MUSC OCME CME Application
Q: Where can I find applications to request CME credits for conferences or grand rounds?
A: These forms will be provided to you at your preliminary meeting with OCME staff. A CME Coordinator will be assigned to work with you as you begin the accreditation process. The applications are designed to lead you through the steps that will make your CME activity comply with the Accreditation Council for CME (ACCME)'s Updated Compliance Criteria. Don't fail to answer all the questions because missing data means the MUSC will be unable to demonstrate compliance.
Q: What was wrong with the old CME planning forms?
A: The forms had to change because the vast majority of ACCME's Updated Compliance Criteria are new and weren't covered by the old form. Your responses to each question, coupled with the actual artifacts (e.g. Grand Rounds announcement, audience handouts, audience disclosure of commercial relationships, save-the-date cards, course brochure and syllabus etc.) are important because they form the basis for the MUSC’s re-accreditation...and that's what will allow the MUSC OCME to continue offering CME credit. You are an extension of the CME office. Each question in these new planning forms has a purpose and each has been engineered to demonstrate to the ACCME how the MUSC OCME meets expectations.
Q: Is there a fundamental difference between the new and the old planning forms?
A: Yes, there has been a philosophical shift. Now the goal for CME is improving practice. Acquiring knowledge for knowledge's sake or validation of current practice used to be sufficient, but no longer. CME is now all about improvement. That is why the new CME planning forms start by asking you to identify what needs to be improved. That points the direction for how you're going to design the educational activity to accomplish the desired result. Evaluation has also undergone a big change. Now evaluation involves determining if the desired educational result was accomplished. That's all new to CME. That's why MUSC OCME created these new planning forms.
Q: The needs analysis section of the forms asks for an explanation of what needs improvement. Can I just write down what the faculty or audience suggested for topics, or cite something just published in a respected medical journal? View ACCME video tutorial
A: Need for improvement implies that there is a distance between ‘actual' practice vs. what is ‘ideal/achievable'. Expert opinion about the topic or some recent publication probably won't show a gap. However, you may be able to uncover that gap by probing further: ask ‘why?' For instance, suppose the planning committee decided one of the topics should be "Update on < topic>". Is "Update on <topic>" considered a gap just because the planning committee decided that the audience needed an update? No, it's not a gap because "Update" doesn't demonstrate a distance between ‘actual' practice vs. what is ‘ideal/achievable'. However, by probing deeper and asking ‘why?' the basis for the gap might become evident, but if not, the list of suggested questions might help.
Q: What's the difference between ‘knowledge', ‘competence' and ‘performance'?
A: After you have identified the gap between ‘actual' practice vs. what is ‘ideal/achievable', the next step is to assign the root cause for the gap. Analyze if the identified gap is caused by insufficient knowledge (e.g. factual information, or knowing that), competence (e.g. strategies [knowing how] or practical skill/application [showing how]), or performance (e.g. doing). At this point you should be able to develop the desired result for this educational activity.
Q: What does "educational need" mean?
A: The educational need defines the type of instructional method or learning experience that is needed by your learners in order to achieve the ideal behavior that is the goal of your educational activity. For each identified gap reflect on the type of gap and choose the instructional method that will best meet the educational need of your learner. Some examples are:
- Knowledge – expert lectures and presentations to share information/facts
- Competence/Strategy – presenting cases, evaluating guidelines, analyzing best practices
- Competence/Application- interactive small-group case-based discussions, lab activities, role-play scenarios that allow the learner to demonstrate their ability to apply what they’ve learned.
- Performance gaps will be addressed using the same instruction as competence but will be measured several months after the activity to determine if the competence achieved was applied as a change in practice.
Q: What is ‘commitment to change' ?
A: Commitment to change is a simple way of discovering actual changes in the learner's practice that resulted from the educational activity. Learners are instructed to write down those changes in their practice they intend to implement. At 1-3 months in the future, the learner is contacted and asked about the status of implementation of the intended changes, barriers identified, and the next steps identified. They can be used for evaluation at the performance level. The MUSC OCME can provide you with more details and assistance with instituting the commitment to change strategy. Please don’t hesitate to contact them at 843-876-1925.
Q: What are vignettes?
