The complex web of CME is not easily reduced to one-size-fits-all regulations nor to a degree of exact specificity as might be applied to a mixture of chemicals. So it is with the April revision of the Standards of Commercial Support, which says that faculty must disclose their relevant financial relationships with commercial interests, but does not further specify what level of financial relationship must be disclosed. That's because it would be unreasonable to fix precise dollar amounts to faculty disclosure requirements when it is virtually impossible to accurately compare one event with another.

CME providers cannot reasonably be expected to investigate financial relationships to the most minute detail and then decide, based on some ill-defined guidepost, that a particular compensation level is OK while another is not. How, for example, can we put a price tag on the value of faculty time, experience, and knowledge? This is not only extraordinarily arbitrary, it invades the privacy of the faculty member, and in no manner can it be proven to improve CME. The Accreditation Council for CME has rightly placed the burden of correct judgment on both the CME provider and program participants. Participants can judge the appropriateness of relationships among faculty and commercial supporters based on individual value systems, while providers are obligated to assure that such relationships do not bias program content.

CME Providers in Control

The ACCME and its Standards Task Force have worked long and hard to improve the existing Standards of Commercial Support. They have done so with the suggestions and advice of interested parties of every stripe, and as the April draft confirms, they have made substantial changes to the earlier draft, which many had found objectionable. The ACCME is not in an enviable position having to provide a foundation for the CME process, while simultaneously satisfying the wants, expectations, and opinions of a far-reaching and often divergent constituency. With the April draft, ACCME has done a commendable job by presenting a reasonable and workable document. The new policy places clear responsibility for control of all activity components on the CME provider, precludes commercial influence, focuses on appropriate financial arrangements, and tightens disclosure requirements. It should be acceptable to providers and funders alike. While sections of the Standards document will need further clarification or interpretation, basically it is a sound document that is not overly restrictive.

Vote Yes and Move On

As with all regulatory documents, there is an inherent danger that their principles will be exaggerated or over-interpreted. Should we be trapped by yet another round of debate and complaint, CME will again be in regulation free-fall and, very likely, we will construct a standards model very similar to that to which we so vigorously objected. While time and events subject all regulations to revision — and so it will be with the Standards — the time is right to support the new draft as it applies at this point in time and get on with the business of improving the CME product. Collectively, all in CME have spent countless hours debating, interpreting, and in some cases, applying the earlier draft document. That amount of time and level of energy was appropriate in the sense that our voices were heard and the Standards modified. Now it becomes important to pump that level of concern and commitment back into the CME process per se.




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