CME/CE Rumors- Fact or Fiction?

This is a place where rumors about CME/CE can come to be debunked...or be verified! (managed by Pam Beaton)

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Rumor: All CME providers are the same

A few weeks ago, the CME Guy served up an interesting post on his blog about "Finding Your CME Community."  In it, he mentioned a situation when he was at a MECC in which he was going through reaccreditation and was wondering if the surveyor could remain unbiased.  I realize it's a dog eat dog CME world out there sometimes, but the idea of competition between CME providers had not been something I encountered before.  

I started thinking about this again when I was preparing for a presentation on planning forms for the Alliance for CEHP Annual Meeting- I couldn't believe how many planning mechanisms are out there (and how many of them look the same) and when I got an email from a state-accredited provider- it reminded me of the days when I used to work with said state-accredited provider and how different things are from the large organizations I've encountered.  

I've always been a strong advocate for the state-accredited providers- many of whom aren't afforded the same CME luxuries as the rest of us- those who wear multiple hats (credentialing coordinator, medical staff coordinator, medical librarian AND CME coordinator), who see what big medical center is doing and get overwhelmed by the fact that they don't have the resources to do it.  Or the big medical specialty society who talk like everyone has a CME staff of 12.  

The bottom line is that for the most part, we all want to provide excellent CME to improve patient care, but how we do it is vastly different (but not necessarily wrong).  So this week when some of us meet new peers and friends, remember that they may not be doing the same things as you but may have a really cool thing that they ARE doing well.  For those of us who are unable to go, keep in touch (and reach out to people) through Twitter with the hashtag #acehp13.

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Fact or Fiction: Disclosure of commercial support.

Submitted question: Fact or Fiction: If an event does not receive any commercial support, that must be disclosed in the event brochure.

Answer: Fiction!  If you don't accept commercial support for an activity, there is no requirement that you must disclose the absence.

Although Standard 6.2 under Standard 6 of the Standards for Commercial Support requires the disclosure of no relative financial relationships to the audience, Standard 6.3 only requires the disclosure of support.  

Great question!

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Are CME activities that change knowledge alone compliant?

A wonderful peer recently posed this question to the blog:

I think there's still confusion out here about the distinction between how we design an activity and what we're supposed to be trying to measure (coming out of that individual activity).  It's difficult to measure or demonstrate change in competence as the result of an activity where the learners are from a broad community instead of being on your own staff where you can integrate systems changes and follow outcomes over time for example. 

  If I understand correctly, it's fine to design activities primarily to close a knowlege gap, but these activities should be contributing to a program level effort to change competence, performance, or patient outcomes.  The closest I come to trying to measure competence from a one-time knowledge based activity is in asking learners to respond to case presentations before and after the information is delivered (trying to show intention to apply the new knowledge), or asking if they intend to change anything about their practice in light of the new information (which doesn't usualy get me much information). 

  So my question is, for an individual activity, is it sufficient to measure change in knowlege, i.e., a pre-test/post-test?

WOW.  This is a loaded question.  Looking at Criterion 3 "The provider generates activities/educational interventions that are designed to change competence, performance, or patient outcomes as described in its mission statement" and the further clarification on the subject, activities can be designed to change knowledge as long as the overall CME program is designed to change competence, performance or patient outcomes.  

Here's what the ACCME had to say about it in a video with Dr. Kopelow.

Personally, I think there are two issues at play here.  One being that you have to plan CME activities to change competence, performance or patient outcomes, but you don't necessarily have to be successful.  There is no rule that you have to bat 1.000 with each and every CME activity.

Also, as a patient, if I go to my doctor and describe XYZ symptoms, I don't want him/her to say "I know what that is."  I want him/her to say "I know how to treat it" (competence) or "I can treat it" (performance).  Or if they need more information on how to treat it, at least it goes beyond knowing what it is (which is why I'm a big fan of internet point-of-care even though it hasn't caught on yet).

I think we need to get creative when we develop pre/post tests.  Case studies are certainly effective in analyzing changes in competence, but we can also ask more questions that are applicable to practice.  Instead of asking what something is, we can ask how it would be treated, even having more than one right answer.  In addition, having a definitive answer, as opposed to "all of the above" or "none of the above" can help us identify additional practice gaps.  Self-reported changes are perfectly acceptable, and can also help us gather some great new information!

Physicians hopefully will learn something new from a CME activity.  What they do with that information is what we should be trying to analyze...self-reported or otherwise.  

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Can levels of commercial support include exhibits (and advertising)?

