Compliance corner: Content Validity, Eligibility and Accreditation

March 16, 2022
Area(s) of Interest: Continuing Medical Education (CME) 

Definition of Continuing Medical Education and Standard 1: Ensure Content is Valid

While separate, the policy for Continuing Medical Education (CME) Content Definition and Standard 1: Ensuring Content is Valid are important areas to consider when designing accredited education.

All accredited activities must begin with ensuring the content of activities meets the definition of CME and assists physicians in carrying out their professional responsibilities more effectively and efficiently. Education that does not meet the definition of CME cannot be accredited.

Definition of CME:

Continuing medical education consists of educational activities which serve to maintain, develop, or increase the knowledge, skills, and professional performance and relationships that a physician uses to provide services for patients, the public, or the profession. The content of CME is that body of knowledge and skills generally recognized and accepted by the profession as within the basic medical sciences, the discipline of clinical medicine, and the provision of health care to the public.

In Standard 1: Ensure Content is Valid, the accredited provider is responsible for validating clinical content to ensure that education is fair and balanced, and that any clinical content presented supports safe, effective patient care.

Recommendations for patient care must be based on current science and evidence, and to protect the integrity of accredited CME, must adhere to the definition of CME noted above.

CME providers need to develop activities that encourage free and rigorous scientific discourse — while ensuring that faculty do not advocate or promote unscientific treatments and that clinical care recommendations are based on established scientific consensus. When a CME activity includes information about an approach to diagnosis or treatment that is not generally accepted, it is allowable to facilitate debate and discussion about the approach, but it is not allowable to advocate for the test or treatment, or teach clinicians how or when to use it.

We encourage you to regularly review these areas to ensure that your process for planning, delivering and evaluating activities includes effective strategies for validating clinical content.

Standard 3: Identify, Mitigate, and Disclose Relevant Financial Relationships – New Definition of Ineligible Company

The new Standards for Integrity and Independence in Accredited Continuing Education became effective for all activities January 1, 2022. Within Standard 3: Identify, Mitigate, and Disclose Relevant Financial Relationships, the definition of an Ineligible Company changed.

The first step in Standard 3 is collecting information from all planners, faculty and others in control of content about all their financial relationships with ineligible companies within the prior 24 months. The collection mechanism your organization uses must include the correct and complete definition in order for individuals to respond appropriately to these areas.

Below is the definition of an Ineligible Company to ensure that your organization is using the appropriate verbiage on your collection mechanism to identify financial relationships with ineligible companies.

The Definition of an Ineligible Company in the new Standards for Integrity and Independence effective January 1, 2022:

Those whose primary business is producing, marketing, selling, re-selling, or distributing healthcare products used by or on patients.

Accreditation Statement – Who is your organization’s CME Accreditor?

In the January 2022 newsletter, the Accreditation Statement was addressed, along with the requirement to use the statement verbatim. Additionally, we find that some organizations may not correctly identify their accreditor.

The spirit of the Accreditation Statement policy is that the learner is being given information that will tell them which organization is responsible for the activity and responsible for compliance with all accreditation requirements (this is you, the provider), and to whom that organization is accountable for its accreditation.  

The California Medical Association (CMA) is recognized by the Accreditation Council for Continuing Medical Education (ACCME) to accredit CME providers that focus on serving learners in California or contiguous states, such as community hospitals, state specialty societies or county medical societies.

Organizations accredited by CMA will use “California Medical Association (CMA)” in the statements as follows:

For Directly Provided activities:

The [name of accredited provider] is accredited by the California Medical Association (CMA) to provide continuing medical education for physicians.

For Jointly Provided activities:

This activity has been planned and implemented in accordance with the accreditation requirements and policies of the California Medical Association (CMA) through the joint providership of [name of accredited provider] and [name of nonaccredited provider]. The [name of accredited provider] is accredited by the CMA to provide continuing medical education for physicians.

In May 2019, CMA resumed direct management of the CME program from its subsidiary Institute for Medical Quality (IMQ). For activities prior to May 2019, IMQ/CMA was the accreditor.

For additional information, please refer to the CMA CME website.


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