The Case:
Dynamic Data Dissemination (D3), an Accreditation Council for Continuing Medical Education–accredited publishing company, conducts several hundred CME activities each year. About a quarter of these activities are jointly sponsored with Savvy Science, a non-accredited medical education organization that is part of a large group of companies. The relationship has been successful and lucrative for both organizations.
Savvy Science’s parent company reorganized in early 2013. Danny Diligent, D3’s CME director, has requested confirmation that Savvy remains eligible to jointly sponsor CME activities and that its new organizational structure has not created a commercial interest, or CI. Danny feels concerned when his second request for confirmation goes unanswered. He is worried that Savvy’s new structure may prohibit future joint sponsorship but wants to give his educational partner the benefit of the doubt. Could Savvy simply not understand the rationale for the request and the importance of the response?
Danny realizes it is time to kick off the planning for several new activities to be jointly sponsored with Savvy, and he grows more concerned when he discovers that commercial support for all the new activities will be provided by the same grantor. Does Savvy have a relationship with the grantor? He reaches for his antacid as he picks up the phone to call Savvy’s president.
Is Danny right to be concerned?
Overstreet: Yes! Danny wants to continue planning activities with them, but he must protect his accreditation and the integrity of his CME program. The provider is responsible for ensuring that all ACCME criteria are met, so Danny needs to be confident that Savvy is eligible for joint sponsorship.
Parochka: I agree. Having commercial support provided by a single company begs these questions: What relationship does the joint sponsor (and its sister or parent companies) have with the grantor? Are these activities promotional or educational? How should providers determine if their joint sponsors are CIs?
Overstreet: Providers need to ensure that joint sponsors—and others who can control or influence content—are not CIs. The ACCME does not prescribe how to determine eligibility for joint sponsorship; providers have to select and implement their eligibility-determination method based on their risk tolerance, and knowledge of and comfort level with potential partners, along with other factors. Some require a signed attestation that the entity is independent from CIs. Reviewing the potential partner’s Web site and marketing materials also may shed some light on its business model.
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Parochka: Several years ago, the National Association of Medical Education Companies and the Society for Academic CME developed an attestation form that could be used to determine whether a medical education company fit the definition of a CI. While a positive step to identifying relationships with CIs, proof of the company’s structure was not a mandatory component of the process. Accredited providers could require potential joint sponsors to have their administrative structure reviewed by ACCME. Having a copy of ACCME’s response in the activity files would go a long way toward documenting an educational partner’s eligibility. If joint sponsors balk at the cost of the ACCME review, providers might consider requiring that content be peer-reviewed independently before certifying jointly sponsored activities for credit. (The joint sponsor would need to be forewarned that allocation of credit may be denied based on the peer-review findings.)
Karen Overstreet, EdD, RPh, FACME, CCMEP, is a medical education consultant in Raleigh, N.C. Reach her at [email protected]. Jacqueline Parochka, EdD, FACME, is president and CEO, Excellence in Continuing Education Ltd., Gurnee, Ill.; and partner, PTR Educational Consultants. Reach her at [email protected].
