AOE Compliance Connection

Welcome to the July edition of AOE Compliance Connection, AOE’s monthly newsletter.  As we pass the “halfway” mark of 2018, we are hopeful that you are enjoying a busy and productive summer season!

This month’s newsletter features a spotlight on the release of the ACCME’s new website, news about the ABMS/MOC collaboration, board updates for ACCME, ANCC, ACPE and a detailed look at exactly what your LOAs should (and should not) contain.

Before we dive in to this month’s edition, we want to bring to your attention the release of the ACCME’s 2017 Annual Report.  This report highlights the growth within the CME community, and isolates a few salient points.  Data is pulled from more than 1,800 accredited providers (which adds up to nearly 163,000 activities!).  2017 demonstrated an increase in both physician and non-physician participants.

Other statistics and easy-to-digest graphics are available in AOE’s summary of the full report here.

The Continuing Certification of the American Board of Medical Specialties (ABMS) encompasses 24 boards.  To be included, a board must first achieve initial Board Certification.  The Continuing Certification Directoryis a “central repository of CME activities approved by Member Boards of the ABMS which meet the Lifelong Learning and Self-Assessment requirements of one or more ABMS Member Boards” (www.abms.org).  It exists to increase access to CME and Self-Assessment activities, patient safety activities and interdisciplinary competencies. Additionally, the directory increases alignment with other national priorities.

Providers can now submit accredited CME activities via a single submission form.  The value of a common submission form is clear – a single pathway for multiple board approvals streamlines the application process.  In addition, it advances consistencies in the approval process across multiple boards and enhances the recognition of CME activities that are relevant to multiple specialties.  Learners will benefit from the easy access to and identification of activities.

When soliciting commercial support for accredited CME activities, providers must take appropriate steps to ensure compliance with the ACCME Standards for Commercial Support.

Specifically, Standard 3.4 states that, “The terms, conditions, and purposes of commercial support must be documented in a written agreement between the commercial supporter that includes the provider and its educational partner(s). The agreement must include the provider, even if the support is given directly to the provider’s educational partner or a joint provider.”

Commercial support awarded (whether monetary or in-kind), known as an educational grant, or sometimes referred to as an independent medical education grant, must be accompanied by a letter of agreement (LOA) that is signed by the commercial supporter and the accredited provider, at minimum.  If the provider is working with an education partner(s) or joint provider, they must be listed in the LOA, but their signatures are optional.  The LOA must be signed before launch of the supported activity. Many times, a commercial supporter will have their own LOA, but sometimes it is up to the provider to furnish one. In either instance it is a best practice to review an LOA against a checklist prior to signing. The LOA should include:

• Name and signature of the commercial supporter
• Name and signature of the accredited provider
• Name and signature(s) of any educational partner(s) and/or joint provider(s)
• Dollar amount of the commercial support and/or the nature and amount of “in-kind” support
• The purpose of the commercial support
• Language outlining that the provider has independence regarding educational program decisions and makes all decisions regarding the disposition and disbursement of funds
• Language articulating that the commercial support is solely for supporting the educational initiative

In reviewing an LOA, it is also helpful to note any specific requirements and deadlines so funding is not jeopardized. Often, commercial supporters will require providers to submit a reconciled budget and/or outcomes data. Additionally, sometimes commercial supporters have specific stipulations that preclude funds from being used in a certain manner (e.g. to cover meals).

One final best practice: While LOAs must be reviewed on the front end, prior to signing to ensure compliance, it is also a best practice to review LOAs during reaccreditation, particularly if there has been staffing changes. Documenting any issues found with LOAs and understanding how mistakes came to be aids a provider in determining if management processes need updating or if staff training is necessary.

The ASHP/ACPE Accreditation Standards for Pharmacy Technician Education and Training Programs have undergone a thorough revision/update process. The transition will begin this month (July 2018) and will look forward to a full implementation by January 2019.

These Standards were last revised in 2015, and ASHP and ACPE cite a few contributing factors to their latest revisions:

• The recent experience gained by the Pharmacy Technician Accreditation Commission (PTAC) in its accreditation reviews.
• Expansion of the range of pharmacy practice in state laws to include pharmacy technicians.
• Feedback from the 2017 Pharmacy Technician Stakeholder Consensus Conference (PTSCC) about the need for updated entry-level pharmacy technician education and training.

The revised Standards, that now include pharmacy technicians, are intended as public protection by serving as a guide for pharmacy technician education and training program development at the entry- and advanced-levels.

Some changes you’ll see in the revised Standards: Fifteen Standards now appear in three sections, much like the style used by other accrediting bodies. The words “must” and “should” no longer appear, and the Standards instead utilize declarative statements of expectations for compliance. Minimum hour requirements have been edited to reflect education and training needs for entry-level and advanced-level preparation of graduates. Based on PTSCC feedback, the Standards have been divided into entry-level and advanced competencies within one document. Programs may choose if they want to provide only entry-level programs or both entry-level and advanced level programs.

The transition to the final revised Standards begins this month and full implementation is set for January 1, 2019.