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College of Human Medicine

CME Policies & Procedures

Purpose and Background

The Michigan State University (MSU) College of Human Medicine (CHM) is accredited by the Accreditation Council for Continuing Medical Education (ACCME) to sponsor continuing medical education (CME) for the purpose of increasing physician, and all other health care providers, knowledge, competence, skill, and performance. Therefore, the review and validation of the content of continuing medical education activities is critical to assuring the public and learners that (1) all recommendations for patient care in accredited continuing education must be based on current science, evidence, and clinical reasoning, while giving a fair and balanced view of diagnostic and therapeutic options,  (2) that all scientific research referred to, reported or used in accredited education  in support or justification of a patient care recommendation must conform to the generally accepted standards of experimental design, data collection, analysis, and interpretation.(3)Although accredited continuing education is an appropriate place to discuss, debate, and explore new and evolving topics, these areas need to be clearly identified as such within the program and individual presentation. It is the responsibility of the Office of Continuing Medical Education (OCME) to facilitate engagement with these topics without advocating for, or promoting, practices that are not, or not yet, adequately based on current science, evidence, and clinical reasoning. (4) Organizations cannot be accredited if they advocate for unscientific approaches to diagnosis or therapy, or if their education promotes recommendations, treatment, or manners of practicing healthcare that are determined to have risks or dangers that outweigh the benefits or are known to be ineffective in the treatment of patients.

The Office of Continuing Medical Education (OCME) is the administrative unit at CHM responsible for ensuring compliance with the ACCME Accreditation Requirements (Criteria, Policies, and the Standards for Integrity and Independence in Accredited Continuing Education), as well as other regulations and policies as they relate to the provision of CME. 

The MSU College of Human Medicine Office of CME requires that the following policies and procedures be followed throughout the development and implementation of CME activities. The following requirements are in addition to the ACCME Criteria, Policies, and Standards for Integrity and Independence in Accredited continuing Education.

General Definition of Acceptable Content of CME

The Accreditation Council for Continuing Medical Education defines content that is acceptable for CME as:

Continuing medical education consists of educational activities which serve to maintain, develop, or increase the knowledge, skills, and professional performance and relationships that a physician uses to provide services for patients, the public, or the profession. The content of CME is that body of knowledge and skills generally recognized and accepted by the profession as within the basic medical sciences, the discipline of clinical medicine, and the provision of health care to the public.

Activity Leadership

Activity Director

The Activity Director is the MSU CHM faculty member or employee of the joint sponsor institution who is responsible for planning, developing, implementing, conducting, and evaluating the CME activity.

Activity Co-Director

The Activity Co-Director shares responsibility with the Activity Director. If the activity is jointly provided, either the Director or Co-Director must be a MSU CHM faculty member.

Administrative Facilitator

The Administrative Facilitator is the staff person responsible for operational and administrative support of the activity and not in control of content.

Independence

Educational activities shall be planned and the content controlled by the provider or  joint providership, including identification of the need/gap in practice and competencies to be addressed, objectives, selection of speakers, educational methods and evaluation; the ineligible company(ies) shall have no involvement or influence over the activity. Request for “technical review” of the activity content by  an ineligible company will not be accepted.

  1. Final authority for all areas relating to the ACCME Criteria, Policies, and Standards for Integrity and Independence in Accredited Continuing Education will be retained by the OCME.
  2. All faculty, meeting, and marketing logistics are to be appropriately handled by OCME staff or their designee(s). Representatives from an ineligible company cannot provide meeting planning or faculty coordination functions. 
  3. Information on the identity of learners at CME activities is considered confidential and the property of OCME. Information on learners will not be released to third parties.

Identification and Resolution of Conflicts of Interest

The OCME is required to have a mechanism to identify and resolve all conflicts of interest prior to the educational activity being delivered to learners. Therefore, all individuals who are in a position to control the content of an educational activity must complete a disclosure form prior to an educational activity. By completing the disclosure from the individual is attesting that they have read and agreed to abide by this policy and that any and all clinical recommendations that they make for patient care as part of their planning or CME presentation, the activity materials will be based on the best available evidence, that they will give a balanced view of therapeutic options, and that the content will be in accordance with ACCME’s Content Validation Statement.

