AOE Compliance Connection

Welcome to the January 2026 edition of AOE’s Monthly Newsletter! We’re charging into the new year with updates on AI guidelines from ACCME and Joint Accreditation, ACCME’s updated definition of Regularly Scheduled Series, and helpful reminders for annual disclosure collection.

In addition to our monthly newsletter, the Weekly Compliance tips section of the AOE website is chockfull of helpful answers to commonly asked questions on accredited CME/CE. Check them out for actionable advice your team can use for compliance success.

ACCME and Joint Accreditation recently released new guidance as it relates to the use of AI in the accredited CE space. Specifically, they’ve outlined 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’ve advised accredited providers to:

• Safeguard independence and mitigate bias, including screening AI-generated and AI-assisted content in the same ways human-developed content is reviewed.
• Transparently disclose AI use by listing the specific AI tool used and how it was used, labeling specific pieces of content created with AI, and more.
• Ensure human oversight, accuracy, and accountability by enlisting identified, experienced clinicians to review AI material.
• Protect learner identity and sensitive information, as it pertains to protected health information (PHI), personally identifiable information (PII) and related data.
• Limit prohibited or high-risk uses, including those related to diagnostic/treatment recommendations, sensitive content on public or non-secure platforms, and more.
• Establish internal governance and continuous improvement practices including policies, training and security protocols.
• Secure Databases and AI Systems as they relate to use of confidential or proprietary information and legal data protection standards.

You can review and download the full guide here.

AOE is working to outline recommended best practices for adherence and implementation of the new guidelines. Additionally, AOE will be participating and presenting at the Alliance 2026 Annual Conference in February, where staff will be attending several of the available AI sessions. You can explore the full Alliance schedule and respective sessions here.

Provided by AOE Senior Program Manager, Sarah Porter

The ACCME updated the definition of a regularly scheduled series (RSS) which can be found here. The updated definition indicates that, “If an RSS is presented live and recorded for the same audience who might happen to miss one or more sessions, then it would still be reported as one RSS and those learners would be part of the aggregate count of learners.” In short, this updated definition affirms that learners may claim CME credit for watching a recorded RSS session. However, the definition clarifies that, “If the RSS is recorded and intended for a different, broader audience, then it should be reported as two separate activities – one RSS and one enduring material.”

AOE has outlined recommendations for our accredited provider clients when considering whether to record RSS sessions and how to effectively manage accredited CE compliance.

Consider the Value-Add/Benefit

Recording RSS sessions shouldn’t be a blanket application for all RSS initiatives. Just because CME credit may be claimed for a recorded RSS session doesn’t mean that recording RSS sessions is best. Consider the following questions and ensure there is a clear-cut rationale for implementing recording and posting of RSS sessions:

• Will offering recorded sessions undercut the live audience and, ultimately, the session engagement by reducing in-person attendance and real-time discussion and Q&A?
• Are there implications with HIPAA when recording certain RSS sessions such as morbidity and mortality conferences or tumor boards during which patient cases are reviewed and discussed?

Platform and Technology

What technology and resources are necessary? Does your organization have a means of seamlessly recording RSS sessions? Do you have a learning management system or alternative platform on which to post the recorded RSS sessions for the designated target audience?

Workflow and Logistics

To effectively manage credit claiming and associated reporting (e.g., MOC reporting), if applicable, it’s recommended to set a clear deadline for how long recorded RSS sessions will be available to the target audience and when the credit claiming window closes. AOE’s recommendation is to permit access to recorded content for CME credit for 30 days post-session. However, accredited providers may elect to set alternative deadlines based on their unique programs and processes.

January marks a busy time for annual disclosure collection. Whether you’re a seasoned accredited CME/CE professional or new to the space, here are helpful reminders to guide your process this year.

Ensure your team collects disclosure information for all individuals in control of educational content.

This encompasses various planners/managers, faculty/authors/content developers, moderators, and content reviewers (even if your organization utilizes different titles for these roles). Don’t forget to collect disclosure information from members of organizational bodies like planning, education, or special committees, even if they are only intermittently active during the year. When in doubt as to whether an individual is in “control of content,” take a conservative approach—it can’t hurt to have the information on file.

Keep ACCME required elements; lose the fluff.

Your disclosure form should include fields for information that individuals must provide for compliance with Standard 3:

• Name and role in the education
• ACCME’s definition of an ineligible company
• Field to list financial relationships with ineligible companies for the prior 24 months, in any amount, regardless of his/her view of the relevance of the relationship to the education
• Fields for the name(s) of the ineligible company(ies) and the nature of his/her financial relationship with the company(ies)
• Field to note if the relationship(s) have ended
• Field to note if he/she has no relationships to report
• A field to attest that the information provided is correct as of the date of completion

Any details beyond these items (e.g. background information on your organization, your policies for mitigation, examples to help individuals fill out their information, and so forth) are up to you. Less is generally more and ensures you’ll obtain the critical details you need.

File disclosures, identify relevant financial relationships, and designate any mitigation measures before your educational activities kick off.

In a perfect CME world, providers would have all 2026 disclosures collected before January 1^st; the reality is that many may still be wrangling them. As long as you ensure that an individual in control of content does not assume his/her specific role prior to collecting his/her disclosure and mitigating any relevant financial relationships he or she has reported, you’re in the clear.

Protect your files.

Whether you distribute printed disclosure forms, send out linked pages for e-signature, or guide individuals to an online portal—make sure you store completed disclosure information in a secure location. Per the ACCME, accredited providers are “required to retain activity files/records of CME activity planning and presentation during the current accreditation term or for the last twelve months, whichever is longer.” This includes disclosure information for individuals in control of content.

Remind individuals that changes must be communicated.

In theory, annual disclosure collection is a “one and done” undertaking for the year, but it’s crucial to remind respondents that any changes must be communicated immediately to your team. If an individual establishes new financial relationships with ineligible companies in 2026, ensure they know how and where to share the updated information with you. Additionally, you must confirm the information on file is current prior to launching new activities he/she might be involved in later in the year.

If you are in need of additional guidance and/or staffing support to manage your accredited CE program’s disclosure management process or volume, please contact the AOE team here to discuss ways we can help.

• ANCC - Accredited Provider Workshop: Understanding the 2025 Accreditation Criteria
  January 27 - 28, 2026 (Two Day Virtual Workshop)
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• AAMC -  2026 Emerging Technologies for Teaching and Learning: Digital Demonstrations Virtual Conference
  February 4 – 5, 2026 (Two Day Virtual Conference)
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• ANCC – Accredited Provider Workshop: Understanding the 2025 Accreditation Criteria
  February 11 - 12, 2026 (Two Day Virtual Workshop)
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• 2026 Alliance Annual Conference
  February 16 – 19, 2026, Atlanta, GA
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• 2026 Joint Accreditation Leadership Summit
  May 5, 2026, Chicago, IL
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• ACCME – Learn to Thrive 2026
  May 6-8, 2026, Chicago, IL
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