AOE Compliance Connection

Welcome to the November edition of AOE Compliance Connection, AOE’s monthly newsletter.  In this month’s newsletter, we introduce a new series called “Did You Know?” featuring some fun (and helpful) FAQs about the new Standards. Additionally, we are spotlighting the presentation of one of AOE’s own at a recent educational session and include an overview about Joint Accreditation and how to know if you should be considering it for your organization. AOE is working hard to keep you updated on all the latest CE news – make sure to check out the weekly compliance tips on our website and social media pages, too. We’d love to hear from you at inquire@aoeconsulting.com with any questions you or your CE team members have!

With the Thanksgiving holiday just days away, the AOE team would like to express our gratitude for the interactions, questions, and discussions we’ve had with so many of you over this past year. We look forward to continuing to engage with the CE community into 2022 and beyond!

The ACCME website is a resource for a large range of information – from accreditation timelines to fee schedules, providers can find tools to support their CE activities and programs. Often, some of the most valuable information on the ACCME’s website is nestled in the FAQ section, in which a broad range of provider questions are tackled and answered. There is guidance and wisdom to be uncovered in the FAQs regarding the new Standards and for the next few months we will dedicate this section of our monthly newsletter to featuring some hidden but valuable gems from the ACCME’s FAQ lists that relate specifically to the new Standards.

Let’s kick it off with three questions focused on stock ownership and patent holders:

1) If an individual reports that they own stock in an ineligible company, how should the provider manage the relationship?

ALL individuals in a position to control content are expected to disclose all financial relationships with ineligible companies within the past 24 months. What should a provider do if the individual discloses stock ownership? The answer depends on whether or not the company is publicly traded or privately held. If the individual owns stock in a privately held ineligible company, they are considered owners or employees and therefore cannot serve in a position that places them in control of accredited CE content (i.e., planners/faculty). The exception to this would be if the individual were to meet one of the three ACCME exclusions described in Standard 3.2. If, however, the individual owns stock in publicly traded ineligible company(ies), they are NOT considered to be owners or employees, so may participate in a position to control accredited CE content, so long as the provider takes appropriate steps to mitigate any relationship deemed relevant and disclose the relationship to learners.

2) Are patent holders who receive royalty payments from ineligible companies considered to be owners of those companies?

Like stock ownership, the question comes down to the nature of ownership. The ACCME clarifies that, no, individuals who receive patent royalties from ineligible companies are not considered owners or employees of those companies. Those individuals may control content in accredited CE if the appropriate steps are taken per Standard 3.

3) Can a provider leave it up to an individual who controls content to determine if his/her financial relationship is relevant and needs to be mitigated?

No. With the new Standards, the ACCME now requires that all financial relationships with ineligible companies be disclosed, and clearly outlines that it is the responsibility of the accredited provider to determine relevance based on what has been disclosed and the topic area being addressed by the accredited CE activity. The responsibility for identifying relevant financial relationships cannot be delegated to the person disclosing a financial relationship.

Joint Accreditation for Interprofessional Continuing Education™ is celebrating its 10^th anniversary. In honor of this milestone, let’s take a look at what Joint Accreditation is, who all is involved, what the timeline and fees look like, and if it might be a good thing for you and your organization to consider.

What is it?

Joint Accreditation for Interprofessional Continuing Education™ (or simply “Joint Accreditation”) offers organizations the opportunity to be accredited simultaneously in multiple disciplines. Through a single application and accreditation process, joint providers can provide CE for physicians, pharmacists, nurses, dentists, athletic trainers, dietitians, optometrists, physician assistants, psychologists, and social workers. The stream-lined fee structure, accreditation standards, and application process simplifies CE for providers wishing to award interprofessional continuing education credit (IPCE) in addition to single profession credit. At this time, Joint Accreditation is the first and only process in the world offering this benefit.

Joint Accreditation is built on the belief that IPCE leads to improved health care delivery and, ultimately, better patient outcomes.  At its core, IPCE is simply when members from two or more professions collaborate and “learn with, from, and about each other” in the educational design effort.

Who is involved?

Joint Accreditation was initially co-founded by the ACCME, ACPE, and ANCC, who reviewed and granted the first two organizations the status of Joint Accreditation in 2010, hence the ten-year anniversary in 2021. Since that time, the IPCE community has grown significantly, and now includes nine professions, more than 100 accredited organizations, and over 30,000 educational activities each year.

Currently, the list of collaborating accreditors includes:

• Accreditation Council for Continuing Medical Education (ACCME),
• Accreditation Council for Pharmacy Education (ACPE),
• American Nurses Credentialing Center (ANCC),
• American Academy of PAs (AAPA),
• American Dental Association’s Continuing Education Recognition Program (ADA CERP),
• American Psychological Association (APA),
• Association of Regulatory Boards of Optometry’s Council on Optometric Practitioner Education (ARBO/COPE),
• Association of Social Work Boards (ASWB),
• Board of Certification for the Athletic Trainer (BOC), and
• the Commission on Dietetic Registration (CDR).

What is the timeline/fee structure?

Receiving Joint Accreditation is a process that takes 13-15 months, beginning with the determination of eligibility to receiving the final decision. You can find more specific information about the cohorts and timelines here. The fees exist in a range, but first-time applicants can expect an eligibility review fee of $1,500 and an initial application fee of $22,000. Other application fees and annual fees are outlined here.

Are you eligible?

There are three conditions any organization must meet in order to be eligible for applying for Joint Accreditation:

1. You must have had structure and processes for “education designed by and for the healthcare team” functional and in place for at least the past 18 months.
2. More than 25% of your educational activities over that 18 month window can be considered “interprofessional” (in which the planning process also includes health professionals from a minimum of two professions reflective of the target audience).
3. If you are accredited by any of the collaborating accreditors, you are in good standing, and you engage in the joint accreditation process and demonstrates compliance with the Joint Accreditation Criteria.

Before any organization submits an Intent to Apply form, interested applicants should reach out to the Joint Accreditation staff (info@jointaccreditation.org) to have an initial conversation about the process and requirements. In advance of a formal discussion with the Joint Accreditation staff, AOE would be happy to answer any questions you may have, as well (inquire@aoeconsulting.com).