Confidentiality of information in accreditation of continuing medical education is important. Let’s talk about this for a moment. ACCME some time ago made it clear that accredited providers and the ACCME system needs to be compliant with HIPPA.
So, ACCME will not allow you to forward to us any patient-identifiable information for the purposes of your accreditation. And you cannot keep as a part of your records of continuing medical education patient identifiable information. That’s confidential information and ACCME shouldn’t have it and doesn’t need it, and neither do you as an accredited provider for your continuing medical education function.
Another area of information that is confidential is performance measures of individual physicians, professionals and learners. Or performance measures of institutions. It is those data that are important sources of performance gaps, professional practice gaps in continuing medical education and it is wonderful and appropriate for accredited providers to use those data, but you do not need to forward those to the ACCME as proof that you’re using professional practice gaps or performance measures from institutions or individuals. If you have 10 physicians, all of whom have performance measures on an individual parameter of certain type of care, their percent of times that they do it properly, and the mean of that is below the national average— it is perfectly appropriate for you to say to the ACCME: We use such and such a performance measure for our physicians and use that as a professional practice gap to design activities. And in our institution, the overall care on average is below national averages and we’re trying to address that. That qualitative information is perfectly appropriate as a professional practice gap for the individuals and for the institution as a whole. So you can translate data into information and information into knowledge about an organization. Use that in a qualitative way as a description of your professional practice gap, retaining confidentiality for your institutions and your persons, keeping those individual numbers out of your records and still showing the ACCME that you’re basing your education on valid, timely, professional practice gaps.
