ACCME Plans to Bulk Up While Cracking Down...I Think...Until It Will Exist No More

To expand its "operational elements," the Accreditation Council for Continuing Medical Education plans to increase its current fees and to introduce new fees for accredited providers of CME. The ACCME—the US organization that confers accreditation on universities, medical societies, and MECCs to provide CME—stated its intent to increase its revenue in an abstrusely worded annual Policy Announcements. Presently the ACCME's initial and reaccreditation fees are $6500, and its annual accreditation fee is $2000; according to its website, the ACCME provides accreditation for 740 organizations.

The ACCME did not specify its newly proposed fees in the announcements, but additional revenue is intended to support substantial staff increases and "an enhanced monitoring and surveillance system." And while information in this section of the policy document, "An Expansion to Operational Elements," remains vague, it is certainly the clearest in meaning among all sections of the document. Other informational parts of the announcements and proposed policies "for comment" are written in an overbearing, and often senseless, wordiness. Perhaps the ACCME knows what it means; the rest of us can only guess.

Let's begin with the introductory "Accredited CME is[sic] Education That Matters to Patient Care."*

The ACCME continues to emphasize that CME must be a strategic asset to all stakeholders who seek to improve health care in the US. Since 2006, the ACCME has maintained a focus on supporting a well-organized transition to a criterion-based system for the accreditation of CME providers that matches the gaps in physician competence, performance, and patient outcomes (ie, professional practice gaps) with practice-based learning and change.

In the first sentence, I pretty much stumble after "that" and then experience a full-body wince at the use of "stakeholders." In the phrase, "CME must be a strategic asset," "strategic asset" apparently means some important, positive thing; but it's really axiomatic that a cited asset would be important, so the adjective, in my mind, is unnecessary. And then I'd argue that "asset" should be supplanted with an adjective like "important." Then there's the phrase, "all stakeholders who seek to improve health care in the US." That's pretty much everybody, isn't it? So the first sentence can be distilled to something like, "The ACCME continues to emphasize that CME is important to everybody"—which is not a particularly useful or insightful introductory sentence. So just delete the whole thing. 

Then there's the second sentence: "Since 2006, the ACCME has maintained a focus on supporting..." For starters, how about, "Since 2006, the ACCME has focused..." or even "has supported..."? What has the ACCME "maintained a focus on supporting"? A "well-organized transition to a criterion-based system for the accreditation of CME providers." There are at least a few problems with this phrase. The ACCME supports a transition (and not a poorly organized transition, mind you) to a criterion-based system (BTW, it is really just 1 criterion?), but the ACCME doesn't indicate what the transition is from. A non-criterion-based system? Something like astrology? But even an astrological sign is a criterion, albeit a capricious one. So the distinction of a "criterion-based system" is nonsensical without further definition. 

To that point, the remainder of the ACCME's second sentence indicates that the "criterion-based system... matches the gaps in physician competence, performance, and patients outcomes...with practice-based learning and change." The ACCME now defines its "criterion-based system" for accreditation as something that matches gaps—or really, addresses deficiencies—in "physician competence, performance" (which are really the same) and "patients[sic] outcomes." And then the method by which these deficiencies are addressed is "practice-based learning and change." But all medically related learning is potentially applicable to practice, depending on whose practice you're talking about.

So the ACCME's definition of its "criterion-based system" for accreditation (which, when it comes down to it, is not really a system) is the CME provider's act of demonstrating (and I'm helping out the ACCME here) that there is information which has the potential to improve medical practice. Therefore..."Since 2006, the ACCME has supported the accreditation of [or simply "accredits"] CME providers who attempt to provide knowledge that elevates medical practice," or something to that effect. This statement, in its distillation, is also kind of self-evident and, therefore, unnecessary. 

I could go on and on, but the exercise is life sucking. Anyway you get my drift, even if you read only part of the Policy Announcements.

The most controversial aspect of the ACCME's Policy Announcements is in a "For Comment" section, which proposes that the commercial support of CME should only be allowed to continue after several considerable changes. These changes are likely to make the production of timely CME difficult and probably more trouble than it's worth for many providers. (The ultimate and ironic consequence [described below] of the ACCME's proposed conditions should be evident to anyone who has played chess.)

1. When educational needs are identified and verified by organizations that do not receive commercial support and are free of financial relationships with industry.

The ACCME cites government agencies as a example; although, it does not stipulate which government agencies engage in or would engage in the identification of CME needs, or how current CME providers would access or use this information to obtain grant support from industry. Also, what defines freedom from financial relationships?

2. If the CME addresses a professional practice gap of a particular group of learners that is corroborated by bona fide performance measurements (eg, National Quality Form[sic]) of the learners' own practice.

Another ill-considered hoop. Other than citing the National Quality Forum, a nonprofit "performance-improvement" organization, it's not clear what would qualify as valid corroboration. At its website, the NQF notes that it endorses a number of "clinician-level performance measures" and is currently asking for measures related to cancer, infectious disease, and surgical care. But how this information may be obtained or used by CME providers is not described by the ACCME or the NQF. 

3. When the CME content is from a continuing education curriculum specified by a bona fide organization, or entity (eg, AMA, AHRQ, ABMS, FSMB).

Again, how CME providers may obtain and use another organization's curriculum for content is not clear (and perhaps not yet known).

4. When the CME is verified as free of commercial bias.

And who or what determines commercial bias?

Now the big irony of the ACCME's proposed crackdown on commercially supported CME is that it conceivably leads to the organization's undoing through the following process. 

• Industry will provide less commercial support for CME (as has been the case during the last year or so).
• There will be considerably fewer organizations producing certified CME and, therefore, fewer organizations will need accreditation to provide CME.
• Fewer accredited CME providers will reduce the ACCME's fee revenue.

High five, ACCME.

CME = continuing medical education; MECCs = medical education communications companies.

*BTW ACCME, always capitalize verbs, no matter how short, in titles.