By Sarah Porter
At the 2020 Alliance Annual Conference in San Francisco, CA, attendees had the opportunity to participate in a session titled CPD Escape! The session was modeled after popular escape rooms, often employed as team-building activities. An escape room, or escape game, is a game in which a team of individuals work together to identify clues, solve puzzles and complete tasks in one or more rooms in order to “escape” within a designated amount of time. CPD Escape! required session attendees solve multiple CPD compliance cases, grounded in the ACCME’s Standards for Commercial Support. The team that completed all cases in the least amount of time won this CPD-focused escape game. Five of the cases are included below to facilitate you engaging in your own CPD Escape! with your colleagues. Play along! Read the statements below, make your guess and then click to see the explanation.
Case 1: Valued Validity
Click here to download Case 1. The scenario describes an interaction between a commercial support funder and the accredited provider to validate content for a commercially supported activity. This scenario should be reviewed for compliance with the requirements set for by ACCME’s Criterion 7, Standard 1. Is the interaction appropriate? Why or why not?
Case 1 Answer: This is not acceptable behavior because the accredited provider must maintain independence and ensure that all decisions related to planning, presentation and evaluation of content are made free of control of a commercial interest (ACCME Criterion 7, Standards for Commercial Support 1.1).
Case 2: Attainable Attestation
Click here to download Case 2. This Attestation Form is a template utilized to vet potential joint providers to ensure they are not an ACCME-defined commercial interest. The form must be reviewed to determine if it would be appropriate to work in joint providership with the organization. Two answers are required: Should Armstrong, Inc. work in joint providership with Smith, LLC? Why or why not?
Case 2 Answer: No, Armstrong, Inc. should not work in joint providership with Smith, LLC because Smith, LLC has a parent organization that, based on the overview of the company, meets the definition of an ACCME-defined commercial interest even though they marked “No.” A commercial interest cannot take the role of non-accredited partner in a joint provider relationship (ACCME Criterion 7, Standards for Commercial Support 1.2).
Case 3: Dratted Disclosure
Click here to download Case 3. The Disclosure Form included in this case is a template form to be reviewed for compliance with the requirements set forth by ACCME Criterion 7, Standard 2. One compliance issue must be identified although there are several issues.
Case 3 Answer: One answer is required. This disclosure form 1) does not include the correct and complete ACCME definition of a commercial interest; 2) does not include relationships over the 12 months prior to the involvement in the activity; and 3) does not include “any amount” for the financial relationships. As such, if this form was utilized, those individuals in a position to control content have likely not disclosed all relevant financial relationships with ACCME-defined commercial interest to the accredited provider. This violates the expectations set forth by Standards for Commercial Support 2.1.
Case 4: Robust Resolution
Click here to download Case 4. The Clinical Content Review Form in this case is a template form to be reviewed for compliance with the requirements set forth by ACCME Criterion 7, Standards for Commercial Support 2. One compliance issue must be identified for this case.
Case 4 Answer: One answer is required. This particular resolution mechanism, a clinical content review by a non-conflicted, independent content reviewer is not an appropriate resolution mechanism to employ for an individual whose role is a planner (Jane Smith, MD), as it does not address the role that planners have in controlling decision prior to content development. This violates the expectations set forth by Criterion 7, Standards for Commercial Support 2.3. As a faculty member, Dr. Alice Smith’s resolution mechanism would be appropriate.
Case 5: Loaded LOA
Click here to download Case 5. The Letter of Agreement (LOA) in this case is a template form to be reviewed for compliance with the requirements set forth by ACCME Criterion 8, Standards for Commercial Support 3. One compliance issue must be identified.
Case 5 Answer: One answer is required. The Letter of Agreement does not specify the purpose of the commercial support. It is not indicated whether support is monetary or in-kind, and no mention is made as to how the commercial support will support the CME activity. This violates expectations set forth by ACCME Criterion 8, Standards for Commercial Support 3.4.
We hope you’ve enjoyed this virtual edition of CPD Escape! If you’re looking for a way to interactively engage your team’s CPD professional development, try developing your own CPD escape game using tricky situations or challenging cases you’ve experienced within your own accredited program(s).