The ACCME’s recently announced series of changes, initiated by the ACCME board of directors, are intended to simplify the accreditation process. We applaud the ACCME leadership for proposing these changes as they serve to clean up vestigial requirements that predate the 2006 Criteria for Accreditation, remove requirements that seem superfluous, and recognize the electronic world in which we live today that made some requirements no longer necessary or appropriate.

Please note: These changes are in a proposal format at this time; they must be vetted, commented on, and finalized before they are ready for implementation by the CME community. The ACCME emphasized that no changes should be implemented by CME providers at this time.

Summary of Proposed Changes by Criterion or Policy

The ACCME did not propose changes to any criteria not discussed below.

The Standard Criteria

Criterion 1:The provider has a CME mission statement that includes all of the basic components (CME purpose, content areas, target audience, type of activities, expected results) with expected results articulated in terms of changes in competence, performance, or patient outcomes that will be the result of the program.
Proposed Change:The requirements for a CME mission statement would be changed to require only discussion of expected results and remove requirements for purpose, content, audience, and types of activities.
Discussion:The emphasis on the revised accreditation system appears to be focused on changing behavior and results. It allows CME providers to shape their mission in any way that suits them as long as the expected results of their program are explicit.

Criterion 4:The provider generates activities/educational interventions around content that matches the learners’ current or potential scope of professional activities.
Proposed Change:Deleted in its entirety.
Discussion:This criterion was redundant, provided the professional practice gaps of learners had been clearly articulated.

Criteria 12:The provider gathers data or information and conducts a program-based analysis on the degree to which the CME mission of the provider has been met through the conduct of CME activities/educational interventions.
Criterion 13:The provider identifies, plans, and implements the needed or desired changes in the overall program (e.g., planners, teachers, infrastructure, methods, resources, facilities, interventions) that are required to improve on ability to meet the CME mission.
Proposed Change:Criteria 12 and 13 would be joined to provide a more logical flow of overall assessment of the CME program and changes to improve the program.
Criterion 14:The provider demonstrates that identified program changes or improvements that are required to improve on the provider’s ability to meet the CME mission are under way or completed.
Criterion 15:The provider demonstrates that the impacts of program improvements that are required to improve on the provider’s ability to meet the CME mission are measured.
Proposed Change:Criteria 14 and 15 would be deleted in their entirety.
Discussion:This change consolidates the existing Criteria 12, 13, 14, and 15 into a single requirement covering the key information for program analysis and planned improvements. The ACCME wants to focus on the core concept of the Plan-Do-Study-Act cycle and eliminate the criteria that are redundant.

Accreditation with Commendation

The ACCME proposes to delete three criteria and add three (or perhaps more) new criteria. But it is important to note that they also propose to allow CME providers some flexibility to select the Engagement with the Environment criteria that are applicable to their unique CME environments. While the ACCME hasn’t stated how this would be accomplished, they propose to require a minimum number of criteria to be addressed in this subset of criteria (let’s say five out of seven) but give the provider the choice of which five to address. Again, this area will be open to a number of comments and we won’t know the results for a while.

Criterion 16:The provider operates in a manner that integrates CME into the process for improving professional practice.
Proposed Change:Deleted in its entirety (but reflected in new Engagement with the Environment criteria; see below).
Discussion:The ACCME believes that C16 is redundant with Criteria 2 and 3 in that if gap analysis is managed correctly the professional practice gaps will become the basis for the activity.

Criterion 18:The provider identifies factors outside the provider’s control that impact on patient outcomes.
Proposed Change:Deleted in its entirety.
Discussion:In the past, it was often difficult to distinguish between barriers or factors that have an impact on quality, patient safety, and physician change. Often methods or content to address the barriers of C18 were consistent with those of C19. Moreover, a complete gap analysis would already have uncovered the barriers to quality and patient safety.

Criterion 22:The provider is positioned to influence the scope and content of activities/educational interventions.
Proposed Change:Deleted in its entirety.
Discussion:In our opinion, this criterion was unnecessary. Other documentation in the self-study or the new performance-in-practice abstracts will clarify whether or not the CME provider is positioned to influence the scope and content of its CME program.

