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Transcript
Andrea Zimmerman, EdD, CHCP: Hello, and welcome back to the Alliance Podcast, continuing conversations. I'm Andrea Zimmerman, senior director of accreditation and compliance at HMP Global. I'm passionate about helping healthcare education professionals understand accreditation in a way that supports innovation and, ultimately, better patient care. Today, I'm thrilled to be joined by Dion Richetti, vice president of accreditation and recognition at the Accreditation Council for Continuing Medical Education, or ACCME. In his role, Dion oversees accreditation and recognition processes for over 600 accredited providers and 28 recognized accreditors, with a focus on strategy, quality assurance and continuous improvement. Dion has been with the ACCME for the past 14 years, and prior to that was in leadership roles at accredited organizations in New Jersey and Chicago. He trained and practiced as a chiropractor before focusing full-time on healthcare continuing education. Dion, welcome to the Alliance Podcast.
Dion Richetti: Thanks, Andrea, it's really good to be here with you.
AZ: Okay, well, let's hop in and start with the big picture. When you're working with providers, what are some of the most persistent myths about accreditation that you hear? You know the “we can't do X” assumptions that actually turn out to be false.
DR: Yeah, that's a great question. You know, I'm gonna start sort of on a lighter note and talk about the most persistent myths. I think the one that continues to come up and is confounding, because I'm not sure where it came from, is this concept of an obligate pathway. Standard Five requires that providers separate any kind of promotion by ineligible companies from accredited education. That separation can simply be out in the hallway, right, in a live event. The thing that folks seem to continue to think is an ACCME requirement is that you cannot allow a learner to walk past an exhibit or through an exhibit hall before going into an accredited space. Standard Five says as long as they're separate, and it's clear to the learner that they're leaving one area and going into the other, you're good. So, we'd love to see providers not feel so restricted from a space, perspective that way. So it's just interesting that that's hung on. But on a more sort of contemporary note, one of the things that we hear is, “well, there's no way that I could use AI, artificial intelligence, or large language models in the development of an accredited CE activity.” And really, there are so many ways to be creative and use this, but be cautious. So there's no, at this point, prohibition on the use of artificial intelligence as a tool, as long as, just with any AI activity that you do, or any work that you do with AI that there's a human behind it who's checking it. The Alliance has released some really nice guidance on how to incorporate AI into accredited continuing education, and ACCME is working with our partners in joint accreditation to soon release some additional guidance. So we ask that providers, feel comfortable asking us as to what they're thinking about in terms of using AI. And obviously, we don't want to encourage anything where a hallucination might create an issue. And that does happen, as we know, but we definitely encourage providers to explore and use AI as a tool.
AZ: Yeah, that's so interesting, in both of those examples, it sounds like there really is a lot of freedom, as long as there is caution, and people are just taking the steps to be careful. So, once those misconceptions take hold, they can really shape how people design activities?
DR: Yeah, I mean, so one way that I've approached looking at our requirements throughout my career has been really to think of it as a framework that allows you to really fill in the matrix. And as a provider, if you understand the spirit behind the requirements themselves, then you can have a lot of freedom, both in the design and evaluation of your activities. If you think about misconceptions that might impact someone's creativity or diversity in formats. One of the things that we've worked very hard at is to say, “yeah, we have a list of formats to enter activities in PARS, but they're not meant to constrain.” Right? They're just a way to, categorize and sort. So we often see that folks say, “well, I don't know if this would meet the appropriate formats criterion, because it's not on that list.” Well, number 11 on the list is “other” or “blended learning.” And we've seen an explosion of providers who are experimenting and trying new things. But if you think that you're constrained by the fact that you can't figure out which one of those items on the list in PARS fits what you're doing, that's not necessarily a bad thing. As long as you understand that the activity needs to be based on a professional practice gap, an underlying educational need, that you're thinking about the end in mind at the beginning, and designing the activity to change competence or performance or patient outcomes, that you've got a way to ensure that the activity is free of any kind of commercial bias, and that you have a method to analyze the changes that you want to see, the sky's the limit. You know, there's so much that you can do. And in today's digital environment, that creativity really is wide open.
