AOE Compliance Connection

Welcome to the May 2020 edition of AOE Compliance Connection, AOE’s monthly newsletter. This month, AOE’s newsletter features two important reports, one regarding the changing Standards for Integrity and Independence and one pertaining to the ACCME Commendation Criteria. Additionally, you’ll find board updates for the ACCME, ANCC, and ACPE, along with an updated calendar of CME/CE events. Follow us on Twitter and Facebook for weekly compliance tips and other timely updates!

In April, the ACCME published the Executive Summary and Comments on the Standards for Integrity and Independence. The call for comments, which opened January 7 and closed February 21, resulted in 344 responses to the online survey and responses via email and letter. As seen in the ACCME’s graphic below, responses from every provider type comprised the 344 responses, of which 75% (n=251) are accredited CE providers.

The report can be read in detail here, but the feedback gathered can be summarized by saying that the feedback was overwhelmingly positive. Providers confirmed that the proposed Standards meet the ACCME’s goals. However, some feedback was constructive and posed new questions for consideration.

What are the next steps in this year long process? The ACCME Board of Directors reviewed the feedback during their March meeting. They plan to move forward with the new Standards, but determined some modifications are needed based on feedback received. To allow for these modifications, the adoption and implementation of the revised Standards has been delayed temporarily and a final version of the Standards is expected before the end of 2020.

In its April 30, 2020 ACCME Report, the ACCME released its Menu of Criteria for Accreditation with Commendation Transition Report. The report provides background information on the Menu of Criteria for Accreditation with Commendation, data from the two-year transition period, lessons learned, and minor modifications made to five Commendation Criteria (C30, C33, C36, C37, C38).

Data and Analysis from the Two-Year Transition Period

During the transition phase from November 2017 to November 2019, Accredited Providers going through Reaccreditation had the option to respond to the original Commendation Criteria, Option A: C16 – C22, or the New Menu of Criteria for Accreditation with Commendation, Option B: C23 – C38. Over the course of the transition period, 28 ACCME-accredited providers and 17 state-accredited providers applied for Accreditation with Commendation under the new menu (C23 – C38) with 30% and 35%, respectively, demonstrating success. To date, there has been one cohort of Accredited Providers who applied for Accreditation with Commendation after the transition phase. There were 41 Accredited Providers eligible to apply and 16 (39%) applied with 5 demonstrating success.

Key Takeaways

• According to the ACCME, all provider types have successfully achieved Accreditation with Commendation. This includes government or military organizations, insurance companies, managed care companies, schools of medicine, hospitals/healthcare delivery systems, non-profits (physician membership organizations) and publishing/education companies.
• Each criterion has been selected by at least one provider and at least one ACCME-accredited provider has been found in compliance with each of the criteria. 
• The report highlights common reasons for non-compliance for various criteria. The following is pulled verbatim from the report.

Minor Modifications

• Criteria 33, 37 and 38 originally indicated that providers should submit “at least two” projects (C33) or examples (C37 and C38). For each criterion, some providers submitted more than two examples, not all of which met the Critical Elements. This required more work for providers, surveyors and the Accreditation Review Committee (ARC) members and also gave some providers more opportunities to demonstrate compliance. All three criteria now limit the number of examples to two.
• For Criterion 30, not all providers interpreted the term “technical and procedural skills” as “psychomotor skills.” The ACCME has since added “psychomotor” to the language of the Rationale and Critical Elements.
• Criterion 36 originally required that provider demonstrate that in at least 10% of activities the majority of learners’ performance improved. This resulted in a breadth of data. The ACCME has since aligned C36 to other criteria that require an attestation to meeting the criterion in at least 10% of activities and providing evidence/examples based on program size (Small: 2; Medium: 4; Large: 6; Extra-Large: 8).