Welcome to the March edition of AOE Compliance Connection, AOE’s monthly newsletter!
We have much to share with you this month, including last minute advice about PARS and a look at ACCME’s President and CEO Graham McMahon’s latest publication regarding the future of CME. Look for our regular board bulletins for ACCME, ACPE, and ANCC information, inclusive of upcoming activities and educational opportunities.
We are committed to excellence in everything we do: Customer service, compliance management, training and consulting and keeping our thumb on the pulse of an ever-changing enterprise. This newsletter is just one of the many resources we make available to our partners and CME/CE stakeholders.
We hope you enjoy this month’s edition of AOE Compliance Connection! For even more information, compliance tips and a look at the staff at AOE, please visit our webpage or reach out to us at inquire@aoeconsulting.com!
Accreditation Board Bulletin
ACCME
Appropriate management and resolution of conflicts-of-interest (COI) continues to rank among the highest areas of non-compliance in the ACCME’s accreditation system. The ACCME recently created a tutorial and flowchart tool to aid providers in identifying relevant financial relationships and resolving of those identified COIs deemed relevant. By following the step-by-step guide, CME providers can successfully meet the ACCME’s expectations regarding COI identification and resolution in support of compliance with the ACCME Standards for Commercial Support. View the flowchart and instructions for using it.
The ACCME expects accredited organizations to ensure independence by:
- Identifying relevant financial relationships. Relevant financial relationships are financial relationships: a) in any amount, b) which occurred in the 12-month period preceding the time that an individual was asked to assume a role controlling content of the CME activity and c) which relate to the content of the educational activity, causing a conflict of interest.
- Resolving conflict of interests. The ACCME considers financial relationships to create a conflict of interest in CME when individuals have both a financial relationship with a commercial interest and the opportunity to affect the content of CME about the products or services of that commercial interest.
- Disclosure to learners. The identified relevant financial relationships or no relevant financial relationships need to be disclosed to learners prior to engagement in the educational activity.
As a reminder, the deadline for entering data into PARS for the 2016 reporting year is March 31, 2017. More information on PARS.
ACPE:
Continuing Pharmacy Education (CPE) Activity Announcements, whether in the form of audience generation invitations or front matter materials, should include enough information to adequately inform prospective learners of essential elements of the activity prior to their engagement with the content.
Different than other accreditation boards, the ACPE has explicit requirements for Activity Announcements, which are outlined in Section V, Policy 4.0 of their Policies and Procedures Manual and are as follows:
- Learning objectives
- Type of activity, i.e. knowledge, application, practice
- Target audience(s)
- The appropriate target audience designation (‘P’ and/or ‘T’)
- Faculty member(s) name, degree, title/position
- Fees for the activity
- Schedule of the educational activities
- Amount of CPE credit, specified in contact hours or CEUs
- Official ACPE logo, used in conjunction with a statement identifying the accredited provider(s) providing or joint providing the activity:
- “The [name of accredited provider(s)] is/are accredited by the Accreditation Council for Pharmacy Education as a provider of continuing pharmacy education.”
- The ACPE Universal Activity Number assigned to the activity
- A full description of all requirements established by the provider for successful completion of the CPE activity and subsequent awarding of credit (e.g., passing a post-test at a specified proficiency level, completing an activity evaluation form, participating in all sessions or certain combinations of sessions which have been designed as a program package, etc.).
- Acknowledgment of any organization(s) providing financial support for any component of the educational activity, and,
- For home study activities: the initial release date and the expiration date.
In addition to the above requirements, internet-based activities have additional requirements including hardware requirements like minimum memory/storage, processor speed, etc. More information about these specifications can be found on page 18 of the Policies and Procedures Manual.
ANCC:
The ANCC has three different application cycles throughout the year, the most recent being the July Application Cycle for which applications were due by March 1, 2017.
The next step in the process is the production and submission of the Self-Study package, due July 1, 2017. The Self-Study phase is a two-part progression beginning with the provider submission of the Self-Study documentation. The documentation is required to include organizational overview evidence, written evidence of compliance with ANCC Accreditation Program criteria and complete activity file documentation. Upon submission of the Self-Study package, a team of ANCC Accreditation Program appraisers review and score the Self-Study documents per established criteria.