Proposed Additions

New Engagement Criterion:The provider routinely demonstrates and promotes interprofessional collaborative practice in the operation of its CME program and in the design and implementation of its educational activities.
Discussion:This new criterion is institutionalizing the concept of collaboration in CME activities. It speaks to “routine interprofessional collaborative practice” and seeks to ensure that CME providers are working together in the best interest of quality and outcomes. While “interprofessional” needs further definition, we believe that it embodies both collaboration between nurses, pharmacists, and physicians, as well as between various specialties—depending on the mission of each provider and the identified needs for the activity.

New Engagement Criterion:The provider routinely incorporates patient data (for example, data from registries or electronic health records) into the process for identifying professional practice gaps and educational needs.
Discussion:In our opinion, this new criterion may be the most challenging of the new guidance for some providers, but it also creates an expectation that CME providers should be connected to real patient outcomes data in the way they plan CME. It introduces the reality of EMR and the ability of some providers to access current information. For providers without access to such information, it offers other methods such as morbidity and mortality data and registry information that will require more due diligence. While this proposed criterion appears to be challenging for accredited medical education companies in particular, it will require them to develop processes to access real patient clinic data through public registries, collaborative partners, or other EMR data gleaned from their course directors and faculty.

New Engagement Criterion:The program of CME conducts assessments of the individual’s professional competence and performance and designs and implements individualized learning activities to address the needs that were identified through the assessments.
Discussion:This advanced criterion will require that CME providers measure competence through mechanisms that are more sophisticated than commitment-to-change questions, and demonstrate that outcomes analyses results were used to develop additional CME interventions that reflected the findings of the original outcomes assessments. This criterion will move CME stakeholders toward maintenance of certification, new and creative online methods for learners to assess their own needs and individually tailor CME to those personal gaps, and toward using CME as a tool to correct critical performance gaps such as in remedial CME.

Changes to the Standards for Commercial Support

Standard 4.3:Educational materials that are part of a CME activity, such as slides, abstracts, and handouts, cannot contain any advertising, trade name, or product-group message. 
Proposed Change:Prohibit the use of corporate logos in any educational materials.
Discussion:This change is consistent with the recommendations of all organizations that have previously reviewed areas of potential bias in CME.

Standard 6.4:“Disclosure” must never include the use of a trade name or a product-group message.
Proposed Change:Prohibit the use of a corporate logo in the disclosure of the receipt of commercial support.
Discussion:This change is a parallel action to the one above.

Other Proposed Policy Changes

• Joint sponsorship: The phrase would be changed to “Joint Providership,” which in turn will impact a revised Joint Providership Accreditation Statement.
Discussion:This change serves to clear up confusion between the words “sponsor” and “provider.”

• Enduring materials: The ACCME proposes to eliminate all special language requirements for enduring materials, such as principal faculty and their credentials, medium or combination of media used, method of physician participation, estimated time to complete the activity, dates of original release and/or update, and termination date.
Discussion:The ACCME felt these requirements predated the 2006 Criteria for Accreditation and were inconsistent with learners’ current familiarity with electronic media.

• Internet CME: Similarly, the ACCME proposes to eliminate the special language requirements for Internet CME, such as listing special requirements prior to the beginning of the activity, hardware and software requirements, provider contact information, policies on privacy and confidentiality, and copyright information.

• Journal CME: The ACCME proposes to eliminate special requirements for journal CME, including the requirement to communicate required information prior to the journal activity, but that is supplanted by the general Standards for Commercial Support requirements to inform learners of disclosure information before the start of the activity.
Discussion:This change simplifies ACCME policy and removes special requirements as stated for other types of CME activities listed above.

• Regularly scheduled series: The ACCME proposes to eliminate the requirement for describing their monitoring system.
Discussion:This change recognizes that processes for compliant CME practices for all types of activities include RSS without a need for special documentation. In our opinion, this proposed change is unclear and will need to be adjusted or clarified as the monitoring of hospital or medical school departments’ application of the criteria is essential to demonstrating compliance.

Initial application for accreditation: The ACCME is proposing to eliminate the requirement that the initial accreditation interview be conducted at the offices of applicant, but is leaving in place the requirement for an activity review for initial accreditation.
Discussion:This process removes rote processes and stickers in favor of the provider stating the responses to questions the answers to which demonstrate the evidence of compliance. There will be mechanisms to paste in information, and there will be several attachments to complete each file abstract. Same amount of work, but different format.

