The CME Coalition has submitted comments to CMS regarding Open Payment’s impact on CME, including the impact on the distribution of journal reprints and medical texts. As the letter explains, “upon publication of the rule in 2016 there was a significant pause in funding for accredited CME as commercial supporters tried to assess the interaction of the rule and its sub-regulatory guidance.” The letter goes on to note that while a majority of stakeholders have interpreted the FAQs to exclude most independent, accredited CME activities from the definition of “payment,” the Coalition remains concerned that “if CMS were to ever make changes to the rule or FAQs to require reporting for independent CME, we would see significant reductions in both funding of and participation in accredited CME programs.” Further, the letter details the extensive barriers preventing the slightest industry influence from entering the accredited educational content that our members support, provide and rely upon — specifically citing the Accreditation Council for Continuing Medical Education’s (ACCME) Standards for Commercial Support (SCS) that have been adopted by many accrediting organizations.
At the 16th annual CBI summit on independent medical education and grants, the CME Coalition's Andy Rosenberg outlined the major legislative and regulatory issues that the Coalition has been engaged in throughout 2018.
The CME Coalition has submitted comments to the State of New Jersey in support of its proposed rule to allow the provision of meals during the course of live CME activities. This proposal represents a reversal of an earlier rule that went into effect in January 2018, which currently limits the value of meals provided to New Jersey doctors during CME activitiess to just $15. As the Coalition explains in the letter, "based on the typical venues used for CME seminars, the original rule’s $15 threshold presents a considerable challenge for event organizers and health professionals." The letter outlines how the cheapest meal options at typical CME venues range from $17 to $35, and commends the Attorney General for proposing to reverse the prior rulemaking.
The public has until October 5, 2018 to comment on the proposal.
In a letter to Centers for Medicare and Medicaid (CMS) Administrator Seema Verma, the CME Coalition urged the agency to provide an exemption for CME and certain educational materials from the reporting requirements of the Physician Payments Sunshine Act. “We strongly believe that commercial support payments for CME that do not meet the Sunshine Act’s definition of payments should be definitively exempted from reporting,” writes CME Executive Director Chris Lamond. “As a nation, we should be encouraging and facilitating accredited physician continuing education, not stigmatizing it by requiring the collection and reporting of payments that underwrite it.” The letter also notes that while the current FAQ #8165 provides CME stakeholders with solid guidance regarding independent commercial support for CME activities, the numerous updates to the policy via these FAQ updates leaves stakeholders with a need for certainty that only a definitive Final Rule can deliver.
Slides: CME Coalition Presentation at the alliance for Continuing Education in the Health Professions industry Summit
On May 8, 2018, CME Coalition's Andy Rosenberg and Tom Sullivan gave a presentation at the Alliance for Continuing Education in the Health Professions Industry Summit in Baltimore, MD. Rosenberg and Sullivan presented information on changes to the Quality Payment Program that involve CME-related activities. They also reviewed variations to state laws and bills that effect CME, as well as other national issues that effect medical education including shared-decision making, the future of the Merit-based Incentive Payment System (MIPS), and the New Jersey gift ban.