AOE Compliance Connection – January 2022 Newsletter

Welcome to the January edition of AOE Compliance Connection, AOE’s monthly newsletter. In this month’s newsletter, we continue our series called “Did You Know” featuring some fun (and helpful) FAQs about the new Standards. We also report back to you from our time at the Alliance 2022 Annual Conference last week and include an overview spotlighting how AOE can help organizations looking at initial accreditation and wondering about next steps! As always, we work hard to keep you updated on the CE enterprise through our weekly compliance tips, our social media pages, and more. Reach out to us at inquire@aoeconsulting.com with any questions. We’d love to help make sure 2022 is off to a great (and compliant) start for you and your CE team!

Let’s continue our series featuring some of the most helpful ACCME FAQ features. Often, information on the ACCME website is nestled in the FAQ section. AOE will be uncovering some of the guidance and wisdom specific to the new Standards throughout this series.

At the end of 2021, we tackled three questions related to stock ownership and patent holders. This month, let’s kick 2022 off with three questions related to collecting disclosure information and mitigating financial relationships:

1) Do we need to mitigate relevant financial relationships differently for planners than for other roles?

Yes. Often providers use mechanisms to mitigate relevant financial relationships for authors, speakers, and reviewers that do not address the planner-specific roles of controlling decisions that occur before content is developed, choosing topics, and selecting faculty members for the accredited CE activity. For example, a peer-review of content wouldn’t address these roles. To mitigate planners’ relevant financial relationships, the provider must use mechanisms that are targeted to the planning process itself.

2) We have some speakers who speak at more than one CME activity – do we need to collect their disclosure information each and every time?

No, you don’t have to collect the information every time an individual serves as a speaker at your accredited CE activities. It is true that the Standards require that the provider be able to show the ACCME that everyone who has control of accredited CE content has disclosed all financial relationships with any ineligible company to the provider. This disclosure can take place by the provider accessing disclosure information from prior accredited CE activities, database information, or even another institution and then verifying with the individual that those relationships are current and applicable.

3) Am I required to obtain disclosure information for those in control of content when the content of my CME activity is not related to the products or services of an ineligible company?

Actually, no.  As the provider, you are required to identify relevant financial relationships for anyone in control of the content of an accredited CE activity. Both of these requirements must exist for this situation to take place: 1) financial relationship(s) with an ineligible company and 2) the ability to control content related to products/services of said ineligible companies. In the situation of the accredited CE content not being related to the products or services of an ineligible company, there would be no relevant financial relationships for you to identify or mitigate!

AOE is here to serve you and your CE team with any and all compliance and accreditation-related questions that arise. If you are considering initial accreditation with ACCME, Joint Accreditation (JA) or another healthcare board, don’t hesitate to reach out to us.

AOE remains ready to partner with you and your team to understand your individual organizational structure, to assess your current CE policies and procedures, to map out strategic areas for program infrastructure to meet accreditation requirements, and to practically and quickly implement new process(es), or the identified necessary changes.

Our expertise, informed by dozens of interviews with accreditation board surveyors and hands-on experience with multiple board self-study reports, spans the entire accreditation process.

When you reach out with questions about initial accreditation, you can expect a friendly and professional conversation involving:

• CE Program Assessment and Accreditation Workshop
• CE Policy & Procedure Review, Updates and/or Development
• Board-Specific Eligibility Forms, Self-Study Design, Development, or Compliance Review
• Activity File Audit, Compilation, and/or Compliance Review
• Mock Survey
• Timelines and Milestones

If your team is considering initial accreditation with any major board, reach out – we are ready to answer your questions and help you take next steps.