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April 24, 2014

ACCME Bans Corporate Logos

The board of directors of the Accreditation Council for Continuing Medical Education (ACCME) has voted to ban logos from all accredited CME materials. The ACCME has been toying with the logo change for years now. Back in a 2011 call for comment, the majority of respondents expressed disapproval of its proposal to ban them. In light of the comments, ACCME deferred any definitive action regarding logos.

Policy and Medicine has repeatedly noted that corporate logos are an important means of ensuring transparency to the learner. We have supported the CME Coalition's Reasonable Logo Use Guidelines that acknowledges the benefits of logo use while maintaining effective separation between education and promotion.

The ban goes into effect immediately but ACCME accredited providers have until May of 2015 to replace any previously printed materials and change websites with existing programs. 

The ACCME, however, rejected all logo use. Their revisions relate to the following provisions of the ACCME Standards for Commercial Support™:

Current:

Standard 4.3: 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.

Standard 6.4: 'Disclosure' must never include the use of a trade name or a product-group message.

Revised:

Standard 4.3: Educational materials that are part of a CME activity, such as slides, abstracts and handouts, cannot contain any advertising, corporate logo, trade name or a product-group message of an ACCME-defined commercial interest.

Standard 6.4: 'Disclosure' must never include the use of a corporate logo, trade name or a product-group message of an ACCME-defined commercial interest.

Commercial Support Acknowledgments Policy

The provider's acknowledgment of commercial support as required by SCS 6.3 and 6.4 may state the name, mission, and areas of clinical involvement of the company or institution and an ACCME-defined commercial interest but may not include corporate logos and slogans. , if they are not product promotional in nature.

____

ACCME CEO and President, Dr. Murray Kopelow, discussed the modifications in a webinar (emphasis added).

"…We appreciated the more than 500 responses we got to this request for comment, all of them were read and all of them were included in our analysis. You said the changes could eliminate ambiguity; they could decrease the learners' perception of influence; they could strengthen the perception of the effectiveness of the Standards for Commercial Support; and you also said that they could create the potential for an appearance and a reality of less disclosure.

Concerns about reduced transparency and disclosure were very important to us. They caused us to pause because disclosure & transparency always have been fundamental values of ACCME. The ACCME discussed these concerns and in March 2014 the ACCME concluded that logos are a form of corporate branding and that branding is not appropriate in educational materials and they are not appropriate in disclosure of commercial support of accredited continuing medical education. We thought that the value of continuing the separation of promotion from education outweighs the concerns that were expressed.

…In Standard 4.3 we say educational materials that are a part of a CME activity, such as slides, abstracts and handouts, cannot contain any advertising, corporate logo, trade name or a product-group message of an ACCME-defined commercial interest. We also modified Standard 6.4 that talks about the disclosures relevant to potential bias. The disclosure of commercial support must never include the use of a corporate logo, trade name or a product-group message of an ACCME-defined commercial interest.

We also modified the ACCME's clarifying policy to say that the provider's acknowledgment of commercial support as required by Standards 6.3 and 6.4 may state the name, mission, and areas of clinical involvement of an ACCME-defined commercial interest but may not include corporate logos and slogans. This change is effective immediately. It does not apply to currently printed existing materials; you do not need to throw them out and reprint them, but you do need to make all of these changes and incorporate this new policy by May 2015 into your printed materials and your Internet presentations of continuing medical education.

I want to emphasize that this change only applies to mixing educational materials and logos and only applies to mixing disclosure of commercial support and logos; it applies to nothing else. It is not relevant to when a speaker mentions a brand name in your educational materials or if you're using a device to teach accredited continuing medical education and that device has a logo or brand on it. You don't have to remove that logo from the device.

We have other safeguards in place to manage all of those circumstances. If you're concerned about decreasing transparency, about disclosure, you could use strategies to draw attention to the disclosure of commercial support. And perhaps for future discussion we should explore the creation of an icon for commercially supported continuing medical education that will help people recognize when CME is commercially supported.