Identification of Conflicts

For an educational activity, all individuals involved in control of the content must disclose relationships with an ineligible company if the relationship is financial, occurred within the past 24-months and is relevant to the content.

Financial relationships are those relationships, in any amount, in which the individual benefits by receiving salary, royalty, intellectual property rights, consulting fee, honoraria, ownership interest (e.g., stocks, stock options or other ownership interest, excluding diversified mutual funds), or other financial benefit.

Both the presence and absence of financial interest must be disclosed to the audience for all individuals involved with the content of the activity. A Conflict of Interest Disclosure Form must be completed by:

  1. CME Committee members or other reviewers of content annually
  2. each individual involved in the planning at the initiation of the planning process
  3. each speaker/presenter, moderator, panel member, author prior to the presentation

Should a potential conflict of interest of anyone involved with the content of the activity be identified from the Disclosure Form, this conflict must be mitigated according to the Conflict of Interest Mitigation Policy.

The audience must be made aware of any financial interest a speaker may have as well as the off-label use of a product that the speaker may be discussing in the presentation. In addition, any financial interest of a planning committee member, CME activity director(s), member of a panel or moderator must be disclosed to the audience. This must be accomplished by an acknowledgement in the notice of the meeting such as in the handout materials or syllabus.

Resolution of Conflicts

Courses

The OCME will review all disclosure forms for activity directors and planning members, speakers/presenters, moderators, panelists and authors prior to an educational activity receiving approval.

Regularly Scheduled Series

The OCME will review all disclosure forms for activity directors, planning members and speakers/presenters for the first two sessions prior to the activity receiving approval. Disclosure forms for subsequent sessions must be completed ten (10) business days prior to the session taking place. In the event the OCME finds the potential for a conflict of interest of anyone in control of the content of a CME approved educational activity, one or more of the following actions will be initiated to allow resolution to occur.

Conflict Mitigation Actions

CME Activity Directors and Planning Committee Members:

  1. Complete the online CME Conflict of Interest Disclosure Form prior to submission of the activity CME application packet. Applications will not be reviewed until all activity directors and planners complete disclosure. CME staff will review all completed Conflict of Interest Disclosure Forms and identify the best course of action.
  2. If no conflict is identified, then no additional action is required prior to the CME approval process.
  3. If a conflict is identified:
    1. Activity directors with a relevant conflict will be replaced with an activity director with no relevant conflicts. A conflict of Interest Mitigation Form (COIM) will be required for all planners prior to the activity being reviewed.
    2. CME staff will review the COIM Form in addition to all planning documents, identified presenters/speakers, and topics to ensure that presenter/speakers and topics represent a balanced, evidence-based medicine approach.
  4. If CME staff feel the conflict(s) are unable to be mitigated, then another faculty member with no relevant conflict(s) may be identified to assist with the planning to ensure independence, the activity director or planning member may be required to be replaced by planner(s) with no relevant conflicts, or the application for CME credit may be denied.

CME Committee Members and Reviewers of Content:

  1. Complete the CME Conflict of Interest Disclosure Form annually or as changes to financial relationships occur (whichever comes first).
  2. Content will only be reviewed by committee members and reviewers who have no relevant financial relationships related to the content under review.

CME Moderators and Panel Members:

  1. Complete the CME Conflict of Interest Disclosure Form prior to the CME activity start Date. CME staff will review all completed conflict of interest disclosure forms and identify the best course of action.
  2. If no conflict is identified, then no additional action is required.
  3. If a conflict is identified and there is no physical content to be reviewed:
    1. Require the activity director to complete the COIM Form at least ten business days prior to the activity start date.
    2. CME staff as well as committee reviewers will determine how topics and speakers were determined and obtain evidence that the topics represent a balanced, evidence-based medicine approach.
  4. If a conflict is identified and there is physical content available to be reviewed:
    1. Require the moderator/planner to submit content for review and resolution by the activity director and/or CME staff
  5. If CME staff and/or reviewers feel the conflict(s) are unable to be mitigated, the moderator/panelist will not be allowed to continue in the role or CME credit will be eliminated from their involvement.