My friend The CME Guy recently posted this question on Facebook:

"A program director wants to do away with charging exhibit fees. Instead, he wants to implement a tiered commercial support structure where an exhibit table is included with higher levels of support (Platinum, Gold), but not with lower levels (Silver, Bronze). Is that OK to do?"

My answer:

Nope.

Not in the least.

No.

Granted, this is a bit confusing because the ACCME DOES allow for levels of support, but under SCS 4.1, exhibits and advertising can not be a condition of commercial support (there's actually an FAQ about this).  As The CME Guy pointed out, his question wasn't specific to the written agreement, but an agreement is an agreement.  If you allow exhibits to be a part of the package for commercial support, then that would be considered non-compliance.

Exhibits and advertising are separate from commercial support, period.  That's not to say that the funds for the commercial support and exhibit can't come in the same check, but one can't be a condition of the other.  You can't force a commercial supporter to exhibit, and you can't force an exhibitor to provide commercial support.  Under the example above, it could be seen that the provider is strong arming the commercial interest into a higher level in order to exhibit.

As I've mentioned on a number of occasions, the Standards for Commercial Support Are Not So Standard.  

As always, contact the ACCME with questions.

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"All programs have to give credits?" (submitted question)

Oh wow!  This is such a great question- thank you for submitting it.

Quick answer- NO.  Not all programs have to give credit.  Say, for example, you have a great educational program that would benefit your learners, but does not fit the definition of CME (what immediately comes to mind is discussing mission work), then do it...just don't give credit.  

Or if your faculty (not employees of a commercial interest) have been a part of the research of a product or device and want to talk about it...do it, just don't give credit.  

Credit doesn't have to be an all or nothing, either.  You can give partial credit to an educational activity- you can include sessions like those above but just not give credit for those sessions (perhaps as an early morning or lunch session).

Your education is what you make it!

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Joint sponsorships automatically equal compliance with Criterion 20

I've seen (and heard) that providers assume if they joint- or co- sponsor an educational activity with another provider, they meet the requirements for Criterion 20.  I've even seen "co-sponsorship" as an exchange of organizational logos without any real collaboration.  

While it's great that CME providers are working with other CME providers, rubber-stamping a CME activity for credit is NOT building "bridges with other stakeholders through collaboration and cooperation."  Thankfully the ACCME provided clarification on this within their note on the Criterion, but as providers, we should ask ourselves how we can work meaningfully with other providers to improve the education for the learners, and consider that throughout the planning process.  We should also look beyond CME providers alone, and collaborate with other professional healthcare associations.  

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You have to have learning objectives

Admittedly, this is one of the easiest ways to demonstrate compliance with Criterion 3, but there is no requirement to have learning objectives.  

One thing to consider- you still must show how your activities are designed to change competence, performance or patient outcomes, and learning objectives are just part of that process.  When creating learning objectives, think about how the learner will actually change their practice (is it attainable?  is it reasonable?  is it measurable? is it even plausible- such as training physicians to treat the zombie apocalypse?).  How will the activity close the professional practice gap?

As always, look at the ACCME's compendium of case examples, not just for areas of compliance, but for areas of non-compliance.

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Employees of commercial interests in CME activities- now in the ACCME self-study

(Not a rumor, just an FYI)

For July 2013 Cohorts and later, the ACCME is now requiring that the provider describe in the self-study if/how employees of a commercial interest participate in CME activities.

It's on page 2- start preparing.

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The thicker the binder, the more likely we'll get reaccredited

Thanks to Sue Pelletier for this one!

The first thing I have to say is OUCH.  That ouch is for when the binder inevitably drops on my toe due to gravity and 20 lbs of paper.

When you're getting your stuff together, think like a surveyor.  Would YOU want to read through 400 pages of words to find how you address practice gaps, how you identify and resolve COI, and how you analyze your overall program (to name a few)?  Your CME program may be doing some amazing education, but when you tell your story, be concise.  Be direct.  Tell what you're doing, not a Beowulf-length epic novel.  

Tell your story, and then back it up with your evidence.  If your evidence is on one page of your planning form, there is no need to include your entire planning form (as an example).  If you have a policy attached to your disclosure form, just include the signed disclosure part.  

Same thing goes for your activity files- include what you need for the labels- there is no duplication.  More doesn't necessarily mean better.

Take your time, and if you need help- ask the ACCME, go to one of their workshops, or if you need it, hire someone!

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Space and place- What's the deal?