Following the submission of the Self-Study package, the appraisers will schedule a virtual visit to be conducted between July 15 and October 15, 2017. The purpose of the virtual visit is for the appraisers to discuss the Self-Study documentation with the provider to clarify and validate content. The appraisers many times request additional records or documentation before, during, or after the virtual visit. After conclusion of the virtual visit, the appraisers will prepare a final written report for the Commission on Accreditation (COA).
The last milestone in the cycle is the accreditation decision. The COA reviews the appraisers’ report and determines the accreditation decision. The final decision will be completed between October 1 and January 1, 2017. The next application cycle is the November Cycle with applications due July 1, 2017.
As a reminder, the deadline for entering data into NARS for the 2016 reporting year is April 1, 2017. More information on NARS.
CME in the News: ACCME Calls on Healthcare Leadership
Earlier this month, the ACCME announced the publication of an article by President and CEO Graham McMahon in Academic Medicine. “The Leadership Case for Investing in Continuing Professional Development” is a call to action for healthcare leaders when it comes to quality education.
“Engagement in the learning journey of health care professionals as they seek to improve their competence and expertise is an investment in people. Accredited continuing medical education (CME) is one of the key resources that supports this lifelong pursuit,” Dr. McMahon writes.
Throughout the article, healthcare leaders are encouraged to empower their institution’s CME unit, to update their view of CME and to explore the potential of CME as a strategic change agent. Dr. McMahon poses three questions for each leader to ask of themselves and their institution:
- What can I do to leverage the convening power of education to achieve my institution’s mission?
- Is my CME and QI departments collaborating effectively?
- Am I investing in educators to help achieve my organization’s strategic goals?
Dr. McMahon offers encouragement, statistics and advice on leveraging the power of education in healthcare’s future. He poses the suggestion that CME does not just play a role in the learner’s development, but stands to benefit the hosting institution greatly, as well:
“Ultimately, health care leaders who recognize the strategic value of education and invest in their people can expect a meaningful return—not only in terms of the quality and safety of their clinicians’ work but also in the spirit and cohesiveness of the clinicians who work in their institution.”
Read the complete The Leadership Case for Investing in Continuing Professional Development.
Navigating Solutions: Best Practices for Reviewing PARS Data
The March 31 deadline for submitting your CME program data for 2016 activities to the ACCME’s Program and Activity Reporting System (PARS) is quickly approaching.
Whether you decide to enter activities individually or complete a batch upload, the following guidelines can help ensure that the data you submit is accurate.
- Spell Check: This is a quick, easy step that is often forgotten. Spell check can be done in your batch upload file or by downloading activity data once it has been entered into PARS. Reviewing your PARS data for spelling errors demonstrates your organization’s commitment to professionalism and accuracy.
- Review “Hours of Instruction” against AMA PRA Category 1 Credit(s)™: Most often the data in these two columns will be the same. Confirm this is the case and closely review any activities for which these columns differ (e.g. a large annual conference for which not all sessions were certified).
- Providership: Confirm Providership for each activity. If joint providership is selected, ensure that the correct joint provider is listed. If a joint provider is listed for multiple activities, ensure that the name is consistent.
- “Designed to Change _____?” and “Changes in _____ Evaluated?):” Closely review the data in these fields to ensure alignment. If an activity was designed to change performance, then changes in performance should have be evaluated. Double check that data is available in the activity file. If an activity is designed to change performance or patient outcomes but that data was not collected, this would indicate an area for review in your CME program.
- Commercial Support Received: Carefully review the reporting of all commercial support. Ensure that the names of commercial supporters match the letter of agreement, ensure that the amount and/or type is accurate, and ensure that commercial support is not reported in duplication.
These five tips are a high-level overview for reviewing your PARS data. AOE recommends a thorough review of your CME program’s data prior to submission. Lastly, we recommend submitting your data a few days prior to the deadline to circumvent any potential issues.
Upcoming Activities/Education Opportunities
- ANCC New Applicant/Provider Workshop
Open to both applicant organizations and currently accredited organizations
March 23, 2017, Chicago, IL
Read More >> - Self-Study for ACCME Accreditation Webinar
April 4, 2017, Online
Read More >> - ACCME 2017 Meeting: Evolution, Innovation, and Alignment
April 24-27, 2017, Chicago, IL
Read More >> - ANCC Pathway to Excellence Conference
April 27-28, 2017, Dallas, TX
Read More >> - SACME 2017 Annual Meeting
May 16-20, 2017, Scottsdale, AZ
Read More >> - ANCC CNE Symposium
July 18, New Orleans, LA
Read More >>