Speakers/Presenters/Authors:

  1. Complete the CME conflict of interest disclosure form ten (10) business days prior to the CME activity start date. CME staff will review all completed Conflicts of Interest Disclosure Forms and identify the best course of actions.
  2. If no conflict is identified, then no additional action is required.
  3. If a conflict is identified, provide the OCME with a copy of the slides/content to be presented at least ten (10) business days prior to the CME activity start date.
    1. The presentation content will be peer reviewed by the activity director and/or CME committee member or by an independent specialist who is familiar with the content.
    2. If a conflict of interest or bias is detected within the content, the presenter/speaker/author is expected to modify the content or the presenter/speaker may be replaced.
  4. If activity director, CME staff and/or committee reviewers feel the conflict(s) are unable to be adequately resolved, CME credit(s) will be eliminated from the affected presentation(s).

Earning and Claiming CME Credit

The OCME outlines the process in which to earn and claim CME credit for each type of activity.  It is the responsibility of the participant to read and follow the outlined process in which to earn and claim CME credit.

Appropriate Use of Commercial Support

  1. The CME Director is the only allowed signatory for all corporate educational grant letter of agreements. The department or joint provider is responsible for submitting grant letter of agreements for commercial support to OCME for review and approval.
  2. The source of all support from commercial interests must be disclosed to learners prior to the activity occurring. When commercial support is ‘in-kind’ (e.g., provision of equipment), the nature of the support must be disclosed.  In order for commercial support acknowledgement to be made, the letter of agreement must be signed by both the commercial supporter representative and OCME prior to printing/production/activity.
  3. In the case of jointly or co provided activities, the grant letter of agreement will delineate the joint/ co-provider’s name and contact information.
  4. In the event there are social events or meals at CME activities, they cannot compete with or take precedence over the educational event(s) and should comply with the American Medical Association’s Guidelines on Gifts to Physicians: Code of Medical Ethics Opinion 9.6.2.
  5. The provider must make all decisions regarding the disposition and disbursement of commercial support. A provider cannot be required by a commercial interest to accept advice or services concerning teachers, authors, or participants or other education matters, including content, from a commercial interest as conditions of contributing funds or services. All commercial support associated with a CME activity must be given with the full knowledge and approval of the provider.
  6. Industry representatives, if invited, may attend CME-approved activities discreetly for their own education, but may not interact with attendees in any way that might be interpreted as marketing nor may they participate in the discussion.
  7. RSS activities utilizing commercial support for an individual session are required to follow the same guidelines as other activities utilizing support. The OCME requires advanced notification of the support in order to meet accreditation requirements (Letter of Agreement, acknowledgement of support to audience).
  8. In-kind support (i.e. meals) can be paid for directly by the supporter but must be acknowledged and disclosed to the audience. No administrative fee is associated with in-kind support.
  9. An administrative fee will be charged for each non-restricted educational grant obtained.
  10. Checks should be made payable to: MSU-CHM Board of Trustees Michigan State University attention OCME.

Appropriate Management of Associated Commercial Promotion

The provision of exhibits at educational activities may serve to complement or enhance the activities’ value. At the discretion of the activity director, commercial exhibitors may be invited to display materials relevant to the subject of the meeting.

  1. Arrangements for commercial exhibits or advertisements cannot influence planning or interfere with the presentation, nor can they be a condition of the provision of commercial support for CME activities.
  2. Exhibit fees shall be separate and distinct from educational grants (they are not considered commercial support). Exhibitors must sign OCME's Hold Harmless Letter of Agreement.
    1. Exhibit fees shall be set for each activity and will be standard for that activity; all potential exhibitors shall have equal access to purchasing exhibit space (first come-first serve).
    2. Different fee amounts can be set based on amount of space (i.e., 3’ table vs. 6’ table), organization type (i.e. for-profit vs. not-for-profit). All fee options must be made available to all exhibitors.
  3. All exhibitors must be in a room or area separate from the educational activity and the exhibits must not interfere or in any way compete with the learning experience prior to, during, or immediately after the CME activity. A floor plan is required with the activity application.
  4. Commercial interest representatives may attend CME activities at the discretion of OCME for the direct purpose of the representatives’ own education; however, they may not engage in sales or marketing activities while in the space or place of the educational activity.
  5. OCME will not utilize a commercial interest as the agent providing a CME activity to learners; e.g., distribution of self-study CME activities or arranging for electronic access to CME activities. Distribution of CME activity brochures by representatives of a commercial interest may be allowed by OCME if said distribution is not the sole marketing method, and commercial interest has signed a grant agreement in support of the activity, and OCME has sent a formal request letter to the commercial interest requesting this assistance.

