If you follow @CME_Scout on Twitter, you
know I like to report on the latest news and trends that affect how we do our
jobs in the continuing medical education (CME) space.
So last week I chose to pay the $129
registration fee to attend the annual meeting of accredited CME providers
hosted by the Pennsylvania Medical Society (PAMED) in Harrisburg.
Here’s a quick recap, written for Linda, a CME colleague in Media who didn't have time to
go.
The 8:15 a.m. overview was short on
specifics of areas of non-compliance and areas for improvement, as promised on
the original agenda. Instead, Barbara Dugan, associate director for CME at the
Pennsylvania Medical Society (PAMED), followed a revised agenda and spent a
great deal of time on a participatory exercise aimed at familiarizing attendees
with ACCME's simplification initiative. (See photo 1 below.) We received a
good, color-coded handout in our packets related to this topic. To me, ACCME
simplification is long overdue. As a board-certified editor, I've often found
the wording of ACCME criteria to be obscure and redundant.
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| Photo 1: Participatory exercise related to simplified ACCME criteria |
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| Photo 2: Example of a simplified ACCME criterion |
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| Photo 3: A key terminology change |
The 9:45 a.m. presentation on the Sunshine
Act was given by Sterling North, director of continuing professional
development at Geisinger Health System, and Justine Rubino, certification supervisor
at University of Pittsburgh Medical Center (UPMC). They used slides developed
by Barbara Barnes, MD, MS, associate vice chancellor at UPMC and vice president
for sponsored programs, research support, and CME at UPMC.
North's presentation raised more
questions than it answered. North, by his own admission, is not an expert on
this topic and could not answer many questions from the floor, at least not in
a convincing manner. "I don't want to be an expert on the Sunshine Act,
quite frankly," North told us. "Here's another thing that we're being
faced with . . . I'm not an expert, I'm dealing with this just like you guys
are."
For example, Barnes' slide deck did not
emphasize the fact that honoraria paid to faculty of ACCME-accredited
educational activities are exempt from reporting under the act. This seems like
it would have been important information to include, given the fact that the
audience for the day-long meeting consisted of accredited CME providers from around
the state. This point did come up during Q&A however, because I asked about
it. Leslie Howell, director of CME, training, and physician leadership programs
for PAMED, confirmed that faculty honoraria for ACCME-accredited programs are
exempt from reporting, but added there is a complicating wrinkle: what about
programs accredited indirectly, through state medical societies? According to
Howell, the majority of accredited CME providers in the United States fall into
this category. Howell recommended taking a hard line on this issue, insisting
that providers accredited directly by the ACCME and those accredited indirectly
through their state medical societies all report data annually through the same
PARS portal and are therefore all a part of the same system, so the exemption
holds.
Barnes' slide deck was moderately helpful in
other areas. Here are 4 highlights of what she considers the implications for
CME:
1. Payments to teaching hospitals for
commercial support and exhibits will be reportable.
2. It is likely some companies will also
report for non-teaching hospitals (there is nothing to prevent them from doing
this).
3. Although it is not required, companies
may try to report "directed" payments to physicians in accredited CME
activities for honoraria and meals.
4. Payments to hospitals and directed
payments to physicians for meals and speaking will be reportable for non-CME
activities.
Questions from the floor reflected
physicians' concern regarding what conclusions may be drawn from these data
once released to the public. Another person wondered how the ACCME's definition
of "commercial interest" aligns with the federal government's
definition under the new open payments system. There was also considerable
discussion of whether medical trainees (residents) are covered, and whether
physicians who are no longer seeing patients are covered.
Ms. Rubino offered her perspective that drug
companies do not seem to understand the law. There is a common theme of wanting
to overreport, and they seem to collect a great deal of information they don't
need. There is also a great deal of variation among companies with respect to
the information they are gathering. Her job within a centralized office at UPMC
allows her to survey a wide range of agreements with many commercial supporters
and she sees "no consistency" on key points such as meals and types
of participants required to report. "It's not standard by any means,"
Rubino said.
One of the most helpful parts of the
presentation was provided by Ms. Rubino, who distributed a handout containing
examples of language taken from actual letters of agreement (LOAs) that UPMC
has executed with various commercial supporters and exhibitors. She gave
us 6 examples from LOAs and 2 examples from exhibits. The most egregious
example of overreporting given was example 6, in which the commercial interest
informed UPMC that the following data would be collected for each
"transfer of any value" to a U.S. physician:
1 address
2 professional type
3 specialty
4 NPI#
5 state license number
6 state of license
7 non-US license
8 date of payment
9 total amount of payment
10 currency of payment
11 form of payment
12 nature of payment
13 expense type
14 product
15 therapeutic area
16 city, state, and country of travel
Pretty amazing, eh? Seems like Big Pharma
may be trying to make a virtue out of necessity here, gathering as much
physician data as possible since this is required by the Sunshine Act anyway,
with the hopes of being able to use the data for other purposes, perhaps sales
and marketing and direct mail, at a later date. The vibe in the room full of
many hospital-based physicians was one of disbelief, mistrust, anger, and
frustration.
Which reminds me: the meeting was aimed at
directors, coordinators, and chairs of CME from both accredited and
non-accredited community hospitals and medical specialty societies in
Pennsylvania. There appeared to be roughly 60 people in attendance, including
faculty and presenters. (See photo 5)
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| Photo 5: Meeting room setup. Leslie Howell sits at far left. |
The "Leading from the Middle"
presentation by Donald Hess, MD, MPH, was interesting, engaging, offbeat, and a
little too long. Linda didn't ask about it so I won't elaborate. Same for the
fish bowl exercise in problem-based learning.
The final panel discussion consisted mostly
of elderly physicians quizzing a bright, young, and obviously competent
hospital CME director on how she produces short e-learning modules on a variety
of topics using Adobe Captivate software and how she then attempts to measure
changes in physician competence and patient outcomes afterwards.
The wrap-up and final Q&A got bogged
down in the nitty-gritty details of CME committee work and, in my view, missed
any mention of the elephant in the room: What is being done to save vibrant and
effective CME at local community hospitals in Pennsylvania, which are so
obviously on the brink of extinction?