Analyzing the Changes

While these changes will simplify and consolidate the process of accreditation and reaccreditation, they also will require some additional sophistication be added to the skill sets required to truly manage one’s CME program. These skill sets were articulated by the Alliance for Continuing Education in the Health Professions, and they can be found on the Alliance Web site: acehp.org.

For example, performance-in-practice will now be demonstrated through a template to be provided by the ACCME. This format removes the label system and the need to cull a mountain of paper to assemble documentation. Instead, the format asks providers to assess and summarize how they complied with the applicable criteria. This will require abstracting, systems thinking, and understanding of educational interventions, etc. Members of providers’ staffs who merely copy and paste lengthy needs assessments from proposals to commercial supporters will now need a detailed working knowledge to truly comprehend the needs, or be engaged in selecting educational formats appropriate to the goals of the activity, or the analysis of outcomes of their education instead of just summarizing data. It will also require providers to demonstrate in a  succinct manner their understanding of each criterion and to demonstrate their compliance with it.

The new emphasis on promoting interprofessional practice in the operation of the provider’s CME program requires a proactive approach on a systemwide basis. As providers seek to collaborate and share best practices across clinical and management operations, patient care will be improved.

Likewise, routinely incorporating patient data into the process for identifying professional practice gaps will require providers to consider the sources of relevant patient data from registries, electronic medical records, or the best way to incorporate informatics to support decision-making.

Similarly, assessing individual learners’ performance gaps and designing boutique CME experiences for individuals is available to all types of CME providers, but providers will have to optimize their creativity to develop systems and processes to enable this process to occur. This process naturally occurs in maintenance of competence processes conducted by all specialty boards as a part of recertification, as well as in AMA PRA-defined Performance Improvement (PI) activities.

Six Recommendations

As we said at the beginning of this article, the new accreditation system is at the ‘proposal-and-comment’ stage and probably won’t be implemented until late 2014 or early 2015. But in the meantime, it is prudent to give some thought to the skills and processes that your organization will need to develop. Here are some of our recommendations:

1. Consider a strategic planning meeting with your CME committee or advisory board. As a primary component to the needs assessment in planning CME, you should include in the discussion ways in which your organization can access patient data. 

2. As the ACCME moves toward individualized learning, have you considered designing CME activities that fulfill specialty board requirements for MOC?

3. In what other ways can your organization address the individual practice gaps of your learners? Will new technology be required to facilitate that process? Do you have the outcomes measurement tools in place to quantify the individualized changes that have taken place after engaging in CME?

4. Identify areas of personal growth that will position your staff, as educational professionals, to be more engaged in the process of CME. For example, do you know how to synthesize lengthy needs statements into clear, 25-word expressions of the professional practice gaps as expressed by physician planners? Do you know how to review a gap analysis, how to write learning objectives, and how to design outcomes questions that will measure improvement in competence and/or performance? Do you know how to rewrite learning objectives submitted by faculty so that they express what the learner is expected to be able to do in their practice after the CME intervention? Find a trainer or coach to help you plan personal education to hone those skills.

5. What about interprofessional education? Is that type of education indicated in your organization’s purpose and mission? If so, are you currently providing education that is only intended for physicians or nurses or pharmacists, or have you thought about how to use your CME/CPD as a tool to hone an effective care team that meets the needs of patients and their families? In other words, it’s not just about offering a lot of education for different professionals; it’s about how those professionals interrelate to advance the quality of care!

6. In terms of your CME/CPD mission statement, while we don’t advocate changing anything as yet, it is not too early to start thinking about the outcomes of your CME process. What do you want CME to achieve for your learners and their patients? How will the outcomes of your education advance quality and patient safety? How will your activities be planned to effect real and meaningful outcomes? What does that change mean in terms of the training needs for your staff and planners? Do you have the skills onboard to effect those outcomes? If not, what budget will help you achieve that goal and where will those funds come from?

To help you plan a course of action, identify your personal action steps as you consider the coming CME changes. To assist this process we have developed a worksheet that you can download from http://passinassociates.com/downloadmmm.

Steve Passin is president and CEO, Sue O’Brien and Judy Sweetnam are senior associates, and Denise Doyle is an associate with Steve Passin & Associates—based in Newtown Square, PA. Send questions or comments to Steve Passin at passin@passinassociates.com.