Promotional Materials

  1. Product-promotion material or product-specific advertisement of any type is prohibited in or during CME activities.
  2. The juxtaposition of editorial and advertising material on the same products or subjects must be avoided.
  3. Live (staffed exhibits, presentations) or enduring (printed or electronic advertisements), promotional activities must be kept separate from CME activities.
  4. The ACCME does not permit subtle advertising in conjunction with CME-certified activities such as by having book bags, pens, or other accoutrement that bears the name of the manufacture and/or its products.
  5. Educational materials that are part of a CME activity, such as slides, abstracts and handouts, cannot contain any advertising, trade name or a product-group message.
    1. Print advertisements and promotional materials will not be interleafed within the pages of the CME content, including meeting syllabi.
    2. Computer based, advertisements and promotional materials will not be visible on the screen at the same time as the CME content and not interleafed between computer ‘windows’ or screens of the CME content.
    3. Audio and video recordings, advertisements and promotional materials will not be included within the CME activity. There will be no ‘commercial breaks’.
    4. Advertisements and promotional materials cannot be displayed or distributed in the educational space 30 minutes before or after a CME activity. Learners shall not be forced to interact with exhibitors and/or promotional activities. Commercial Interests are not allowed to engage in sales or promotional activities while in the space or place of the CME activity.
  6. Commercial logos cannot be used on any promotional material.
  7. Promotion of an activity cannot be done until the CME Office has granted the approval.

Content Validation and Fair Balance

Standard 1: Ensure Content is Valid

  1. All sponsored CME activities will comply with ACCME’s Content Validation Statement.
    1. All recommendations for patient care in accredited continuing education must be based on current science, evidence, and clinical reasoning, while giving a fair and balanced view of diagnostic and therapeutic options.
    2. All scientific research referred to, reported or used in accredited education in support or justification of patient care recommendation must conform to the generally accepted standards of experimental design, data collection, analysis, and interpretation.
    3. Although accredited continuing education is an appropriate place to discuss, debate, and explore new and evolving topics, these areas need to be clearly identified as such within the program and individual presentations. It is the responsibility of accredited providers to facilitate engagement with these topics without advocating for, or promoting, practices that are not, or not yet, adequately based on current science, evidence, and clinical reasoning.
    4. Organizations canot be accredited if they advocate for unscientific approaches to diagnosis or therapy, or if their education promotes recommendations, treatment, or manners of practicing healthcare that are determined to have risks or dangers that outweigh the benefits or are known to be ineffective in the treatment of patients.
  2. Presentations and CME activity materials must give a balanced view of therapeutic options; use of generic names will contribute to this impartiality. If the CME educational materials or content includes trade names, where available, trade names from several companies must be used.

Off-Label Use Disclosure

  1. Faculty (speaker or presenter), activity directors, and moderators are required to disclose to the learners when products or procedures being discussed are off-label, unlabeled, experimental, and/or investigational (not FDA approved); and any limitations on the information that is presented, such as data that are preliminary or that represent ongoing research, interim analyses, and/or unsupported opinion.

Faculty Honoraria and Travel Reimbursement

  1. Honoraria amounts will be negotiated by the OCME or joint provider taking financial responsibility for the CME activity and shall be based on fair market value with the realization that the amounts will vary with the specialty, subspecialty, speaker qualifications, length and number of presentation(s), nature of the conference, preparation time, and travel time.
  2. An honorarium is limited to $3,000 per speaker unless prior approval is received from the CME Committee.
  3. No individual involved in a CME activity may receive payment directly from an ineligible company for honoraria, travel, or out-of-pocket expenses.
  4. OCME will approve the amount and source of the honoraria and estimated travel expenses prior to the CME activity by reviewing the activities projected budget.

