AOE Compliance Connection

Welcome to the November 2026 edition of AOE’s Monthly Newsletter! This edition of AOE Compliance Connection includes a review of key 2026 accreditation board updates, the second installment of our Standards refresher series, and a recap of a recent Almanac article on AI-powered sentiment analysis and evaluation data.

Don’t forget to check out AOE’s weekly compliance tips. We share pointers for accredited program success each and every Monday, and you can skim our running library of tips here.

The end of the year is approaching quickly. Before we jump into annual reporting preparation and deadline reminders, we’re taking a moment to review all major 2026 ACCME/JA updates. Make sure you’re current on those that impact your program.

• ACCME/JA released Guidance on the Responsible Use of Artificial Intelligence (AI) in Accredited Continuing Education (CE), outlining ways that providers can integrate AI into their CE programs while complying with existing policies like the Standards for Integrity and Independence in Accredited CE. They also announced the launch of two AI-related resources: an Artificial Intelligence (AI) in Accredited CE web page and a best practices and guidelines document titled Content Validity for AI-Enabled Clinical Learning.
• ACCME/JA announced the American Board of Thoracic Surgery (ABTS) plans to end self-reporting of CME credits by diplomates. The reporting responsibility will transition to accredited providers over the next two years, officially taking effect on January 1, 2028.
• ACCME/JA announced the American Board of Physical Medicine and Rehabilitation (ABPMR) has joined the CME for MOC/CC collaboration with ACCME. Accredited providers can now register suitable activities (i.e., those that meet ABPMR’s specific requirements) with a launch date of on/after January 1, 2025 for ABPMR CC credit via PARS.
• ACCME/JA released a policy on The Prohibition of Gift Cards or Personal Remuneration Associated with the Purchase of Accredited CME. The rule states: “An accredited provider, or any of its agents, may not offer, provide, or facilitate a gift card, cash equivalent, or other form of personal remuneration to any individual learner or group of learners as part of, or in association with, the purchase or registration for an accredited continuing medical education (CME) activity. This prohibition applies regardless of the source of payment for the CME activity, including self-payment and circumstances in which an employer, institution, or other entity pays for or reimburses the costs associated with participation.” The policy also outlines permitted practices, rationale, and an implementation note.

*This is the second installment of a five-part series.

The current Standards for Integrity and Independence in Accredited Continuing Education were released in December 2020 with required implementation by January 1, 2022. (They replaced the Standards for Commercial Support). They are recognized and upheld by multiple boards in addition to the Accreditation Council for Continuing Medical Education (ACCME), including ACPE, AAFP, ANCC, and Joint Accreditation for Interprofessional Continuing Education (view additional accrediting bodies here).

Even though we’re a few years past their debut, and there are “only” five of them, the Standards continue to challenge providers on compliance and best practice grounds. Providers must demonstrate ongoing compliance with the Standards to achieve and maintain accreditation, so it’s critical that your internal policies and procedures support smooth, consistent compliance.

With accreditation at stake, it’s a good practice for CE teams (of all types, sizes, and even records of excellence) to engage in a periodic “Standards refresher.” Over the next few months, AOE will highlight each Standard and areas to stay vigilant for non-compliance risks.

Standard 2: Prevent Commercial Bias and Marketing in Accredited Continuing Education

The second Standard is all about safeguarding education from other interests. As sourced from the ACCME:

Accredited continuing education must protect learners from commercial bias and marketing.

1. The accredited provider must ensure that all decisions related to the planning, faculty selection, delivery, and evaluation of accredited education are made without any influence or involvement from the owners and employees of an ineligible company.
2. Accredited education must be free of marketing or sales of products or services. Faculty must not actively promote or sell products or services that serve their professional or financial interests during accredited education.
3. The accredited provider must not share the names or contact information of learners with any ineligible company or its agents without the explicit consent of the individual learner.