AZ: Yeah, can you help us understand that a little bit? Since you've mentioned the other category. Are there a couple of examples that you've seen of something that is creative in format that has come through that people are trying? Maybe that will help our listeners expand their perception of what's possible.
DR: I mean, we've seen things that are really esoteric, like incorporating, art and creativity into a CME activity. Whether it was having a CE activity that took place at a museum of art, and connecting that to talking to patients about feelings, about coping with disease and cancer and sort of opening the learner's minds up to being able to better communicate, to using social media, using snippets on TikTok as part of a CE activity, that reall push the boundaries maybe a little bit, but is perfectly acceptable. We see that providers sometimes think they have to have, this comes back to the myth thing a little bit, certain elements. And, “well, I couldn't do that because there's no physician involved.” Right? A common misperception at ACCME is that our providers think, “well, because my accreditation allows me to provide continuing medical education for physicians, means that you have to have a physician on the planning committee. Or there has to be a physician who reviews content.” And that is not the case at all. So we ask folks again to think about what you're trying to accomplish. What’s the end you want for your learners? And that may or may not require someone with MD or DO credentials to actually participate in the planning or the delivery of the activity.
AZ: Yeah, that's a good point. I imagine it can be really frustrating when innovation gets stalled for no real reason. Can you share an example of a planning decision where someone thought they weren't compliant, but actually were? Or in reality, they had more flexibility than they realized?
DR: Yeah, a great example is, you know, with the release of the standards in 2022, we made it clear that when there's no opportunity to insert commercial bias, that you don't have to go through any of the elements of Standard Three. You don't have to collect disclosure, you don't have to assess relevance, you don't have to mitigate and you don't have to disclose. Right? So, if, for example, you think about that activity where the learners were in the art museum, for example, and it was really about communicating with patients. The provider have often thought, “well, I can't do this because there really isn't an opportunity for me to collect disclosure or disclose anything.” But knowing that they were free from having to do any of those processes because there was no opportunity to insert commercial bias meant that they could have done it because none of those aspects were required. So, again, it comes down to thinking about the spirit of the requirement. If you understand that disclosure is really about the relationships that individuals in control of content have with these companies that produce, market, sell, resell or distribute healthcare products used by or on patients, but if there's no opportunity for some influence to occur toward those products, that whole process can be off the table. So, one reason that I think the task force that came through with the standards wanted to put that front and center was to liberate folks who were doing CE activities that don't provide that opportunity. You know, don't provide an opportunity for bias to be inserted. There are things that folks think are sacrosanct, like, “oh my goodness, it's apostasy to not have disclosure in CME in the same conversation.” Well, there are times where disclosure is a distraction, and you just don't need it. Right? Because the whole purpose of it isn't part of the education.
AZ: Yeah, that's a really good point, and I like how you were talking about the spirit of the standards and what is meant for educating our CPD professionals. But that's really difficult, too, don't you think? Because, so many of us are trying to make sure that we're meeting the accreditation standards, we know that we are going to have to apply for renewal and be able to demonstrate how our activities meet the standards and the guidelines, and so many of us are looking for it to be written out on paper. So how do you distinguish, or what would you suggest to providers of accredited continuing education?
DR: Yeah, so in no way do I want to minimize the effort and the importance of being accurate and precise in the work that you do as an accredited provider. When we talk about this matrix, you really do need to understand the concepts of the criteria and have processes and procedures that will ensure that you stay within those boundaries. When I say, “first learn the spirit,” I mean before you worry about how you're gonna fill in the matrices, right, that you understand the boundaries and where they are now. I tell a story pretty often about how when I first started as a compliance director in CME, I was nervous, and my boss said to me, “relax, it's not tax law, there's only 22 rules.” And that's true, right? You first start reading the criteria and the standards, and say, “okay, do I get what's here? And then, where is ACCME more precise? Where do I need to be more careful?” And that's in the standards, right? Which is why we have just a cornucopia of educational opportunities for folks to support them in understanding this area, where we are very precise, right? So, if I was going to give a provider guidance on where should you spend your time, I would say, a) if I do activities that are really focused on, or that include, how to use or when to use any kinds of healthcare products, then I better know about relationships and how to manage them really well. If, however, my focus is, “well, we really need to be, working on evaluation.” Well, there's a whole lot more flexibility on evaluation. If you understand more levels and know what the minimum requirements are for ACCME, your analysis of change is you have so many options that you can be a lot more flexible. So if you understand where the floor is, and that the floor is higher for things that have to do with the standards than for other parts of your CME activities, you know where you have to be more focused on the details. And again, it comes back to understanding why we're doing this. So, and I think I've lost your question in there somehow in my rambling…
AZ: No, you're right on track.
