A legal advisory from the American Medical Association (AMA) presents the Sunshine Act reporting requirements for continuing medical education (CME), and concludes that AMA certified and ACCME accredited programs "are exempt from reporting by commercial supporters." Consistent with the October 2014 guidance issued by the Centers for Medicare and Medicaid Services (CMS), AMA concludes that when an “applicable manufacturer conveys ‘full discretion’ to the continuing education provider, those payments are outside the scope of the rule” and thus, not subject to reporting. AMA goes on to highlight the strict firewall that exists between commercial supporters and CME program participants, adding that "the rules of accreditation strictly prohibit any commercial supporter from having any direct or indirect influence or control with respect to the content, faculty, speakers, or attendees of an AMA certified or ACCME accredited educational program or activity."
| AMA Guidance on CME Sunshine Act Exemption |