Kopelow concluded that: "In the meantime, if you want to use a logo to recognize excellence" use the ACCME logo.

Analysis:

If ACCME's priority is clearly communicating to learners that a particular event has received commercial support, then prohibiting the use of corporate logos is counterproductive. Learners look for the corporate logos to see if there is commercial support. Way back in 2011, Policy and Medicine observed that ACCME never explained the reason for its stance against logos. We pondered whether logos cause any harm, and noted that "[l]ogos are quite useful differentiating one company from the next."

We are also concerned that this ban may create confusion that spills over to sponsorship at annual meetings.

ACCME issued calls for comments on the logo issue, and has received similar feedback. Stakeholders have noted the following reasons for objecting to the change:

  • Utilizing corporate logos is an important means of ensuring transparency to the learner and makes the distinction between supported and unsupported education apparent.
  • Existing ACCME rules are familiar to CME providers, they are clear, and they provide sufficient firewalls between education and promotion.
  • CME providers are currently able to choose whether or not they include logos in program materials. CME providers should be able to retain that choice.
  • In an economic environment where industry providers have shrinking budgets from which to allocate funding and where mergers are reducing the number of companies who are in a position to provide support, it is becoming increasingly difficult to secure funding for vital programs. Because a benefit supporters receive from supporting CME includes public recognition for their commitment to CME, it would be a mistake to eliminate that recognition and jeopardize that irreplaceable source of financial support.
  • There is no evidence that the appearance of a logo as part of the disclosure of commercial support serves a commercial promotional intent or inappropriately influences physicians.

In response to ACCME's call for comment regarding the use of logos from commercial supporters for accredited CME programs, the CME Coalition created "Responsible Logo Use Guidelines." These rules embrace common-sense rules that respect the transparency and disclosure logos provide to learners on educational grants obtained from commercial interests in support of an educational activity. The CME Coalition proposed the following guidelines to help providers:

  • Accredited providers are responsible for ensuring the disclosure and acknowledgement of commercial support, including the appropriate use of corporate logos in activity materials.
  • Disclosure of support from a CI through the use of a commercial supporter corporate logo must be accompanied by the provider's logo in the appropriately designated area of the activity materials.
  • Disclosure of support from a CI including (or with) the use of a corporate logo should occur only once in the appropriate section of the activity materials (e.g. brochure, handout, printed piece, or digital medium). Providers may also elect to acknowledge commercial support elsewhere by listing the CI name without the accompanying corporate logo.
  • CI corporate logos may not exceed the size of the provider's logo(s).
  • To ensure that logos are not inadvertently over-emphasized due to layout or design features, providers should be consistent in appearance with the color used in the disclosure of commercial support section of the activity (e.g., if a print piece is 4-color then all logos should also be 4-color, if the print piece is in black and white then all logos need to be in black and white). Logos from commercial supporters will not supersede those of the providers.
  • Acknowledgement of exhibitors using logos is permitted.

Several strategies CME providers may consider to recognize commercial include: 

  • Commercial Supporter Company name in larger print and/or a different in color than the rest of the text in materials and websites
  • Include the company's mission statement and areas of clinical involvement in program materials, slide, and websites

 Comment

Unfortunately, the ACCME's decision to ban logos comes at a pivotal time for CME. The Council of Medical Specialty Societies stressed in a letter to ACCME CEO, Murray Kopelow, "[a]s the Open Payments program is in its first year, now is not the time to make any changes in this critical set of standards which have been adopted as is by CMS." Currently the Physician Payments Sunshine Act includes an important exemption for accredited CMEs. ACCME is one of only five accrediting body provided for in the Sunshine Act. Thus, they provide a key role in keeping physicians informed and up-to-date on the best practices for patients across the country. We will keep a close watch on any updates regarding ACCME policies.

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