    Amounts being paid will be reviewed by the OCME to assure that:
    1. The honoraria being paid are commensurate with the value of the speakers’ presentation;
    2. The procedure for payment is consistent with ACCME policy and Standards for Integrity and Independence in Accredited Continuing Education;
    3. Payment is consistent within the institution;
    4. Out of pocket expense reimbursement may include: (A) coach airfare, (B) hotel accommodations, (C) food and beverage while traveling, (D) ground transportation, and gratuities.
  1. Directly sponsored CME activity faculty/authors/content validation reviewers who are employees of MSU will be paid their honoraria in accordance with the MSU Financial Services policy (Outside Work For Pay - Faculty Handbook).
  2. Reimbursement or prepayment of travel expenses for faculty (speaker, presenter, moderator, panel member) of MSU certified CME activities must comply with MSU Travel Office’s Policies and the ACCME Standards for Integrity and Independence in Accredited Continuing Education.
    1. If teachers or authors are listed on the agenda as facilitating or conducting a presentation or session, but participate in the remainder of an educational event as a learner, their expenses can be reimbursed and honoraria can be paid for their teacher or author role only.
    2. The provider may not use commercial support to pay for travel, lodging, honoraria, or personal expenses for non-teacher or non-author participants of a CME activity. The provider may use commercial support to pay for travel, lodging, honoraria, or personal expenses for bona fide employees and volunteers of the provider, joint provider or educational partner.

Auditability

  1. For directly sponsored CME activities, CHM Departments are responsible for maintaining auditable records in accordance with MSU policies and procedures.
  2. For jointly/co-provided activities, the joint/co provider is responsible for maintaining auditable records and providing a detailed final budget to OCME.

Joint/Co-Provided Activities

  1. A commercial interest cannot take the role of non-accredited partner in a joint/co-provided relationship.
  2. Jointly provided activities must be consistent with OCME’s mission and purpose statements.
  3. A faculty member from CHM must review and approve the proposed activity.
  4. OCME must review and approve all materials associated with the activity prior to their release. Once materials have been reviewed and approved by OCME, no further changes can be made without notifying the OCME.
  5. Any and all funds solicited on behalf of a CME activity must be received by OCME. Checks should be made payable to MSU-CHM Board of Trustees Michigan State University attention OCME. 
  6. In-kind support, for example lunches or dinners, can be paid directly by the supporter but must be acknowledged and disclosed to the audience. There is no administrative fee associated with such in-kind support.
  7. The responsibilities and role of the joint provider will be clearly delineated in a letter of agreement between the joint provider and OCME. OCME has the right to withdraw from any activity if the joint provider fails to meet its obligations as described in the letter of agreement or fails to comply with OCME policies and procedures.  In addition to the aforementioned letter of agreement, joint providers must comply with HIPAA regulations.
  8. The joint providers shall submit a projected budget for each CME activity to OCME for review and approval. OCME will review the projected budget to ensure that adequate resources have been devoted to the development of an activity consistent with meeting the activity’s objectives.  OCME will withdraw from an activity if resources are inadequate for the development of a high quality educational product or activity.
  9. The projected budget must include funds to support CME staff members travel and accommodations (based on current MSU approved per-diem rates) required for activity monitoring.
  10. At OCME’s discretion and with written authorization, the joint provider may solicit funds under the direction of OCME but may not make any representations or commitments to commercial supporters as to educational content, choice of speakers, learning objectives, marketing, and/or evaluation.
  11. All potential joint providership relationships will be examined on their individual merits. Although all CME activities jointly provided with OCME must comply with this policy, OCME reserves the right to refuse to enter into a joint providership agreement for any reason whatsoever, regardless of that organization’s willingness to comply with this policy.
  12. OCME charges fees for its services. These fees and the terms for its payment will be mutually agreed upon and delineated in an exhibit to the aforementioned letter of agreement between OCME and the joint provider.
  13. Michigan State University OCME must be involved before any major planning occurs with the project (i.e., speakers invited, content developed, etc.) The OCME will not be involved if a proposal is submitted for funding prior to contacting the OCME. If changes are made to a proposal (including budget) after the OCME has given approval, the proposal must be resubmitted for review and approval.

