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.

Criterion 16:

ACCME Comments

The provider operates in a manner that integrates CME into the process for improving professional practice.

From Denise: Does the educational mission of your organization integrate the CME program into the system-wide focus on improving professional practice? Do your organizational performance improvement initiatives include CME activities? Documentation may include focus groups and/or interviews with learners in your target audience intended to gain a more clear understanding of the nuances of the current practice environment so as to better define a process for improvement; examples of Performance Improvement (PI), Point of Care (POC) or self-directed learning opportunities; any sequential learning reinforcement of CME initiatives.

ACCME NOTE: The provider goes beyond activity planning to show that CME is used as one of the tools to improve the professional practice.

Insights from SP&A

• This criterion gets at the heart of the new system: that CME is a tool used to improve quality, that it’s focused on patient outcomes, that is relates to patient safety issues, and that CME is not an afterthought but rather a proactive process.

• Get away from responding to available supporter money that spurs CME development; instead, use your CME Committee or Advisory Board to initiate interventions relating to high areas of need. Look at your content areas of excellence and build interventions that address big gaps that are revealed in your research.

• Build a mix of multiple interventions that together will enable sustained behavior changes, and use PI and POC activities in your mix.

Criterion 17:

ACCME Comments

The Provider utilizes non‐educational strategies to enhance change as an adjunct to its activities/educational interventions.

From Denise: Consider using qualitative patient focus groups or quantitative surveys for information and
ideas about these types of activities. Examples of supplemental learning tools or mechanisms used to
reinforce desired educational results are: algorithms, patient education tools provided to the physician learner, reminder mechanisms (bulletins on changes or new regulations), office staff support materials, links to websites for additional information.

ACCME NOTE: Evidence of use of strategies such as, but not limited to, rewards, process redesign, peer review, audit feedback, monitoring, reminders.

Insights from SP&A

• Almost every activity can use noneducational strategies. Use our most current CME planning document to facilitate this process. If planners don’t suggest using a support tool, press back at them and develop one.

• Remember that under Criteria 11‐15, you need to measure the impact of the non-educational intervention used on the outcomes. Be sure to include questions on these tools when you measure IMPROVEMENT IN PERFORMANCE.

Criterion 18:

ACCME Comments

The provider implements educational strategies to remove or address barriers to physician change.

From Denise: Encourage planners to ask about any barriers that learners are likely to encounter what will derail then from achieving the intended result of the activity. Then facilitate a discussion about how the activity can address these obstacles that prevent physicians from making changes in their practice. Notes from course planners, evaluation summaries, ARS responses or outcomes results that demonstrate the barriers are all appropriate forms of additional data.

ACCME NOTE: The provider has data and information that explains patient outcomes, beyond the performance of their learners.

Insights from SP&A

• This is an example of thinking outside the box—a key determinant of those providers receiving Level 3 status. Don’t just go through the motions when planning; always be looking at the behavior change that is the hallmark of a CME activity. What might come in the way of learners attaining the results you intend? This is what Criterion 18 addresses.
  

• Again, the latest version of the CME Planning Document facilitates the identification of barriers.

Criterion 19:

ACCME Comments

The provider implements educational strategies to remove, overcome or address barriers to physician change.

From Denise: Tied directly to Criterion 18, providers must include this strategy in the CME program through
activities where course content is designed to remove or overcome identified barriers. Documentation may
include planning documents, planning notes, course materials and mission statement where barriers are identified in content areas.

ACCME NOTE: The provider has data and information on barriers to change applicable to its own learners, and incorporates these insights into its CME program through activities.

Insights from SP&A

• This is the second part of the process after the identification of barriers. Barriers to achievement of result can’t be allowed to remain unchallenged. Planners must devise strategies to address each barrier identified above, and your documentation needs to be able to show the content that reflects the strategies to dissolve or remove the barrier.

Criterion 20:

ACCME Comments

The provider builds bridges with other stakeholders through collaboration and cooperation.

From Denise: CME today values sharing ideas and best practices and structuring educational partner
relationships that enhance the learning experience. Documentation may include correspondence with a
collaborator regarding input into development or actual involvement in an activity; planning notes that identify the role a collaborator played in an activity or an activity brochure that identifies collaborators.

ACCME NOTE: The provider allies itself with other organizations in a purposeful manner in efforts to
achieve common interests. These collaborations may support any aspect of the provider’s CME program in service of achieving its mission.

Insights from SP&A

• This is more than mere joint sponsorship. It is a “purposeful” strategy to create a team of resources that best supports the activity’s change goals.

• When you start to examine ways that your organization can better connect to various specialty boards that enable you to claim ABMS “PIM” and “SAM” status, you will start to see how important these alliances are to achieving those goals.

• To better under PIMs and SAMs and other aspects of maintenance of certification (MOC), download this PowerPoint presentation www.passinassociates.com/downloads/mocprimer.pdf.

Currently, neither Criteria 21 nor 22 require attached documentation of provider performance, but must
be discussed thoroughly in the narrative of that chapter of the Self Study. More on Criteria 21 and 22 in
the next edition of The Blog.