The Case: Ima Patella, MD, medical director for non-accredited education company CME Pronto Inc., has been working with the CME department at Good Health Medical School to plan a live activity titled “Necks, Shoulders, Knees & Toes.” Dr. Patella has been able to secure several educational grants to support the conference, including one from Prosthesis, Posts, and Pins Inc. that allowed the provider to lower the registration fee. She agreed to provide the list of pre-registrants to the commercial supporters so that they could assist with audience generation.
Without discussing the matter with the accredited provider or joint sponsor, PP&P’s VP of developed and mailed a flyer to potential conference registrants within a 100-mile radius. The flyer announced they could call 800.FREECME to obtain a registration fee waiver and indicated they could invite nonphysician ancillary office staff to the conference. Dr. Patella is surprised to receive a call from the director of CME at Good Health Medical School, who is irate after receiving the announcement of the registration fee waiver and expanded target audience from a fellow member.
Who is responsible for a jointly sponsored activity?
Parochka: Accredited CME providers are ultimately responsible for all aspects of their activities and need to have strict guidelines, policies, and procedures surrounding jointly sponsored activities to avoid embarrassing situations. Accredited providers must offer training so joint sponsors are clear regarding their duties and responsibilities.
Overstreet: Joint sponsors should understand the limits of their authority, and processes should be put in place to ensure that all collaborators communicate effectively. Appropriate interactions with supporters should be spelled out, and the accredited provider should insist on reviewing all marketing materials before they are distributed.
Can the target audience be expanded after the activity is planned?
Parochka: Although the Accreditation Council for CME’s Standards for Commercial Support do not explicitly state that the target audience has to be identified, it goes against logic that CME activities could be planned and implemented without identifying the clinicians who need the education. While the Institute of Medicine recommends as one of its goals, the intent is to design this programming type from the outset, not to consider the intended educational recipients as a planning post-script.
Overstreet: Identifying the audience and its practice patterns and barriers is critically important to the process of gap analysis and needs assessment, which should drive the planning and development of the educational intervention. In many cases, clinicians other than physicians are, and should be, included in the target audience, and this should be determined early in the planning process, rather than during registration.
Should CME providers advertise free CME?
Parochka: CME activities are never free and the practice of advertising them as such should be abandoned.
Providers are required to acknowledge educational grants from commercial interests used to support the educational endeavor. When medical specialty societies offer educational activities without charge, they are generally supported through annual membership dues. Similarly, physician staff dues may be used to underwrite hospital-based CME activities.
Overstreet: Unfortunately, neither the CME community nor medicine has done a good job of educating physicians about the cost—and value—of their education.
Karen Overstreet, EdD, RPh, FACME, CCMEP, is executive director, instructional design and outcomes with Medscape Education, Blue Bell, Pa. Reach her at Koverstreet@medscape.net.>p> 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.
More Ethical Hypotheticals
Risky REMS Remedy