Compliance reminders from recent accreditation reviews
When we conduct accreditation reviews we seek to identify recurring issues that need to be brought to the accredited provider community’s attention for correction. We bring the following examples and resources to your attention in order to support your efforts to meet ACCME requirements.
- Commercial interest definition: The ACCME expanded the definition of commercial interest in 2007. The current definition reads: “A commercial interest is any entity producing, marketing, re-selling, or distributing health care goods or services consumed by, or used on, patients.” Please make sure you use the current definition in your policies and forms, including disclosure forms. Failure to use the full definition could cause your organization to partner with an ACCME-defined commercial interest; collect incomplete information related to the relevant financial relationships of those in control of content, and therefore not resolve all conflicts of interest; and/or not disclose all relevant financial relationships to learners. This could lead to one or more noncompliance findings in Criterion 7 (Standards for Commercial Support 1, 2, and 6).
- Resolution of personal conflicts of interest: When obtaining disclosures from all those in a position to control the content of a CME activity, make sure to ask for information about all relevant financial relationships— not significant financial relationships. The ACCME defines relevant financial relationships as financial relationships in any amount. The word significant suggests an amount of relative value, rather than an amount of any value. Therefore, if you use the word significant, you may not obtain information about all the relationships the ACCME deems relevant, as required by Standard for Commercial Support 2.1. In addition, make sure that you explicitly request disclosure of the relevant financial relationships of the spouses or partners of everyone in a position to control CME content.
- Independence: Accredited providers are prohibited from allowing commercial interests to control CME content by influencing decisions made about faculty, including faculty selection, and by providing assistance in the preparation of activity materials. If you have a policy that allows you to accept guidance from commercial interests, and you act on that policy, you will be found in noncompliance with Criterion 7 (Standard for Commercial Support 1.1).
- Ensuring Independence in CME about Discovery/Research: The ACCME recognizes that it is important for accredited CME to include reporting about discovery and research and appreciates that providers face complex challenges when determining how to integrate this content into accredited CME while safeguarding independence. The ACCME has issued guidance for these circumstances. If you include employees of ACCME-defined commercial interests as faculty or planners in accredited activities that address the commercial interest’s research, you must have a rigorous system of internal controls in place to ensure independence—or your organization will be found in noncompliance with Criterion 7 (Standard for Commercial Support 1.1–Independence).
For more information, including links to tools, sample forms, and FAQs please see Resources for Implementing the Standards for Commercial Support.