Welcome to the February 2026 edition of AOE’s Monthly Newsletter. This edition of AOE Compliance Connection includes commonly asked questions (and answers!) on the Annual Reporting process, guidance on determining eligibility, and helpful tips for curating effective learning objectives.
In addition to our monthly newsletter, check out AOE’s weekly compliance tips for quick, applicable advice your team can use for compliance success.
Accreditation Board Bulletin: ACCME Annual Reporting
In anticipation of the 2025 Annual Reporting deadline on March 31st, AOE is sharing answers to some of the most commonly asked questions we receive each year. If you are newer to the annual reporting process, or simply in need of a refresher, see below for helpful reminders.
What is the “Internal ID”? The Internal ID is a unique code or identifier that your organization creates. It is used in combination with the data in the Activity Type and Activity Date fields to uniquely identify your activity records. As a reminder, providers should not use their assigned seven-digit provider ID number as an Internal ID, (since this number would be the same for all activities you provide).
The Internal ID field is optional, except in the following cases:
- When your organization offers multiple activities in the same format on the same date
- When entering activities via batch upload or web services
- When the activity offers Maintenance of Certification (MOC)
Is it better to enter our activities manually or batch upload them in a spreadsheet? There is no “better” way but consider the size of your program and activity types. Entering information manually tends to be manageable and preferable for smaller programs or providers that need to fill in MOC information. Batch uploading tends to be more efficient for larger programs, and especially robust providers might utilize multiple spreadsheets.
We keep a running internal spreadsheet of all our program activities. Can we utilize that for upload? No. It’s critical to use the official PARS spreadsheet template exactly as provided and file your activity details in there. Any alterations to the template might impact your data and complicate the upload process. This is also true for the Maintenance of Certification (MOC) template.
What do the “Record Action” selections mean? Record action refers to what PARS should do with the activity being reported:
- Add = this is a new activity that launched in 2025 and should be added to PARS records
- Update = this activity has already been registered in PARS, but new data is available for 2025
- Delete = this activity needs to be removed entirely. Selecting this option will wipe any record of it in PARS—so exercise caution. An appropriate use of this selection would be if you formerly planned an activity and ultimately, it was canceled/did not come to fruition.
Do I need to add my enduring material activity each year of its 3-year term? For enduring materials, you will add the activity once (during its initial release year) and then update the activity with additional learner counts each subsequent year of its term. So, if your enduring material activity didn’t launch in 2025, don’t add it in PARS this year—just update it with learner counts in 2025.
Check out ACCME’s Annual Reporting details and helpful resources here.
Compliance Help: Eligibility
Eligibility is a core pillar of ACCME’s policies and Standards for Integrity and Independence in Accredited CE, dictating which organizations can apply for accreditation and how they must conduct their programs to maintain it. Most notably, a provider’s compliance with Standard 3: Identify, Mitigate and Disclose Relevant Financial Relationships largely depends on their ability to accurately determine eligibility—though their failure to do so can threaten their compliance with other standards, too.
Considering the current era of convoluted corporate structures, subsidiaries, start-ups and complex service and product offerings, determining eligibility may feel like a more complicated process than ever before. For clarity, here are AOE’s key steps for a simplified approach:
Start with the basics. Whether you’re applying for Initial Accreditation, vetting a potential joint providership partner, or reviewing a company listed in disclosure information, start by reviewing ACCME’s eligibility definition and Structured Self-Assessment questionnaire. This review should provide clarity for most organizations; any “yes” answers will prompt further analysis.
Review parent companies. If the organization being reviewed has a parent company, defined as “a separate legal entity that owns or fiscally controls the organization,” check to see if the parent company meets the definition of an ineligible company. If it does, you have your answer.
