In the better-late-than-never department: The Accreditation Council for CME has issued a call for comment on three proposals: one aimed to help balance the need for both transparency and confidentiality in ACCME’s Complaints and Inquiries Process; one that would bring knowledge-based activities into the accreditation system, joining competence, performance, and patient outcomes; and one that proposed to revise how ACCME recognizes state and territory medical societies as CME accreditors.

Complaints and Inquiries Process proposal. You can listen to ACCME chief exec Murray Kopelow, MD, explain it here, but basically it’s a followup to last year’s update, which allows ACCME to reserve the right to make public information such as what the complaint is and the outcome of ACCME’s inquiry. It also follows on the heels of some criticism ACCME received last year over how it handled a complaint.

Anyway, here’s the proposal:

1.The identity of providers who have an activity found in Non-compliance from the Complaints and Inquiries Process will remain confidential.



2.When the accreditation status of a provider is changed as a result of the Complaints and Inquiries Process, the new status will be public information, but the reason for the change in status will not be disclosed.




3.The ACCME will make public some of the facts, circumstances and findings of the Complaints and Inquiries Process in a form and manner that is instructive to providers and stakeholders without linking the information (e.g, the nature of the complaint, type of activity, the practices of the provider, the findings of the ACCME, and the changes made by the provider in response to the inquiry) to a particular accredited provider.

Knowledge-based activities proposal. (Dr. Kopelow’s audio explanation here; overview and comment form here). This one proposes to add the word “knowledge” to Criteria 1, 3, and 11, which it dropped in the 2006 overhaul in favor of activities that are designed to change learners’ competence, performance, or patient outcomes. But while knowledge-based activities are important too, ACCME says “we are concerned that activities and programs designed solely to change knowledge may not fulfill accredited CME’s responsibility to be accountable to the public and may not align with current U.S. quality and safety initiatives.”

So ACCME offers two options, one of which would add the word “knowledge” into the criteria, and one that would leave the wording as is, but would add: “Providers can present some activities that are designed to change knowledge. However, the provider’s overall CME program must focus on changing competence or performance or patient outcomes. Providers must include those goals in their mission (C1) and must analyze the impact of their overall program to determine if those goals have been achieved (C11).”

The third proposal concerns “a new and simpler procedure for receiving and analyzing information from Recognized state and territory medical societies.” (Dr. Kopelow’s audio explanation here; overview and comment form here). It sounds like this one is asking that the process for verifying compliance with the Markers of Equivalency be an ongoing one, rather than episodic. This one is pretty detailed; go to the above links for all the particulars.

I urge you to make your feelings known before the March 8, 2010 deadline. You have up to 500 words to get your points across on each proposal. You do have to sign your name to your comments, and ACCME asks that you keep your comments constructive.