One of the areas of greatest question to our clients has been what constitutes acceptable documentation of compliance with the new Engagement with the Environment Criteria 16‐22. Recently the ACCME issued “Notes and Extracted Examples of Compliance based on November 2008 Provider Performance,” which has provided additional clarity on appropriate documentation for these updated criteria. In the last issue of this column we discussed Criteria 16-20. Now we address the remaining two criteria in this section of the Self Study.

Criterion 21—“The provider participates within an institutional or system framework for quality improvement.”

ACCME NOTE: Evidence of the integration of, and contribution by, the CME provider in healthcare quality improvement.

From Denise: Does the provider (including representatives from the provider) have any direct links to quality improvement activities, either at the institution or through a joint sponsorship relationship? Any links to state or national QI initiatives?

Other Insights from SP&A

• This criterion requires that the provider look both internally and externally to show that CME is a tool used to improve quality, that it’s focused on patient outcomes, that is relates to patient safety issues.
• Some external relationships to look toward to provide these links are national quality organizations such as the National Committee for Quality Assurance (NCQA) [http://www.ncqa.org], Agency for Healthcare Research and Quality (AHRQ) [http://www.ahrq.gov], the Leapfrog Group for Patient Safety [http://www.leapfroggroup.org],and insurance carriers and risk management companies.
• Additional reading: Berwick et al., Connections Between Quality Management and Improvement. Medical Care. 41:1 Suppl; 2003.
• If you are a hospital provider, the Leapfrog Group provides comparative quality data on key diagnostic areas as well as “Never Events” for which Medicare and Medicaid will not provide reimbursement, but more importantly for CME those never events provide prima facia evidence of gaps that should be Priority One for your CME Committee.

Criterion 22—The provider is positioned to influence the scope and content of activities/educational interventions.

ACCME NOTE: Evidence of provider’s control of the development of CME activities from inception to idea evaluation.

From Denise: Does the provider control ALL aspects of the CME Program through involvement of staff, planning committees, advisory committees, and Board of Directors? Is the provider strategically positioned to intervene at each step of the CME planning process?

Other Insights from SP&A

• This criterion gets at the heart of the new system: that CME is not an afterthought but rather a proactive process where the provider sets the vision and leadership to bring about activities that really improve the health of patients and change learner behaviors.
• A performance improvement initiative is a good example of an activity designed to truly change behavior and improve patient outcomes.