Review sister companies. If the organization being reviewed has a sister company, defined as “a separate legal entity which is a subsidiary of the same parent company that owns or fiscally controls an organization,” take a pause. If the sister company is completely separate from the organization under review, they might be considered an eligible company. This means:
- No shared management, employees or governance structure
- No sister company personnel involved in planning, developing, or implementing educational content for the organization
- No sister company involvement in the operations for the organization
Run a process checkpoint on biomedical startups. If you’re reviewing a biomedical startup company, the key factor is whether or not it has entered a government regulatory process. Depending on the product type, ACCME’s key examples for U.S. based biomedical startups include:
- Prescription drugs and biologics companies that have entered an Investigational New Drug (IND) application
- Medical devices/in-vitro diagnostics companies that have begun a Premarket Submission process with the FDA
- Over the counter drugs companies that have submitted an application or Over-the-Counter (OTC) Drug Review (OTC drug monograph) to the FDA
Take a careful look at diagnostic labs, pharmacies and software/game developers. These organizations teeter between eligibility and ineligibility; the decisive push comes from proprietary products and hardware. When reviewing these organizations, scour for the following:
- Diagnostic labs that sell proprietary products = ineligible
- Compounding pharmacies that manufacture proprietary compounds = ineligible
- Software or game developers that pair with a device/wearable component = ineligible
Beware of third parties. If you’ve still got your magnifying glass on the organization, check to see if it serves as a third-party administrator of a prescription drug program (a Pharmacy Benefit Manager). These companies can work with a variety of health plans and benefits programs and are considered ineligible.
It is essential for accredited providers to iron out their approach for determining eligibility. A clear approach ensures your accredited CE program will meet ACCME’s requirements, and you’ll avoid sinking precious time and resources into the deliberation process!
CE/AOE Community: Learning Objectives
Alliance’s official publication, Almanac, featured an online article last month on a subject inextricably linked to effective accredited CE: learning objectives. The value of a well-written learning objective (and consequence of a poorly written one) is top of mind for continuing education professionals engrained in the educational planning process.
As important as effective learning objectives are in guiding accredited education, we frequently see objectives that are neither clear nor measurable. Author Stephanie Johnson, PhD, is spot on with the “why”—learning objectives look simple, but they can be “deceptively challenging” to write. We agree, which is why the AOE team embraces the approach of starting with the end in mind: what is the desired outcome of the activity, and what verb provides a clear, effective way to measure it? Is it clear from the start how fulfilled learning objectives will materialize in the evaluation tool for the activity, or is it still hazy?
Johnson dives into traditional frameworks and outcomes methodologies that guide educational design, along with tips for writing effective learning objectives (i.e., use of one, actional, measurable verb and one main idea, as well as alignment with the audience’s needs). More tellingly, she includes the common (and sneaky) pitfalls we are all capable of—squeezing far too much into a single learning objective and not aligning verb selection with the proper learning outcomes level.
The next time you’re tasked with writing or reviewing learning objectives, ask yourself the following:
- Is the learning objective loaded with more than one idea or topic?
- Does the learning objective contain more than one clear, actional, measurable verb?
If so, consider breaking it apart into multiple learning objectives that are each singularly focused, with one actional verb. From there, consider:
- Is the learning objective verb appropriately aligned with the outcomes level this activity is designed to change?
If not, continue to hone your verb choice until you find alignment with your desired outcomes.
Team AOE at 2026 Alliance Annual Meeting
Team AOE will be presenting, attending and exhibiting at the 2026 Alliance Annual Conference! Come visit us at booth 408 in the exhibit hall. We hope you can attend AOE’s session “CPD Escape! Stuck in the Muck of Standard 3” on Tuesday, February 17th at 10:00 am.
Upcoming Events
- 2026 Alliance Annual Conference
February 16 – 19, 2026, Atlanta, GA
Read More >> - 2026 Joint Accreditation Leadership Summit
May 5, 2026, Chicago, IL
Read More >> - ACCME – Learn to Thrive 2026
May 6-8, 2026, Chicago, IL
Read More >>
