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My predictions on ACCME's disclosure moves

Now that I'm over my snit about the Accreditation Council for CME's lack of responsiveness to my questions about its chief executive's statements in The New York Times and new potential public disclosures about those found to be noncompliant with the 2006 Accreditation Criteria, I have a deeper appreciation than ever for the difficulty ACCME faces whenever it has something to announce.

Say too much on one hand and everyone goes crazy trying to figure out how a broad statement could play out in the nitty gritty details of real life; say too little and everyone goes crazy trying to figure out what it is you're not saying. Talk about a no-winner.

Anyway, Dr. Kopelow and I had an interesting conversation shortly after I got all miffy. I really didn't get a whole lot of definitive answers from him, which is pretty much what I expected (while he's the spokesman and public face of ACCME, he can't really speak for the board that's ultimately making the decisions, so in situations like this one, there's not much he can say). But I am glad he was able to take the time to speak with me and at least give me enough to put together an article that says a bit more. Really, though, I don't expect to get much in the way of real answers until after the upcoming December board meeting.

That being said, I'm going to go out on a limb and make a few predictions anyway, based on nothing more than my keen ESP skills, history, and common sense:

1. ACCME isn't going to release information about activities or providers that have had complaints filed against them until after the investigation is completed. Dr. Kopelow of course didn't say or even imply this, but in poking around ACCME’s Web site I don't see anything that remotely would make me think it would be increasing transparency against those accused but not convicted. Look at the wording of the updated Process for Handling Complaints/Inquiries Regarding ACCME-Accredited Providers:

"ACCME reserves the right to make public some information about the ACCME Complaints and Inquiries Process which may include but is not limited to the facts and circumstances involved in the complaint or inquiry, the name of the accredited provider involved, the names of commercial supporters, the names of non accredited joint sponsors and the ACCME’s findings."

To me, that inclusion of findings tells me that it's just thinking about the end of the cycle, not the beginning. I know some people have raised the idea of making the info public at the time a complaint is filed, or at least suspending access to enduring materials and online activities during an investigation, but I just don't see ACCME going in the direction of guilty until proven innocent. I could be wrong, but it just doesn't appear to be the way it has done things up until now.

2. You will get to make your feelings known about any new disclosure policies that may come out of the December board of directors meeting before they go into effect. Think about it: As far as I can tell, ACCME has not adopted any major policies or made any major announcements without asking for comments since the 2006 Accreditation Criteria (and even then all the preliminary materials were open for discussion. A lot of discussion). Put that together with the policy that says comments will be asked for any new rule that could "directly and materially impact the ability of accredited providers to conduct business," and there you go.

3. The ACCME board is taking this very, very seriously, and is looking at it from all sides and angles, backward and forward. This Dr. Kopelow did say, "There are 1,600 state- and nationally accredited providers in our community who are trying every day to have an impact on physician learning and help those physicians have an impact on patient care. That's what we support every day in the accreditation system." They're not going to make any disclosure decisions lightly -- that much I'd put money on.

Am I out in left field, on the ball, or somewhere in between? I'd be curious to know what you think. As always, feel free to leave a comment below or shoot me an e-mail.

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