On-line Activities

  1. OCME-provided activities only appear on websites identified by OCME as appropriate. For example, OCME will not approve their posting on a pharmaceutical or medical device manufacturer’s website.
  2. Links from OCME-approved websites to the websites of ineligible companies are permitted 30 minutes before or after the educational content of an OCME-sponsored activity, but shall not be embedded in the educational content of the CME activity. The learner must be clearly notified that s/he is leaving the educational website.
  3. OCME prohibits advertising of any type within the educational content of CME activities on the Internet including, but not limited to, banner ads, subliminal ads, and pop-up window ads.
  4. Internet provided CME activities shall include a mechanism for the learner to contact OCME if there are any questions about the Internet CME activity. A contact for technical issues is also required.
  5. Internet provided CME activities must have, adhere to, and inform the learner about the site’s policy on privacy and confidentiality and said policy must be approved by the OCME.
  6. OCME must be able to document that it owns the copyright for, or has received permission for use of, or is otherwise permitted to use copyrighted materials within a CME activity on the Internet.
  7. All online activities must require the learner to read the Disclosure and Financial information before being able to start the activity.

Regularly Scheduled Series

  1. All Regularly Scheduled Series (RSS) are expected to be planned, implemented, and evaluated in compliance with the ACCME Essentials, Policies, Criteria, Standards for Integrity and Independence in Accredited Continuing Education and pertinent to the OCME Policies and Procedures. All RSS sessions are expected to meet the definitions of an RSS and continuing medical education.

    Regularly Scheduled Series (RSS): A course planned as a series with multiple, ongoing sessions, e.g., offered , weekly,  monthly, or quarterly; and is primarily planned by and presented to the accredited organization’s professional staff. (Source: AMA and ACCME).

    Continuing Medical Education (CME): Educational activities, which serve to maintain, develop, or increase the knowledge, skills, professional performance, and relationships that a physician uses to provide services for patients, the public, or the profession. The content of CME is that body of knowledge and skills generally recognized and accepted by the profession as within the basic medical sciences, the discipline of clinical medicine, and the provision of health care to the public. (Sources: ACCME, AMA).
  1. In addition to the application review and approval process required for all sponsored CME activities, the OCME
    requires submission of information for each specific session within the series including the following items:
    1. Agenda with Speakers Identified (required 10 business days prior to the session)
    2. Online Disclosure Forms for all speakers (required 10 business days prior to the session)
    3. Learning Objectives (required 10 business days prior to the session)
    4. Changes in Planning Committee since original application and corresponding online Disclosure Forms (required prior to the session)
    5. Proof that each session complies with the ACCME Standards for Integrity and Independence in Accredited Continuing Education (required prior to the session)
    6. Attendance Sheets (required within 30 days following the session)
  2. The OCME conducts bi-annual outcomes survey of prior participants of any RSS activity. These survey results are forwarded to the activity director to include in the planning process for future RSS activities.
  3. All planners of regularly scheduled series are required to survey their audience annually for suggestions or comments for improvement and to identify from the physicians’ perspective where they perceive there is a need or gap in their patient care. The OCME will be available to assist in preparing a questionnaire for this purpose.
  4. Staff may perform periodic, random, on-site evaluation visits to document compliance. A summary report of the on-site evaluation visits will be kept in each RSS file.
  5. RSS planning committees are required to participate in a planning process that links identified needs, objectives, and educational format to desired results. As such, it is expected that the individuals responsible for RSS’ will take part in an annual planning cycle that documents these connections.  In addition, global learning objectives for an RSS series will be prepared and communicated to learners.
  6. Following confirmation of compliance with ACCME Accreditation Criteria, Standards for Integrity and Independence in Accredited Continuing Education, and Policies as well as the OCME Policies and Procedures, OCME will assure that records of attendance and/or participation are entered into the database. CME Credit for sessions found to be noncompliant will not be awarded and OCME will notify the Activity Director of this action.  Noncompliance will be addressed as follows:
    1. Consultation and education with the CME Facilitator for the RSS. In the event OCME does not award CME credit for an RSS activity session or series due to noncompliance, OCME fees will not be refunded
    2. Second noncompliance of same issue will result in the CME certification being revoked.
  7. RSS activities utilizing commercial support for an individual session are required to follow the same guidelines as other activities utilizing support. The OCME requires advanced notification of the support in order to meet accreditation requirements (Letter of Agreement, acknowledgement of support to audience).
  8. When a renewal application for a regularly scheduled series is not received by the due date, the OCME will send an eight-week warning letter to the activity director that the CME credit will be suspended at the end of the two weeks for any future CME sessions and remain suspended until the renewal packet is received.
  9. Academic units and/or regional institutions that plan and execute RSS's certified by OCME are required to provide the necessary resources and staffing needed to carry-out regularly scheduled CME conferences and to comply with ACCME Accreditation Criteria, Standards for Integrity and Independence in Accredited Continuing Education, Policies, and pertinent OCME Policies and Procedures.
  10. OCME will maintain participant credit records for a minimum of six years.

