Transcript Slide 1

CME Under Fire
THOMAS SULLIVAN
President
Rockpointe Corporation
March 6, 2009
Disclosure
• Rockpointe is a Science based Medical education company
of 25 full time employees based in Columbia Maryland
• The Potomac Center for Medical Education is an ACCME
accredited provider and receives financial grants from
pharmaceutical and device manufactures
• I am committed to the free flow of ideas in CME and support
the current ACCME Standards for Commercial Support™
• Author of the website policy and medicine
www.policymed.com
What is CME
• Continuing medical education is important for:
– Everyone in the field of medicine
– Maintenance of competency/ licensure/board
certification and hospital privileges
– Uptake and the free flow of new information and
practices
– Translation of 150,000 journal articles published
each month
Certified CME:
• Education produced by an accredited CME provider
(not easy process)
• Complies with ACCME and other accrediting bodies
standards
• Complies with federal compliance FDA/OIG
guidance
• Content and delivery are independent of supporter
(commercial) influence
• Complies with the AMA definition of CME
• Does not pay for participation, expenses, travel
Promotional Programs – Non CME
Events/Courses
• Promotional Education
– Pharma or Device company directed
– Must stay on FDA Label
– Reviewed by FDA and HHS IG’s office
– Can not be altered by speakers
– Designed to familiarize HCP’s with approved Drugs/
Devices and approved indications
Financial Support for CME
• 50% from private and public sources
(subscriptions and attendee fees)
• 50% from grants including industry support
• Grants Represent $1.2 Billion of support
(2007)
• Little support from public health, insurance
companies, hospitals/health systems,
universities
Regulatory Stakeholders in CME
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FDA
HHS IG
Congress
States Attorney Generals
State Legislatures
Corporate Integrity Agreement s
PhRMA -- AdvaMed
CMS
ACCME
AMA , AAFP, ACPE, ANCC, State medical boards
How is CME regulated
• Federal and ACCME rules require that accredited
providers:
– Ensure that content is evidence based
– Conflicts of Interest Disclosed and Resolved
• Speakers, staff, writers….
– Independence of Provider
– On-Site Audits
– Public Disclosure of Accreditation Status
Physicians Choice
CME agenda is controlled by medicine
Physicians are not paid to attend CME
Participation is voluntary
Physicians evaluate for Bias
Varied CME opportunities: associations, journals,
internet, meetings
• Quality wins out
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Points to Consider with CME
• Commercial and Public Interest are not
incompatible
• No evidence that commercial bias is harmful or
wide spread
• Changes accelerated over last four years
• No viable alternative to funding
• Changes in regulations can have profound effect on
patient care especially in rural and inner-city areas.
Revised PPSA 2009 and CME
• Reporting Payments over a cumulative value of
$100 dollars.
• Requires Reporting of:
– Honoraria, Food, Travel, Education
– Compensation for serving as a faculty member or
as a speaker for a continuing medical education
program
– Grant
– Any other nature of payment or other transfer of
value as defined by the secretary
• Collection of Medicare Billing Number
PPSA 2009 Language (Direct Payments)
• Provides a payment or other transfer of value to
covered recipient (or to an entity or individual at the
request of or designated on behalf of a covered
recipient)
• Question – Does this exempt reporting information
on CME participants and faculty and if so how?
PPSA 2009
Compensation as a CME Faculty or Speaker
• Local CME Providers
– Must provide “timely” information to supporter on
speaker compensation, travel and incidental
expenses
– Manufacturers will be hesitant to give small grants
• Multi Supported Programs
– Would you apply the full payment to the physician
to each supporter.
• Drive away non-conflicted faculty
PPSA 2009
Collection of Medicare Billing Number
• For CME events and activities this could be
considered a problem due to identity theft
• Physicians don’t know this number or readily give
this out
PPSA 2009 Payment Application
• If the payment or other transfer of value is related to
marketing, education, or research specific to a
covered drug, device, biological, or medical supply,
the name of that covered drug, device, biological, or
medical supply.
• Question: CME is not brand or device specific, and
the language directly references education what is
this meant to capture?
PPSA 2009 Effect on Exhibits at National
Meetings
• Reporting cumulative payments of $100
– Negative effect on convention business
– Exhibits would have to keep track of
• Educational Items Distributed and Value
• Coffee/Tea stations at exhibits (would have to swipe
your card for coffee)
• Will reduce overall traffic to exhibit (physicians
hesitant from giving their information just because
they visited an exhibit hall)
Changes to Report
• Physicians but not Manufactures can change report
• No resolution for physicians to change prior to the
publishing of the report.
Pre-Emption
• No Pre-emption of additional requirements
• Without some type of true pre-emption, states will
be able to pass additional restrictions (this could
become a never ending process)
American Academy of Family Physicians
Goals
• Minimizes the administrative burden that reporting
requirements would place on physicians;
• Enables the physician to correct incorrect reporting data
before the companies releases it for publication; and
• Ensures the reporting requirements do not have a chilling
effect on efforts to educate physicians about research and
new developments in diagnosis and treatment.
For More Information
• Thomas Sullivan, Rockpointe
[email protected]
www.policymed.com and www.rockpointe.com
• John Kamp, Coalition for Healthcare Communication
www.cohealthcom.org
[email protected]