Dee Dee Middleroad, MD, MBA, has been director of CE at the University of Quality Tenets for four years. In anticipation of drafting UQT's reaccreditation self-study, she contacted the accreditation agency to clarify one of its recently revised criteria. After a lengthy discussion, the accreditor's provider liaison sent a follow-up e-mail describing appropriate protocol. Dr. Middleroad then ensured that all activities being developed complied with the accreditor's interpretation, and she shared the e-mail with her staff and other CE colleagues, who made sure their accreditation processes were likewise in order.
Eighteen months later, after an uneventful site visit during which the surveyors indicated no compliance problems, Dr. Middleroad received a finding of non-compliance and a request for a progress report due in three months. Her analysis of the accreditation decision indicated that the adverse finding was based on a practice implemented according to the e-mail she received previously from the accreditor. Upset, she called the accreditation agency and was told that her interpretation was not current and that the noncompliance finding was correct. What should she do now?
Fight for Fairness
Parochka: Regulatory agencies continually change their policies and procedures, and accredited providers are expected to keep up-to-date accordingly. Unfortunately, if accreditation changes are not communicated to the entire provider community via newsletters, e-mails, or other dissemination vehicles, program officials mistakenly believe their processes are current.
Overstreet: The lack of clear communication here raises several important questions: Is electronic communication from accreditors considered “policy”? Which accreditation agency staff have authority to provide interpretation for providers? If an interpretation is clarified for one provider, how should other providers be made aware of it? It would be a great service to the CME enterprise for accreditation agencies to ensure transparency and consistency and to clearly address these important issues.
Parochka: Most accreditation agencies have an appeal process that provides programs an opportunity to challenge adverse accreditation decisions. In this case, the CE director has documentation of the accreditation agency's interpretation, which should serve as an opportunity to file an appeal. Program officials have the right and responsibility to ask questions and appeal accreditation decisions. Operating from a position of fear is unnecessary and unwarranted, as long as the accreditor's appeals process is fairly implemented and well understood by all stakeholders.
Overstreet: This case is a great illustration of the importance of documenting all correspondence with accreditation agencies. Filing important communication in relevant project files is critical, especially in an environment in which the rules change rapidly and their interpretation even more quickly. These issues become more problematic — not to mention costly — for providers as accreditors are being pressured to enhance their monitoring processes and are considering sweeping changes to the accreditation system.
Karen Overstreet, EdD, RPh, FACME, CCMEP, is president, Indicia Medical Education LLC, North Wales, Pa. Reach her at Karen.Overstreet@indiciaed.com.
Jacqueline Parochka, EdD, FACME, is president and CEO, Excellence in Continuing Education Ltd., Gurnee, Ill.; and partner, PTR Educational Consultants. Reach her at JacquelineParochka@comcast.net.