Classy Clinical Resources, a professional services company that owns an accredited provider, recently restructured to ensure that it would not be considered a commercial interest by the Accreditation Council for CME. It moved all its nonindependent activities to a separate company to ensure its ability to provide independent content. ACCME approved CCR’s restructuring plan and determined that the company and its subsidiaries were not commercial interests.

In planning CCR’s educational grant strategy for 2011, Billy Budget, the company’s operations and finance director, notices that Handy Health Solutions, one of CCR’s “competitors,” is listed as a grant recipient on several commercial supporters’ Web sites. Billy finds that HHS produces both promotional and CME-certified educational activities, all funded through pharmaceutical company grants. Billy and CCR’s leadership feel that their efforts to comply with ACCME regulations have put them at a competitive disadvantage in a community where other providers don’t seem to be playing by the same rules. They are evaluating options to address this situation and to ensure a good start for 2011.

Need to Level the Playing Field
Do providers have “competitors”?
Overstreet: While all CME providers are potential collaborators, they also compete for staff, faculty, learners, and funding. Today’s dwindling resources and decreasing support for medical education may make the competition seem fiercer than in the past.

Parochka: Yes, sadly, providers who abide by the regulations may find themselves disadvantaged by those who do not. Even more unfortunate, apparently the pharmaceutical industry is not filtering out companies that conduct both promotional and educational activities before awarding educational grants.

What role do grantors play?
Overstreet: Grantors should learn about the organizations that are requesting educational grants, including how they are structured and the way they operate. Understanding the grant requester and its affiliates/parents, and not funding those who blur the definition of commercial interest, would protect the grantor as well as the integrity of industry-funded CME.

Parochka: The Pharmaceutical Research and Manufacturers of America could assist the CME community by instituting a policy that requires industry members to determine during the grant-review process whether applicants conduct both promotional and educational activities. Adding an attestation statement—“Do you attest that as a provider you do not conduct both educational and promotional activities?”—could facilitate the educational grant review process, especially if organizations that do both are disqualified during the review.

What should Billy do now?
Overstreet: Billy is smart to plan ahead for next year and to evaluate what other providers are doing—which will become easier to do as grant-funded education becomes more transparent. He also would be wise to ensure that his own shop is beyond reproach regardless of what the competition is doing.

Parochka: Billy could also contact the leadership of CME organizations (such as the National Task Force on CME Provider/Industry Collaboration or the Alliance for CME) and related publications to ask that these topics be addressed. Creating awareness of this dilemma will go a long way toward ensuring that educational grants go to appropriate and qualified applicants.

Karen Overstreet, EdD, RPh, FACME, CCMEP, is executive director, Lippincott CME Institute, Wolters Kluwer Health Medical Research, Blue Bell, Pa. Reach her at Karen.Overstreet@wolterskluwer.com.

Jacqueline Parochka, EdD, FACME, is president and CEO, Excellence in Continuing Education Ltd., Gurnee,
Ill.; and partner, PTR Educational Consultants. Reach her at JacquelineParochka@comcast.net.

Your Views Welcome / To share your comments on this case, or if you have an “ethical hypothetical” you’d like reviewed, e-mail spelletier@meetingsnet.com.

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