Non-Compliance

The following steps will occur when the CME Office finds an educational activity/session in non-compliance:

  1. The CME specialist will send an email to the facilitator indicating what information is missing from the activity/session being reported. The facilitator will be given 7 business days to respond to the request for missing documents.
  2. If no response from the facilitator or the missing document has been received, a non-complaint letter will be sent to the activity director. The activity director will have one week in which to comply or that activity/session will not be certified for CME and the participants will not receive credit
  3. If the same occurrence happens a second time, the CME certification will be revoked for that activity.

Activity Closing Documents

All required documentation must be received in the CME Office no later than 30 days post activity in order to be eligible for CME credit.  The following materials should be submitted as a complete package:

  • Live Courses and Regularly Schedule Series
    • Completed attendance sheets
    • All materials distributed at the activity (brochures, syllabus, agenda, handouts)
    • Hold harmless form for exhibits (as applicable)
    • Final reconciled budget reconciliation at the conclusion of the approval period
  • Enduraing Material, Internet Live, Journal-Based CME Activities
    • Completed electronic list noting learner's name, credentials, email address and total credits earned
    • Final budget reconciliation
  • All Other CME Activities
    • As defined during application process

CME Activity Information Page includes the educational objectives, faculty financial disclosures, commercial support disclosures, and the appropriate ACCME accreditation statement.

The completed electronic participant list provides participant names, credentials, email addresses and total credits earned for their participation in a course.

Materials distributed at the event including the brochure, syllabus, agenda and handouts.

Reconciliation of the final budget is required for all educational activities.

Outcome Surveys

Outcome Surveys are an important part of improving the overall CME program and are required to meet the Accreditation Council for Continuing Medical Education requirement.  An outcome survey request will be emailed to all activity participants 8-12 weeks post activity by the OCME. Each activity is required to reach a response rate of at least 25%.  Activities that do not meet the 25% response rate will be sent a non-compliant notice. The OCME will send the facilitator an email informing of the upcoming outcome survey.

Activities that consistently fail to reach the 25% response rate, over a two year period, will jeopardize the CME certification of the activity.

MSU Office of Continuing Medical Education Privacy Statement

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Please note that other Michigan State University websites may adopt different privacy practices as their specific needs require. 

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References

Accreditation Council for Continuing Medical Education (ACCME), Accreditation Rules and Standards for Integrity and Independence in Accredited Continuing Education.

American Medical Association Council on Ethical and Judicial Affairs (AMA CEJA) –Ethical and Judicial Affairs

Accreditation Council for Continuing Medical Education (ACCME and American Medical Association (AMA) Glossary of Terms and Definitions

Food and Drug Administration (FDA) – Final Guidance on Industry-Supported Scientific and Educational Activities

Office of Inspector General (OIG) – OIG Compliance Program Guidance for Pharmaceutical Manufacturers

PhRMA – PhRMA Code on Interactions with Healthcare Professionals

Adopted and Modified

January 2007; July 2008; September 2013; May 2014; January 2015; October 2015; June 2016; May 2017; December 2018; July 2021.

Continuing Medical Education