ACCME Asks for Comments on Comment Procedures

Invoking an endless reflection in facing mirrors, the Accreditation Council for Continuing Medical Education—the organization that accredits other organizations to produce certified CME—is currently asking for public comments on its proposed Notice and Comment Procedures. Comments on the ACCME's comment procedures, which will restrict a comment period to 30 days, will be allowed for (you guessed it) 30 days (from April 22 to May 21).

The ACCME is also soliciting comments on its proposals to provide branded designations for certain CME programs that are not funded by commercial sources (trademarked Commercial Support-Free™) or those that are not delivered by individuals with relevant commercial interests (trademarked Promotional Teacher and Author-Free™). As usual, God (or the devil) is in the details; the proposals beg a host of questions. Top of mind: What defines a relevant commercial interest? What defines a relationship with a commercial interest?*

Last, the ACCME recommends the creation of a CME Funding Entity, a source of pooled industry funds that would somehow be managed independently of the ACCME. Funds from the "entity" would be handed out to accredited organizations to develop and deliver certified CME. How the administration of such an entity would, itself, be financed is not stated.

* It also seems unfair and really just inaccurate to designate a physician who happens to have some kind of relationship with industry, be it in an advisory or consultant position, as a "promotional" teacher or author.

04/28/09 addendum: Over at The Carlat Psychiatry Blog, Daniel Carlat actually raises a good point (although we differ on the conclusion from that point**). If the ACCME is proposing commercial-free labels for qualifying CME programs—which imply that a commercial-free program is somehow superior to a commercially funded program—then why allow for the certification of commercially funded programs at all?

If the ACCME leadership were purist in thought with consistent standards, it would completely eliminate the option for certifying industry-supported CME, or it would acknowledge (and in fact, stress) that commercially funded CME is an important source of information for healthcare professionals, provided that the current standards are met.

** While Daniel Carlat champions the idea that commercial-free CME is always superior CME, I do not. Continuing education of the healthcare professional is best achieved by allowing access to as many options as possible, provided that CME activities disclose their source of funding and the faculty's potential conflicts of interest.