Lew Miller a respected leader in CME and founder of the Alliance for CME and the Global Alliance for CME weighed in to the ABMS on their proposed ABMS White Paper on MOC/CME.
We are encouraging everyone to read the white paper for themselves and submit comments to the ABMS by March 1st to ABMS at ABMS_MOC_Support_Program@abms.org.
As a long-time advocate of independent CME and performance improvement (whether official PI-CME or not), I applaud the general sentiments of the White Paper, with a few caveats. Given the chance for misunderstanding (e.g., Tom Sullivan's blog):
1. Make a clear statement that ABMS supports the ACCME standards of provider accreditation as the basis for CME activities that apply to MOC. I read that into the statement:
"The group first reaffirmed that MOC CME appropriately exists as a distinct subset within the universe of accredited CME." Apparently this sentence was not evidence enough for Mr. Sullivan.
2. Clarify the statement(s) regarding commercial support, i.e.:
"A general framework for MOC CME must be developed that assures the public trust by progressively eliminating or reducing, to the extent possible, influence exerted by commercial entities."
If the intent of the recommendations is to eventually remove commercial support from any CME activity that qualifies for inclusion in meeting MOC requirements, please say so, and give some indication of a possible timeline. If the intent is simply to reinforce the application of the SCS of ACCME, say so. Right now, the wording muddies the waters in term of guidance to individual boards. It is already the case that one or more boards won't accept PI-CME for Part IV if commercial support is involved. Others are willing to accept such PI-CME. Your guidance to boards on this subject can be helpful.
3. The concept of "interchangeability" in the following paragraph is also difficult to understand. Please clarify what you mean:
"The MOC Committee should continue discussions with the ACCME and others regarding the development of a “standard currency” for MOC CME that would ensure interchangeability of programming between Member Boards, and other stakeholders, and would also identify the special nature of CME programming that meets the identified characteristics of MOC CME."
I am not sure we have enough experience with MOC CME yet to come up with a standard definition for the type of programming that would qualify. We have, for example, the standard AMA format for PI-CME. But there are other models that may make it easier for a physician or medical group to demonstrate practice improvement in a less structured manner. In the UK, the mentoring system for revalidation is supposed to accomplish this through the setting of PI goals by the physician, approval by the mentor, and periodic progress reports.
Over the next 5 years, we will probably come up with 3 more approaches. Perhaps the committee instead should recommend an ongoing research study to evaluate the effectiveness of various MOC CME modalities -- and then consider standardization.
Thanks for the opportunity to comment.
Lewis A Miller, Principal
WentzMiller & Associates LLC
Consultants in Global CME