A: Case vignettes are a low tech version of simulation because they allow direct measurement of learners' application of learning through case-based scenarios. They are simple to set up and can be used for evaluation at the performance level. The MUSC OCME can provide you with more details and examples.
Q: Does ‘competence' and ‘competencies' mean the same thing?
A: No, these words have different meanings, and both terms are used in these CME planning documents. Competence means the simultaneous integration of knowledge, skills, and attitudes required for performance (e.g. developing strategies, knowing how and being able to show how to do something). Competencies are general descriptions of the skills and abilities needed to perform the role of being a physician.
Complying with the ACCME Standards for Commercial Support
Q: Who needs to identify their personal financial relationships? View ACCME video tutorial
A: Identifying personal financial relationships is the first step in a 3-step process for assuring the public that the MUSC OCME is an honest broker of CME. The process begins with everyone in a position to control content disclosing their financial relationships. It's not just the presenters who must disclose, but includes everyone who has any decision-making role whatsoever in the curriculum, including all planners and approvers. However, those persons whose only role is logistical support and have no role in the curriculum design or selection should not be asked to disclose because their disclosure is irrelevant and causes a distraction from those who have relevant financial relationships.
Q: How should we identify personal financial relationships?
A: It is wise to be aware of speaker's personal financial interest very early in the planning process in order to avoid being faced downstream with a relationship for which there can be no easy means for its resolution. When submitting your completed CME application to OCME, you are required to also submit completed disclosure forms for the Activity Director, planners and identified presenters or authors. As soon as additional presenters or authors are identified their completed disclosures must be submitted to the OCME also.
Q: Is disclosing a personal financial relationship sufficient for resolving a conflict of interest?
A: No. Since May 2005 the ACCME has required there be a separate process for resolving conflicts of interest.
Q: What is the 3-step process for identifying and resolving conflicts of interest and disclosing financial relationships to the learners?
A: All 3 steps are required by ACCME and MUSC.
- Everyone in a position to control content must disclose their relevant financial relationships. This includes all planners, speakers, moderators, all approvers and any others who can create or influence the instructional content in any manner.
- All conflicts of interest are resolved and that resolution documented through the MUSC OCME process.
- Prior to the start of the educational activity, learners must be informed of any relevant personal financial relationships or the absence of relevant financial relationships for everyone who is in a position to control content, which includes planners and conference committee members as well as speakers. The details of what precisely was disclosed to the learners must be documented.
Q: How should the learners be informed of any relevant personal financial relationships or the absence of relevant financial relationships?
A: When there is a relevant financial relationship, the learners need to be informed of the name of the person with the relationship, the name of the company with whom the relationship exists, and the nature of the relationship. No dollar amounts are to be disclosed to the learners. When there is nothing to disclose, language similar to the following can be used: "<Name of presenter > and no one in control of content, including planners, have any relevant financial relationships to disclose." The method for disclosure may be one or more of the following:
- Printed at the front of the course syllabus or on the speaker's handout
- As part of the any announcements and reminders that are printed or distributed electronically by e-mail
- Inserted as the 2nd slide in the presenter's PowerPoint series (or otherwise shown at the start of the learning activity)
- Verbally disclosed from the podium, with a written attestation, signed by the moderator who was present in the room at the time, containing precise language that demonstrates the required information was disclosed to the audience, with that attestation dated within 1 month.
Q: What needs to be disclosed to the audience when the educational activity receives commercial support from the pharmaceutical or medical device industry?
A: There are two methods for industry to provide money, but only one of these methods is considered commercial support by the ACCME. That is when the company provides money or in-kind support (use of equipment, etc.) without getting anything in return. In contrast, when the course charges a fee for display or advertising space, this type of transaction is not considered commercial support, and like any rental arrangement, it is a straight business transaction. Any mention in course materials of those companies renting vendor space should be separated from the listing of those companies providing commercial support. Prior to the actual education, the names of companies providing commercial support, either by direct payment or in-kind support needs to be disclosed to the learners. In addition to the company name, a company logo may also appear, but never a logo alone. There can be no product-specific references.
Q: What is considered a commercial interest?
A: A ‘commercial interest’ is any entity producing, marketing, re-selling, or distributing health care goods or services consumed by, or used on, patients.