We can agree that protecting learners is high priority, and providers attest to do so as part of their accreditation status. However, some continue to grapple with Standard 2 compliance. Here are some helpful tips to avoid risky practices:

Be mindful of subtle marketing and promotion tactics. You don’t often see faculty aggressively hawking wares like a late night informercial (remember those?) in educational content. The “marketing and sales of products and services” piece of Standard 2.2 is somewhat easy to spot: pricing, purchase links or salesy landing pages can be identified quickly and removed before content delivery. Promotion can be trickier to recognize, especially if a faculty member does not have relevant financial relationships with ineligible companies. When looking at content, consider 1) if the individual’s professional or financial interests are served in some way by the products or services they’ve mentioned in the content, and 2) if the mention exceeds basic inclusion that is hyper-relevant to the content presented.

Scenario: A faculty member (with no reported relationships with ineligible companies) recently released a book that delves deeply into the topic of her presentation and includes extensive research. It’s an excellent learner resource for additional/continued study.

She includes a dedicated slide about the book, with an image of the book cover.

• Risky. While not overtly trying to sell her book, and although it is relevant to the content presented, she is promoting a product that does serve her professional and financial interests.

She changes this to a text mention of her book on a slide alongside other valuable resources for continued study.

• Compliant. Her book is relevant to the content, and she is not promoting/highlighting it but featuring it as a matter-of-fact additional resource that learners can use.

Use trade names prudently, in the service of what is critical for context and educational value. The ACCME does not prohibit the use of any-and-all trade names, but it does take a use-sparingly, only-if-necessary approach. Aim to limit trade names to one or very limited mentions, use text only (no logos/branding), and reference comparable products or services, as highlighting only one trade name among several could be construed as a form of preference or promotion. If use of a trade name provides needed context/additional detail that will enable learners to better understand the educational content delivered, then it’s a worthwhile use.

Develop a policy and procedure to investigate learner claims of commercial bias. Your team might determine that content is free from commercial bias, but you can’t guarantee that all learners will agree. Since Standard 2 was created to protect learners, it’s important that you are prepared to heed their concerns. Make sure that your organization has a policy and procedure in place to track, investigate, and address/resolve any learner claims of commercial bias in accredited CE. This might include set criteria for credible claims of commercial bias, staff responsible for processing the claim(s), a timeline for response and resolution, methods of documentation, and more.

Put learner consent front and center. Accredited providers can share learner names and contact information with ineligible companies/their agents (e.g., exhibitors, sponsors, commercial supporters) if they obtain explicit consent from the individual learner. Be sure that your marketing department, web services, digital team or other staff responsible for registration forms, “opt-in” pages, pop-up windows, etc. use clear, concise language to communicate this. A learner should know that this choice is theirs and an easy method to select “yes” or “no.” Furthermore, the consent field should not be buried or hard to see.

Join us next month for a refresher on Standard 3.

If your team requires additional support with Standards instruction/compliance, please contact the AOE team here to discuss ways we can help.

The Almanac recently published an article on utilizing AI to analyze qualitative, free response learner data to identify emotional and attitudinal patterns that ultimately influence practice/behavior.

To note, the author, Steve Haimowitz, MD, shares a case study in which evaluation responses for two oncology-focused educational programs were run through an AI-enabled LLM. The AI analyzed free responses (in this case, transcripts of peer-to-peer educational discussions) to look for patterns in language. Through a five-step analysis, the study was able to hone in on barriers to implementation and found that while the clinicians demonstrated a strong understanding of the guidelines/knowledge of the educational topic, there was a “clear tension between clinical agreement and practical feasibility.”

The author sheds light on both the implications and limitations of the study results, pointing to the value of AI-powered sentiment analysis “when paired with structured prompts and expert oversight.” He also shares a helpful list of practical steps to explore the approach. You can read the full article here: Adding Emotion and Context to Outcomes: Using AI-powered Sentiment Analysis in Medical Education.

For providers interested in experimenting with lower-risk AI use and a volume of (de-identified) qualitative learner data that has not been analyzed, it might be worth exploring in the near future.

• Association of American Medical Colleges (AAMC) Annual Meeting: Learn Serve Lead 2026
  November 6 - 10, 2026, Anaheim, CA
  Read More >>
• ACPE Continuing Education (CE) Conference
  November 16 – 18, 2026, Chicago, IL
  Read More >>
• Alliance Annual Conference 2027
  February 18 - 21, 2027, Orlando, FL
  Read More >>