Respondents to the Accreditation Council for Continuing Medical Education’s call for comment came out in favor of a proposal made in January to keep the identity of accredited CME providers confidential as the council investigates allegations that one of their activities is in violation of
Forty-one of the 50 comments collected during the six-week comment period and posted to accme.org April 29 agreed that the names of organizations going through the ACCME’s Complaints and Inquiries Process should remain confidential. The majority also approved of the other two parts of the proposal: that a change in status that results from the Complaints and Inquiries Process should be made public, but not the reason for the change; and that the council can make public “some of the facts, circumstances, and findings of the Complaints and Inquiries Process in a form and manner that is instructive to providers and stakeholders without linking the information to a particular accredited provider.” Seven respondents approved of some aspects of the proposal and suggested additions and improvements. Only one commenter came out against it.
Balancing Transparency and Discretion
One recognized accreditor, the Florida Medical Association, said it supports the the proposal “because it achieves an appropriate balance between transparency and anonymity of providers.” That balance is essential, said several commenters. Too much transparency during the complaints process could be used by those filing the complaint or by the media to “malign a program and/or supporter—particularly if this information is taken out of context,” as the Alliance for CME pointed out in its comments. An accredited provider went further, saying, “The Complaint and Inquiries Process should not be played out in blogs and the media.” It’s fine to provide some information on a need-to-know basis, said the Wisconsin Medical Society, but it shouldn’t be used to “embarrass or demean a CME provider for competitive reasons.” The society was generally in favor of the proposed changes.
One commenter added that it is important to keep the process confidential because accredited providers should be judged by their full CME programs, not have their reputations suffer because of a single activity, something that the Association of American Medical Colleges also pointed out in its comments. Norman Kahn, MD, executive vice president and CEO of the Council of Medical Specialty Societies, said, “Lack of compliance of a single activity is not necessarily reflective of a provider’s compliance with all the criteria for all activities of a provider’s program.”
However, going public with any changes in the accreditation status of a provider that results from the Complaints and Inquiries Process is a good idea, said the majority of commenters, including CMSS. As the Association of American Medical Colleges said, “When a provider's status has changed as a result of a full accreditation review, public release of that information is crucial to transparency.”
Some were concerned that the proposal doesn’t go quite far enough, though. Lilly USA, the only commercial supporter to comment on the proposal, was generally supportive, though it suggested that the reason behind a status change should also be disclosed. “Without qualifying a categorical reason for the status change we feel the report would generate more questions than answers,” said the Lilly commenter. An accredited provider added, “I think the reason for the change in status should be disclosed. Sunlight is the best disinfectant.” Another provider said it really doesn’t matter much one way or the other: “Once supporters learn that you are on probation, your chances of winning continued funding decreases quickly.”
Because a change in accreditation status also could affect a letter of agreement with a commercial supporter, Lilly USA also recommended that ACCME disseminate the information in a report, on a specific area of the council’s Web site, or via e-mail, similar to how it notifies interested parties about its calls for comment.
Many said they approved of being able to use the results of the process to educate the CME community, as the third piece of the proposal would allow them to do. As one accredited provider said, it “will help identify gaps in the process and challenges in compliance for program providers.”
The lone voice of dissent said that nothing less than full disclosure would do. “For those providers who struggle each and every day to do the right thing, it is unfair to let those who bend the rules, do what they want, take enormous sums from pharmaceutical companies, and then pretend not to be influenced. Why should a provider who has been found to be in noncompliance with the criteria be allowed to hide?"
The ACCME’s board of directors will discuss the proposal and responses when it meets in July.