ACCME guidelines for accreditation of CME providers have recently undergone significant revision. However, the ACCME's position regarding eligibility for accreditation has remained unchanged.
It is our position that the ACCME must adopt minimal standards of eligibility and limit accreditation to the medical institutions licensed by the state and responsible for undergraduate medical education and postgraduate resident training, as well as the specialty societies and state medical societies that comprise the medical profession.
Argument 1. Education vs. Promotion: SMCDCME [Society of Medical College Directors of CME] was a leading party to the extensive negotiations and agreements with the FDA [Food and Drug Administration] concerning the distinction between promotion and education. Since a significant portion of educational funds for CME is provided by pharmaceutical manufacturers, the FDA was rightly concerned that organizations directly sponsoring CME not be influenced by these commercial supporters and that their educational offerings be fair and balanced, objective, and free of bias. Hard won concessions of safe harbor were obtained from the FDA after much debate. The FDA agreed to rely on and accept the accreditation system of CME providers. It was established that accredited CME providers were to guard and protect the public interest by preventing undue influence from for-profit corporations on the content of accredited programs. This resulted in a delicate balance between what would be considered "promotional" activities--in which the pharmaceutical companies and medical device manufacturers were permitted to continue--and the "educational," which became the responsibility of accredited providers. The FDA was led to believe that the medical profession had agreed to police itself.
The ACCME continues to accredit pharmaceutical manufacturers, the advertising agencies who are under contract to promote their products, as well as a host of other for-profit companies. Have we, as academic medical center representatives, violated the public trust by not speaking out to restrict the accrediting of these corporations?
2. Mission: The mission of CME providers is to educate physicians in order to enhance the public health. This is not the primary purpose of commercial corporations, nor is caring for patients. Their primary commitment is to generate profits for their principals which is reflected in their internal organization and structure. Medical colleges, academic medical centers, and specialty societies, as well as hospitals, are part of the larger medical profession and are committed to scientific and objective education and its application to patient care. For this reason, they are licensed to educate physicians, provide care, and are entrusted with the responsibility to establish guidelines and standards for medical procedures.
3. Academic Standards: Education of the highest quality is a major goal of all academic medical centers and professional societies. Various mechanisms exist to assure quality, scientific rigor, and objectivity. These include a faculty of clinicians and researchers, academic leadership, external evaluations, peer review, departmental appraisal, faculty committee control, and, in some cases, Dean's approval. In addition, State licensing requirements and periodic review apply to teaching institutions and professional certifying bodies. Mechanisms for careful and meaningful educational review and criticism are not ordinarily part of the structure and tradition of commercial corporations.
4. Continuum of Medical Education: Each academic and patient care organization and each professional society that comprises the ACCME subscribes to the principle of a continuum of education to provide and promote lifelong learning for physicians and other health care professionals. This concept is fundamental to CME since learning must not end after formal schooling or residency training if the public good is to be served. Maintaining the clinical competence of members of the medical profession is clearly the responsibility of the schools of medicine, teaching hospitals, and professional societies. Eligibility for CME accreditation must be restricted to those medical institutions and organizations whose primary mission and social responsibility is medical education and health care.
5. Restraint of Trade: All accrediting agencies should and do set standards which are intended to restrict membership to those entities that satisfy their eligibility criteria and for whom credentialing would not be contrary to the public interest. We, as medical educators, should maintain eligibility requirements for CME accreditation. We believe that it is perfectly reasonable and appropriate for the Accreditation Council to protect and preserve standards which restrict those for-profit, non-medical, non-licensed companies from receiving credentials as physician educators.
The non-professional business organizations should not continue to receive ACCME's imprimatur as "accredited medical educators." These for-profit entities hold non state-issued licenses and have no direct responsibility for patient care or medical education on the undergraduate or graduate level. By granting these businesses accreditation, the ACCME is, in our judgment, not serving the medical profession or the public. The creation of a "Physician Advisory Board" by a commercial company is no substitute for the tradition of the academic medical center, hospital, or professional society. It is important to state: We do not call for the elimination of these commercial business organizations; they have great expertise and serve very useful purposes in the development of promotional literature and lending their expert logistical support to activities developed and sponsored by appropriate educational institutions.
What Should Be Done It is clear that communication companies, publishers, pharmaceutical corporations, and other commercial entities which do not have education and medical care as their primary purpose must be excluded from offering accredited CME. Heretofore, these companies have been granted accreditation and have been permitted to offer CME, thereby allowing them to enter an arena occupied by medical schools, academic medical centers, community hospitals, and medical societies whose main purpose is either education or medical care. To continue to allow various non-professional business entities to offer accredited CME would be to perpetuate a practice which is in conflict with our responsibility to provide physicians and the profession unbiased, high-quality continuing medical education.