Noncompliance with the Attendance Records Retention Policy and the Joint Sponsorship Policy

Please note: This Complaint Summary makes reference to “Joint Sponsorship;” this term had been changed to “Joint Providership” effective February 2014.  For more information please see our web page on Simplification and Evolution.


The ACCME received a complaint regarding a jointly sponsored activity. The complainant questioned the CME provider’s compliance with the ACCME’s Attendance Records Retention Policy because the provider had not verified physician participation upon request.

The ACCME issued a Notice of Complaint. In its response, the CME provider explained that it could not obtain participation records on the series of activities because they were jointly sponsored and the joint sponsor is no longer in business. This revealed that the provider was not in compliance with three ACCME policies. The ACCME requires that the accredited provider must take responsibility for a CME activity when it is presented in cooperation with a nonaccredited organization. (The accreditation statement identifies the accredited provider that is accountable to the ACCME for compliance with ACCME policy. So, the accredited provider cannot blame the nonaccredited organization.) Secondly, under the ACCME’s expectations of jointly sponsored activities, it is the ACCME-accredited provider’s responsibility to be able to submit written documentation of compliance with accreditation requirements to the ACCME.  Finally, the ACCME’s Attendance Records Retention Policy requires the provider to be able to produce verification of physician participation.

The ACCME issued a Notice of Noncompliance. As required, the CME provider submitted a Notice of Corrective Action, explaining that it had revised its organizational policies and procedures regarding verification of participation and it also chose to cease working in joint sponsorship. The complaint was closed.


Published Date: 
Tuesday, August 27, 2013
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