DR: Okay.
AZ: Yeah, can we expand on that a little bit? From your perspective, how can accreditation bodies do a better job of communicating what's truly possible under their guidelines?
DR: Yeah, I mean, I think ACCME is constantly working on trying to do a better job of talking about and working with providers on being successful, because we're all in the accreditation business, not the non-accreditation business, right? So we have focused on trying to be more coaches and less cops. Obviously, you know, we have to draw the line, and we've been asked by the community, and remembering that this is a voluntary, self-regulatory system, everyone says, “I want to be part of this, so I'm agreeing to these regulations.” We have an obligation to make our rules accessible and to be able to support providers in achieving compliance as much as possible. And our data shows that that is true, most providers are compliant with most of our requirements. However, this movement to coach over cop has really spurred us to make a huge investment in support and move away from using the time when folks actually come to a live meeting to lecture them and moving to more active types of learning, focusing on things like case studies. So, we have a plethora of cases available in the free resource, which is the ACCME Academy. And since we've built out that learning management system, every accredited provider in the ACCME system, whether they're state accredited or ACCME accredited or joint accredited, has access to ACCME Academy, which has a growing library of cases. So, studying the rules, you don't have to memorize the rules, right? But if you practice with the cases, and an open book of the requirements, we think that's probably the best way for us to communicate about our requirements, is engaging our providers in practicing them. So our education starts with helping providers understand the spirit. If you take, for example, the course on ACCME Academy on the standards for integrity and independence, there's a lot of emphasis on “why do we ask this? What's the reason we do it?” Right? And then cases, and then the opportunity to ask questions. We have, a question and answer service for all accredited providers that, allows you to, at no cost, ask us a question and get a response.
AZ: How does someone do that?
DR: They email info@accme.org. Now, one of the myths, to come back to myths here, that I want to address is we're not using this to say, “Andrea had a question about Standard Four, we're gonna look at her commercial support application and her reaccreditation differently.” Or, you know, “we're gonna judge that organization for commercial support based on the question.” Really, the folks that ask these questions, get a response, they don't always like the response because we can't tell you what to do, but we can answer specific questions about how to apply the criteria and where the lines are, but that's how we encourage folks to check themselves. If you go to a large meeting, there may not be time to get into the details of your specific circumstance, and that's what info@accme.org is about. We also have a website which is constantly evolving and changing. But it was recently redesigned, and we think it's more accessible. It's the fourth version of the website that ACCME's had during my tenure, and we continue to evolve that. So, as an accreditor, I think we really want to be in communication with our community of the folks that have asked us to be their accreditor. And if you've come to any of our meetings, you'll see that, right? If you participate, I think we have some, upcoming sessions, they're called “Midday with McMahon” where Graham is sort of doing an online regional approach. To really just interact with the community. So we're out there, and ready to talk with the community, and always look forward to that.
AZ: Yeah, I appreciate those, the town halls, the Annual Meetings where you can go and get lots of information. You recently had a workshop for newcomers, right?
DR: Yeah, every year we do an Accreditation Workshop. We used to do these three times a year here, and we found that with all of the information we now have online and the fact that travel s sometimes an issue for folks, doing it once a year, we bring about 200 folks to Chicago to interact with us over two and a half days, and really focus on the nuts and bolts of the requirements. Which is different than our Annual Meeting, Learn to Thrive, which is a bit more advanced, and really is an opportunity to focus more on the andragogy, and less on the rules, while the Accreditation Workshop is all about the requirements, and really working in community with other providers who are at the same level as you are and we break out into groups that meet throughout the workshop to discuss each of the areas of the criteria with expert faculty facilitating these discussions. So it's not two days of lectures, it is two days of really interactive, deep dive into the criteria, and has been really popular, and for us as staff, it's a whole lot of fun to get to meet folks who are, particularly those who are newer to the system. And we've seen that, most of the experienced folks will tend to be focusing on Learn to Thrive, while those in the first five years of their caree, and some others who want a refresher, but for the most part, it's folks who are early in their career who come to that meeting. And it's in August in Chicago, which is a great time to be in Chicago, usually.
