This is the third in a three-part series on the accreditation process for CME providers. The first details the ACCME's accreditation process. The second provides tips on achieving Accreditation with Commendation.
Even good CME providers can find themselves receiving a progress report requirement or being put on probation after the Accreditation Council for CME finds that they made mistakes or omissions that left them out of compliance. Fortunately, these are preventable conditions.
The most common reasons providers are required to submit a progress report, according to the ACCME’s Chief Executive Murray Kopelow, MD, are related to noncompliance with elements of the Standards for Commercial Support, although compliance rates have increased significantly over the past two years. One that often trips up CME providers is Criterion 7 (SCS 1, 2, and 6), which states that the provider must develop activities/educational interventions independent of commercial interests. Of course, you first have to know the ACCME definition of a commercial interest, which is: “A commercial interest is any entity producing, marketing, re-selling, or distributing health care goods or services, consumed by, or used on, patients.”
One of the most common mistakes providers make with this Criterion, Kopelow says, is not recognizing that it’s not just the faculty or authors whose conflicts of interest must be disclosed and resolved, but also those on the planning committee and content reviewers—anyone who could potentially influence the content of the activity.
To be compliant, the provider must control all aspects of the planning, presentation, and evaluation of its CME activities, obtain all the necessary disclosures, implement a mechanism to resolve any conflicts of interest, and let the learners know about any relevant financial relationships held by all who control the CME activity’s content.
Kopelow says that it may get easier to get the proper disclosure information, which up until recently was purely the responsibility of the CME provider. Now that the American Medical Association has adopted its Council of Ethical and Judicial Affairs 1-A-11 report entitled, “FinancialRelationships with Industry in Continuing Medical Education,” which calls on physicians to also abide by guidelines similar to the ACCME’s SCS, the hope is that and other physicians involved in the activity will feel more responsibility toward the disclosure process.
Another common error providers make is failing to articulate the educational needs that underlie the professional practice gaps the activity is created to address, as required by Criterion 2. According to Kopelow, providers sometimes have a difficult time understanding the difference between the practice gap and the need that underlies the practice gap. Put simply, the professional practice is the problem in practice the activity is seeking to solve. The educational need is the potential cause of the problem—does the learner need to know more, need to have different strategies, or do something differently? The articulation of the cause of the problem would be the educational need—knowledge, competence, or performance—that underlies the problem.
The ACCME’s Dion Richetti, and Pam McFadden, University of North Texas, made the distinction with this example in a presentation they gave at the 2012 Alliance for Continuing Education in the Health Professions. They began with this healthcare problem: Medical conditions common with Down Syndrome can contribute to high obesity rates and, while these kids’ genes may make them more prone to obesity, recent independent studies have found that they can make food choices that will help them reduce their body weight when given the right instruction from parents and their healthcare providers.
It’s not enough just to demonstrate that kids with DS are prone to obesity and that new data suggests that education can help lower their body weight. Now the accredited provider should figure out the practice gap, if there is one, for their learners.
In this example, the professional practice gap (or problem in practice) can be stated this way: Children with DS tend to learn more visually and more through repetition than their peers, but most healthcare providers haven't been trained to teach to their needs. Because they don’t teach the kids with DS appropriately, the kids don’t get what they need from many of the existing nutrition education programs.
Be sure to clearly identify the gap between current clinical practice—HCPs not using the most effective methods to teach kids with DS about nutrition—and that ideal, evidence-based practice in which HCPs use current patient educational methods and updated educational materials to effectively teach children with DS how to make appropriate nutrition choices.
So, what’s the education need that underlies the observation that HCPs are not using the most effective methods to teach their patients with DS about nutrition? It might be that the HCPs don’t know about the learning differences of kids with DS. It might be that HCPs don’t have the right strategies in place to teach their patients with DS about nutrition. It might be that the HCPs know about the learning differences, have the right strategies, but don’t have time during the encounters with their patients to implement those strategies. The educational need could be knowledge, competence, or performance or some combination of the three. By examining the problem in practice in this way, the accredited provider is better able to plan and implement an effective educational intervention to help solve that problem.
Coming Into Compliance
The first thing providers need to do to bring their programs into compliance is to understand what is being required of them, Kopelow stresses. Either Kopelow or ACCME Deputy Chief Executive and Chief Operating Officer Kate Regnier, MA, MBA, holds a phone call with the leadership of every organization that goes on probation, and ACCME holds group calls with every organization that is required to do a progress report.
“They need to attend those calls and understand what the requirements are, then they have to go do it right, and be able to show it. Those are the three things they have to do to get into compliance,” says Kopelow.
CME providers need to develop a plan and outline the specific tactics and action plan they intend to take to modify their CME program to meet ACCME's expectations, said Richetti and McFadden in their session. And, they said, providers should take advantage of this opportunity to measure what is and isn’t working as they go through the process using the Plan-Do-Study-Act, or PDSA model to chart their progress. Implementing this plan can also support their compliance with Criteria 12 through 15. Begin the process with the end in mind, Richetti and McFadden emphasized.
Criterion 15, which requires the provider to demonstrate that it is measuring the impacts of the needed program improvements, must be addressed as part of the improvement process and not as an afterthought. Describe what you’re doing to improve your program, and provide evidence that you’re doing it. As Kopelow says, “Ask yourself what you’re doing to show that you’ve made the improvements. Most providers already have the necessary paper trails built into their process; they just have to show us.”
When it comes to probation, some organizations just come unraveled. They lose their staff, their funding, or both, and they just can’t bring about across-the-board compliance. The rest tend to be organizations that haven’t learned from their past mistakes, says Kopelow. They were found out of compliance the last time they came up for accreditation, received a progress report requirement, fixed the problems, and then two years later are found to be making the same mistakes. That’s not fair to the other providers, Kopelow says.
This is the third in a three-part series on the ACCME accreditation process for CME providers. The first details the ACCME's accreditation process. The second provides tips on achieving Accreditation with Commendation.
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