Rethink Excessive Documentation Requirements

A LEADING MEDICAL institution now requires 32 pages of explanatory notes and forms covering 18 distinct categories to validate its grand rounds CME activity. Perhaps this process is atypical, but it's more likely that it is typical of the burden placed on institutions, CME departments, planners, and faculty by current CME regulations. Within the 32 pages are hundreds of fill-in-the-blank requests for activity specifications from needs assessment to financial reconciliation.

Consider the impact of documentation compliance on those interested in creating or participating in a CME activity. The grand rounds example can be more broadly applied across the spectrum of CME events. Even with clerical assistance, planners and activity directors are faced with a daunting task for each new CME activity.

For some — and perhaps for many — documentation requirements are disincentives for CME planners. Department chairs, faculty, and physicians in general usually do not enjoy the luxury of spare time during the workday and, faced with the amount of time needed to justify a CME activity, they may decide such time is better spent in patient care or in another professional endeavor. Ultimately, CME is the loser.

In many institutions, the required documentation often is not received until weeks or months after the CME event — and then only after investing effort and expense in the collection process. Time spent in the pursuit of this documentation surely could be put to a better use. It also can be argued that much of the requested documentation goes unused, only to reside long-term in electronic or hard files.

Unreasonable Requirements

At a time when the factors contributing to the cost of drugs are being scrutinized in the media, and institutions and CME departments are counting their pennies, the cost involved in CME documentation, both financially and in terms of lost productivity, should perhaps be examined. For example, would CME departments approach solvency if they were relieved of some of the documentation that is now required? Would the bottom line improve if all institutional contributors to the process spent less time informing their CME constituents of the rules and designing, printing, distributing, and collecting forms, while maintaining records over a period of years? Could this salvaged energy be refocused on improving the educational components of CME ? Is the time that goes into the documentation process time well spent?

Break the Logjam

The documentation logjam affects all CME providers, some to a greater extent, and it is a problem not restricted to medical institutions. A certain amount of documentation is necessary in any complex process, but we should question whether the CME requirements have become unreasonable.

Given the current structure of CME and its many issues, solutions to the documentation problem do not have a priority status. With no clear solutions, debate and discussion are necessary. Perhaps it is time to begin.


Robert F. Orsetti is assistant vice president, continuing education, University of Medicine & Dentistry of New Jersey in Newark. Orsetti, a 24-year CME veteran, has served in a variety of settings including pharmaceutical companies and medical education firms. He is a member of the AMA's National Task Force on CME Provider/Industry Collaboration. Contact him at (973) 972-8377 or send e-mail to orsettrf@umdnj.edu. For more of his columns, visit mm.meetingsnet.com.


For more about the increasingly complex commercial support process, see “The Frustration Factor” in our June issue, available at mm.meetingsnet.com.

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