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.
| CME Coalition Comments on Open Payments.pdf |