The SCS strike again!  This question keeps coming up over and over- either through written comments or hallway discussions like at the 23rd Annual Conference of the National Task Force on CME Provider/Industry Collaboration meeting (some of us only made it to the hallway).  Unlike that meeting, the space and place issue is often a back and forth between providers and industry.

The ACCME provided some guidance about space or place related to SCS 4.2, and more in the compendium about what I can only assume were poster abstracts (but I could be wrong).  

My understanding- educational space = no promotion.  Anywhere outside of that = promotion.  Sounds very simple, but there's no "50 feet from entrance" rule.  

I think as CME providers, there's the tacky aspect and the non-compliance aspect.  It's up to us to decide how high we want to set the bar.

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Rumor- You have to have public health data to find practice gaps

I have no idea where this rumor started- maybe by the statisticians who gather and disseminate all the data...perhaps they want to feel needed?

In any case, much like it is for other criteria, how you identify your professional practice gaps is up to you.  Survey your physicians.  Look at trends (the current meningitis outbreak is a perfect example).  Look at past evaluations (you have to anyway for C11).

Find what your learners don't know, what they don't know how to do, or what they are not doing- that's your gap.  For public health data- that's great, but you have to determine whether or not that is truly a gap of your learners, or just something that's occurring (if there is some weird salmonella outbreak and the doctors in the area know how to adequately treat it, that's not really a gap.  The gap is clearly in food handling and whatnot).  

Then determine how to address it- do they need more information, more training, more...?  That's your need.

As was mentioned at the ACCME's August Bridge to Quality workshop- keep asking why.  Ask your learners why they want/need the education.  Is it because they want free food or is it because there really is a problem?  Only your learners can "tell" you that- the data alone doesn't have those answers.

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Rumor- Only docs can be faculty

In this day and age, this rumor shocks me, particularly with the advancement of continuing education in the health professions (plural and thank you Alliance for Continuing Education in the Health Professions for being more inclusive)...but the answer is no.

I've been faculty in multiple CME activities about CME.  Nurses can teach doctors.  Techs can teach nurses.  Doctors can teach techs.  With interdisciplinary teams, they all have something to learn from one another.  I've heard some activities actually get PATIENTS involved.  It's not mass hysteria!

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Rumor- You must use a disclosure form

I was going to combine this question with others related to documentation, but realized that the answer could go on to the middle of next week.

So I'm just going to tackle this one and another.

The rumor out there is that you HAVE to have a form to collect disclosures.  Not true.  You just have to show that everyone in a position to control content has disclosed all relevant financial relationships with commercial interests within the last 12 months to you as the provider (SCS 2.1).

I will admit that a form is the standard way, but nowadays with electronic systems, you can do it that way as well (I've built a nice disclosure system in SurveyMonkey in the past which has the date stamp on it- as long as you make sure the individual has to "sign" it).

I've also done a disclosure roll call during planning committee meetings.

The takeaway is this, however: everyone in a position to control content must disclose: faculty, moderators, session chairs, program chairs, planning committee members, some staff (depending on their involvement), etc.  

The second takeaway is that you must have a mechanism to resolve the identified conflicts of interest that came out of your disclosures.  But that's a post for another day.

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Rumor- Employees/Owners of a Commercial Interest can participate in ANY CME activity as long as they disclose and their content is reviewed

Recently I was having the discussion (okay, okay...it was a heated discussion) about whether or not employees/owners of a commercial interest can participate in ANY CME activity (regardless of the topic) as long as they disclose their employee/ownership status AND their content is reviewed prior to the start of the activity AND there is an independent monitor in the room making sure the speaker is unbiased.  Apparently there is a rumor going around that this is okay.

I think the key here is the content.  If a dude owns a company that makes a distal radius plate (so under the definition of a commercial interest) and he's talking about forearm fractures (my personal favorite kind of fracture), then um...no.  If he talks about a 5th metatarsal fracture and his company ONLY makes distal radius plates, then maybe.  If he's talking about continuity of care before the patient gets to the surgical suite, then maybe.  If he's talking about disaster management, which is the ACCME's example, then yes.

The further argument was about the "scientific or discovery process."  I think that process is not as long as some would like to believe- and some faculty would like us to believe.  As soon as it gets into the delivery of care to the patient- and that product or device could be introduced into the content (verbally or in written form)- then it falls under the "probably not a good idea because someone may complain about you" area.

For more: http://accme.org/ask-accme/can-employees-commercial-interests-serve-planners-or-speakers-our-accredited-cme