The Accreditation Council for CME content validation policy, which stirred up a ruckus in its draft form earlier this year, is still provoking questions since its release as a policy in September (see box on page 15). The final policy dropped the draft's requirement that providers document and include in their self-study report the evidence supporting their presenters' recommendations.
However, says Frederic L. Jackson, DO, president and CEO of the Fort Wayne Medical Education Program in Fort Wayne, Ind., “Thepolicy mitigates the burdensome nature of the new rules, but again, they have left it to the CME providers to try to interpret what the rules mean — and to suffer the consequences, through adverse accreditation actions, if they guess wrong.”
“This is the biggest perceptual problem we're seeing,” says Murray Kopelow, MD, chief executive of the Accreditation Council for CME. “Some providers' immediate response is, ‘How are you going to use this for accreditation? How are the surveyors going to handle it? How are we supposed to document compliance?’ My answer is that this isn't an issue for accreditation: the surveyors aren't going to talk with you about this, and you don't need to document compliance. The policy is a set of value statements that define an outcome for your CME, a goal you need to aspire to.” But, he adds, “We want to see 100 percent fulfillment of that goal.”
Kopelow says the ACCME will use a “red flag” type of surveillance system. If surveyors “happen to see something that 99 percent of the world accepts as chicanery, they'll tell us,” he says. ACCME then would follow up with the CME organization to ensure that it has some kind of system set up to ensure that patient care recommendations in its CME activities are based on evidence.
To Sylvia Scherr, RN, executive director of CME/CE with the National Institutes of Health Office of Education, Office of Intramural Research, Bethesda, Md., Statement 1 is “still poorly written, because it still includes ‘based on evidence that is accepted within the profession.’ However…the intent is that recommendations on clinical care be valid; exactly how we accomplish this is our decision.may just need to know that there must be evidence that supports their recommendations; it doesn't say that they have to explicitly incorporate that evidence, or levels of evidence, into presentations.”
Kopelow stresses that the recommendation itself doesn't have to be accepted by the industry, but the evidence it is based on does.
Another thing about the policy some providers take issue with: When the draft proposal came out earlier this year, about half the comments the ACCME received said the proposal was insulting and/or burdensome. The other half said their programs were already ensuring content validity. Jackson comments that the ACCME “apparently passed the statements over the objections of almost half of the constituency.… National politics notwithstanding, I think that a 50/50 vote is not an endorsement.”
Kopelow replies that the half who opposed the draft proposal “were against what it doesn't say — they said, ‘We don't have the ability or the resources to vet all the content before it comes out of the speakers' mouths.’ What they were saying was, ‘We agree with the principle, but…’ So we took out the ‘but,’” Kopelow explains. “Now there's just the principle that everyone agreed with.”
For those who said it was insulting to suggest to faculty that they back up their patient recommendations, “there's a place to assert yourself as a CME provider,” says Kopelow. “You can't just be deferential. Otherwise, you could have faculty basing recommendations on just their firmly held beliefs. The intention isn't to ‘get’ anyone,” Kopelow emphasizes. “The intention is to ensure that CME keeps moving in the right direction.”
While he recognizes the need for rules to keep CME presentations useful and unbiased, Jackson still believes the wording of the value statements are subject to misinterpretation — “Anytime it takes you a half-page statement to explain a one-sentence policy, then the policy is unclear,” he says. “I just think these new rules are more window dressing than clear guidance.”