementary activities to address these issues.

  • Criterion 22 focuses on the achievement of all of the new criteria — saying you need to be positioned to influence the scope and content of interventions. To document compliance with No. 22, do an annual self-assessment, analyzing each of the other 21 criteria and how you complied to determine your organization's educational effectiveness.


Steve Passin and Susan O'Brien are, respectively, the president and senior associate of Steve Passin & Associates, a CME consulting company headquartered in Newtown Square, Pa. Reach Passin at assin@passinassociates.com; and O'Brien at obrien@passinassociates.com.

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