Compliance Reminders from Recent Accreditation Reviews

January 23, 2014
Posted by: 
Tamar Hosansky

Compliance Reminders about the Standards for Commercial Support

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

Please read – and check to ensure that your organization is in compliance. The ACCME expanded the definition of commercial interest in 2007; however, in 2014, the ACCME is finding that some providers may not have incorporated the expanded definition into their processes. 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." Some providers have not added “marketing, re-selling, or distributing” to their processes and tools. CME providers must use the complete definition.

Failure to use the complete definition could cause an accredited provider 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). Some providers that have recently been reviewed have received notice of our concerns. Other providers would be wise to evaluate their processes and determine if they have also failed to include the complete definition.

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 Q&A, please see Resources for Implementing the Standards for Commercial Support.