AZ: Yeah. Well, it's better than some other times.
DR: Yes, better than December, January.
AZ: Two other resources I was thinking about that I actually really appreciate. One is a podcast, which I think you can find on any podcast app. It's called “Coffee with Graham.”
DR: Yeah.
AZ: Yeah, I don't know if you've seen a lot of popularity out of that?
DR: You know, we have seen that grow, and Graham has become a bit of a social media influencer. So that podcast is growing, and he has some really interesting topics that he does and talks with folks in the education space.
AZ: Where else is he on social media?
DR: Well, we’re active on LinkedIn, Facebook, Instagram and BlueSky. So you can definitely follow us on all of those platforms.
AZ: Okay, that's a good tip. Another resource that I really like is in the emails that are sent out, and you have, over maybe the past year, year and a half, done a compliance check? I thought that's been very helpful.
DR: The open rates on those are higher than anything else we've ever put out, despite the fact that they throw my picture in there. And we've actually consolidated these into a sort of library on our website. So, if you just put “compliance check” into the search, you'll see that there's an archive of all of the compliance checks. We do them about every other month and we base the topics on these info questions. A large part of our needs assessment there is filtering through our customer response platform to see what's tagged for different areas, along with feedback that we get through the accreditation process and in talking with folks in conversations like this. So we hope that that's been a useful resource, and by enduring it, You can always refer to them if you've lost the email.
AZ: Yeah, no, that's a great point. I didn't know that they were on the website, so hopefully listeners can check there if they've missed them in the past. Just look on the website and search for the “compliance checks,” and they should be able to see that. We also mentioned the ACCME Academy before. If others aren't aware of it, or don't know how to sign up or find it, can you tell them how they can access this?
DR: So, we're kind of a one-stop shop when you want to contact us, by email. So, info@accme.org, and our staff triages these, and our education team, we have two really great team members whose whole job is working on ACCME Academy. So, we'll get you enrolled, we'll make sure that if you need to be connected to the guidance that we have, so there's a whole, like, a whole course on there on how to use ACCME Academy, because there's so much there. So, we really encourage folks to jump into that, whether it's a refresher that you need, or you're new and just starting, there's a course actually for people who are new coordinators at CME offices or CE offices in general.
AZ: Okay. Well, before we wrap up, are there any other practical resources that you'd recommend to our listeners who want to better understand what's allowed, or maybe rethink some of their own assumptions?
DR: So, there's a really cool little video that we recently released that is geared toward your faculty. And it's like a 3-minute video, the dulcet tones of Steve Singer narrate it, and it's just a common sense kind of basics approach to why we do disclosure. And, why we're asking them these intrusive questions, and the purpose of identification, mitigation and disclosure of relevant financial relationships, in terms that anyone can understand, that is just a great way to help faculty understand why they need to complete this disclosure process, and including that as a link to your faculty is, you know, don't make assumptions that they know why you're doing this. And it's only two or three minutes, so it's a great new resource.
AZ: That's a great idea to recommend it for faculty. Thank you!
DR: That's what it was designed for, yep.
AZ: Alright, this has been such a valuable conversation. Thank you for sharing your time and insights. Are there any other last words that you have of wisdom? Anything to share, someone else to connect with, another opportunity in the future?
DR: I just want to say that it's fantastic that, if you're new to this community, connecting with both the Alliance and with ACCME and all of the other accreditors who were involved, there's so much available now that wasn't when I started, a quarter century ago. So, take advantage of what's out there, is the thing I would say, and if you're not sure where to start, feel free to reach out to info@accme.org, and we're happy to help.
AZ: Yeah, thank you so much. Dion, thank you for sharing your expertise and your perspective, and thanks to our listeners for joining us on another episode of the Alliance Podcast, continuing conversations. Be sure to tune in next time as we keep exploring the issues that matter most in CE and CPD.