What is meant by a relevant financial relationship or interest referenced on the application and disclosure forms?
A: A relevant interest is any financial relationship in any amount occurring within the past 12 months that creates a conflict of interest. It is a relationship relevant to the role of the individual participating in the activity to control or influence content development. This might include grants, research support, consultant relationship, stockholder, paid honorarium, etc.
Q: When do relationships create “conflicts of interest”? View ACCME video tutorial
A: The ACCME considers financial relationships to create actual 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.
Q: Is the disclosure and attestation form sufficient to identify and resolve conflicts of interest?
A: No, CME activities are now being held to a higher standard than simple disclosure in assuring independence from commercial influences. The ACCME does not accept simple disclosures or disclaimers, on their own, as a mechanism to resolve conflict of interest. The disclosure must be used in conjunction with another mechanism such as peer review to identify and resolve conflicts of interest.
Q: Which agreement should be signed, MUSC OCME or the Company’s agreement?
A: MUSC OCME will sign the company’s agreement if it meets the MUSC General Counsel’s Office grants and contracts standards. If the grant amount changes, either a new agreement must be signed or the amount changed on the original agreement, signed & dated by all parties. Only 1 signed letter of agreement per company per activity can exist.
Q: Who is authorized to sign grant letters of agreement for MUSC OCME activities?
A: Letters of agreement can only be signed by the MUSC Office of CME; we must review and approve all MUSC CME related grants to ensure the grant language complies with CME guidelines. If necessary, the LOA must be reviewed and approved by the MUSC General Counsel’s Office.
Q: What should I do if the commercial supporter asks me to accept the terms of their agreement online?
A: Terms should not be accepted without prior approval by MUSC OCME. As soon as you receive a notice that a grant is approved pending acceptance of the terms, please provide MUSC OCME with your login information or a copy of the original grant request and the electronic agreement terms. MUSC OCME will review the terms and let you know if they can be accepted.
Q: When can I acknowledge commercial support?
A: The grant letter of agreement must be fully executed (signed by MUSC OCME and the company) prior to being announced in marketing materials AND prior to the activity occurring.
Q: Can commercial interests receive exhibit space in exchange for providing CME grants for the CME activity?
A: No, receiving exhibit space in return for providing an educational grant would be placing a condition on the grant and that is not allowed. Selling exhibit space to commercial interests is considered to be a business transaction. Income from selling exhibit space is not considered to be commercial support as defined by the Accreditation Council for Continuing Medical Education. Educational grants should be kept completely separate and distinct from the purchase of exhibit space.
Q: Who is the CME Provider?
A: The official CME Provider is Medical University of South Carolina, not individual Departments or Divisions or MUHA. The CME or Accredited Provider must be listed as Medical University of South Carolina.
Q: Who is the Educational Partner?
A: When MUSC OCME works with an organization that is not affiliated with MUSC in any way, then the organization (aka joint/co-sponsor) must be listed as Educational Partner. If the activity is directly sponsored (no outside involvement), then this field will be “N/A”
Q: What if a company is providing an educational grant AND an exhibit/display fee?
A: Exhibits are considered promotional and therefore exhibit funds cannot be included as part of the educational grant. The company can pay for the grant and exhibit with 1 check, however, the actual grant agreement amount must not include the exhibit funds.
Q: An out-of-town speaker happens to be in town because s/he has been brought here for another purpose. Can we use that person to speak at a CME-certified activity?
A: It depends on what was the purpose of the trip and who paid that person's expenses. If the person's travel expenses were paid for by a commercial interest (e.g. pharmaceutical or medical device industry) or the trip was for commercial purposes, then that speaker most likely has an irresolvable conflict of interest.
Q. Why is it necessary for a representative of the CME office to attend a live CME activity?
The MUSC OCME office as an accredited CME provider is responsible to ensure that all activities are in compliance with the ACCME Accreditation Essential Areas, policies and accreditation criteria. If any inquiries or concerns are raised to the ACCME about the conduct of a Live CME activity that is accredited by the MUSC OCME office, the OCME staff must be in a position to respond to these inquiries or concerns from the ACCME. Thus onsite observation of the CME activity is a means for the OCME office to verify that the activity is in compliance.
OBU August 2010 (updated September 2012)