AOE Compliance Connection – April 2018 Newsletter

Welcome to the April edition of Compliance Connection, AOE’s monthly newsletter!

All of us at AOE are firmly committed to excellence in everything we do, from compliance management to customer service and everything in between.  This monthly newsletter is just one of the resources we make available to our partners and CME/CE stakeholders on a regular basis.

This month, you’ll find important updates regarding ABIM MOC activities, in addition to our regular board bulletin updates for ACCME, ACPE, and ANCC information, inclusive of upcoming activities and educational opportunities.

For even more information, compliance tips and a look at the staff at AOE, please visit our webpageor reach out to us at inquire@aoeconsulting.com.

The ACCME recently posted an update to the ABIM MOC Assessment Recognition Program Guide that directly affects providers who offer activities for ABIM MOC credit.  The updates, effective March 29, 2018, include small and significant changes.  You can view the updated program guide here.

The most significant changes are as follows:

• Most requirements have been re-numbered.
• ABIM1 and 2 have been combined into a single requirement that covers both providership and AMA PRA Category 1 Credit^TM.
• The evaluation component has been moved into the “All MOC Requirements” category (previously required for only Practice Assessment activities).
• The minimum MOC participation threshold requirement has been moved into the “All MOC Requirements” category (previously required only for Practice Assessment and Patient Safety activities).

For a complete explanation of all the changes to the requirements list and other components of the program guide, AOE has posted a useful table with detailed explanation here.

The ACCME reaccreditation process is now managed entirely online through the Program and Activity Reporting System (PARS). This means changes in how providers submit evidence for both Self-Study Report narrative and Performance-in-Practice evidence. Here is a list of what accredited providers need to know:

1. Flash Drives and Hard Copies:Accredited providers must no longer submit flash drives or hard copies of Self-Study Report narrative and Performance-in-Practice evidence. All information is submitted via PARS.
2. Self-Study Report Narrative = Online Form:Submission of Self-Study Report narrative is now managed online via a form in PARS. The form and process is similar to submission of a grant. Accredited providers must respond to the Self-Study Report outline by providing narrative descriptions and uploading documents as indicated. This has two major implications:
   • Bullets and Bolded Text:Since most of the Self-Study Report narrative is entered into form text boxes, any special formatting will be eliminated.
   • Unlimited Attachments:The structure of the form only permits uploads when requested. This means accredited providers will no longer be able to attach an example of a needs assessment or other evidence.
3. Performance-in-Practice = Online Form:Like the Self-Study Report narrative, submission of Performance-in-Practice evidence is now done via an online form in PARS. The form indicates narrative descriptions providers must enter and when documents should be uploaded. For example, for Criterion 2 and 3 providers may onlyenter narrative text; additional documentation may not be uploaded. As another example, for Criterion 7 (SCS 2), providers must enter information about individuals in control of content into a table.

While these changes alter how providers submit evidence to the ACCME, AOE Consulting recommends that accredited providers still develop a Word and/or PDF version of the Self-Study Report as this document is beneficial in preparing the CME team for the Reaccreditation Interview and can serve as a quick reference during the interview. It likely goes without saying, but having narrative text saved into Word documents also provides a back-up in the event of any technical glitches.

Lastly, AOE recommends that accredited providers begin the reaccreditation process at leastnine months in advance of the accreditation term expiration and map out a detailed timeline to ensure all aspects of the process are accounted for and managed appropriately.

Please Note:This article does not provide an exhaustive list of ACCME expectations and requirements. Please consult the following ACCME resources: Guide to the Process for ACCME Reaccreditation: An Overview and Submission Requirementsand the Self-Study Report Outline for ACCME Reaccreditation.

In 2008, the ACPE Board of Directors voted to adopt the ACCME’s updated definition of a commercial interest:“A ‘commercial interest’ is any entity producing, marketing, reselling, or distributing health care goods or services consumed by, or used on, patients.” Providers of clinical service directly to patients are not ‘commercial interests’.

Since that time, the ACPE has developed and uses five guiding principles to determine whether an organization is a commercial interest:

1. 1. Entities that are owned and operated on behalf of providers of patient care are not commercial interests (hospitals, long-term care facilities, etc.).
   2. In the situation of a parent company that is not a commercial interest who has two subsidiaries (corporation A and B), if corporation A includes the CPE unit and corporation B is classified as a commercial interest, corporation A should not automatically be labelled as a commercial interest as well.
   3. Pharmacies, and companies that provide pharmacist-provided patient care, are not commercial interests.
   4. Companies that are FDA manufacturers are considered commercial interests.
   5. Companies that provide proprietary formulas and have influence on the prescribing of the product are considered to be commercial interests.

To read more about the ACPE’s guidelines on defining commercial interests and how to structure your organization and CPE department accordingly, click here.