ACCME Call for Comment on Accredited Education Delivered via Online and Social Media Platforms

Introduction

The Accreditation Council for Continuing Medical Education (ACCME®) is pleased to invite you to participate in a call for comment about the delivery of accredited education via online and social media platforms. As platforms for delivering CME online have proliferated, ACCME has been asked to clarify its expectations for accredited providers. We have reviewed our existing policies to develop the following guidance. We invite feedback from all stakeholders on the clarity of our expectations.

In addition, as a service to the accredited provider community, ACCME is considering offering a designation for internet platforms, video players, and/or social media channels that wish to host accredited educational content and are willing to demonstrate they meet the ACCME’s expectations. 

We encourage you to review the background and description of the ACCME expectations and proposed designation below before completing the survey (approximately 15-20 minutes).

All viewpoints are welcome, but please make your comments constructive.

Please complete this survey by Thursday, Oct. 12, 2023, at 11:59 pm Central.

We do not accept anonymous responses; to submit the survey, you will need to provide your contact information. If you have questions, please contact us at info@accme.org or visit www.accme.org.

Thank you for your participation.

Respond to the survey.

Background

The delivery mechanisms for accredited CME/CE have evolved and diversified, especially as accredited providers shifted rapidly to virtual learning during the pandemic. Internet-based education has grown in terms of the number of accredited activities, as well as the number of learner interactions with those activities. Educators have increasingly inquired about the use of video-based content, the independence of internet platforms for live and enduring activities, and the incorporation of social media both for the purpose of facilitating learning and engaging learners. These questions largely revolve around compliance with the Standards for Integrity and Independence in Accredited CE.

ACCME's Expectations of Accredited Providers

The ACCME considers virtual spaces (internet platforms, social media channels) the venue for the accredited education. The ACCME’s expectations related to the educational space are the same whether the education is in-person or virtual. Specifically:

  • Accountability: Accredited providers are always accountable for any accredited activity offered in-person or virtually. It is the accredited provider’s continuing responsibility to oversee and monitor all use and reuse of multimedia content wherever it is presented. 
  • Marketing and Advertising: Accredited providers must ensure that learners not encounter product-specific marketing while engaged in accredited education. Accredited providers must ensure that learners must be able to engage with the accredited education without having to click through, watch, listen to, or be presented with product promotion or product-specific advertisement. 
  • Reposting Video Material: Unless the hosting site provides tools that accredited providers can use to protect and manage their content, several additional expectations apply to posted material: 
    • all required accreditation-related information (accreditation statement, presence/absence of relevant financial relationships, that relationships have been mitigated, and, if applicable, the source of commercial support) should be presented with or within the video or displayed metadata.
    • accredited providers should control where and when video content that is a component of an accredited activity is posted or available.  
  • Protecting Intellectual Property: The accredited provider has the responsibility to ensure they have permission of the material authors to post their material on a platform. Accredited providers should have a mechanism in place to request removal of previously posted materials on reasonable request from the content owners or authors who perceive that their intellectual property rights have been undermined.   
  • Protecting Learners’ Identity and Data: The accredited provider must ensure that identity and contact information of learners engaging with accredited education (including websites, recorded or live video or social media) is not tracked by, visible to, or shared with any ineligible company or its agents without the consent of the individual learner. The accredited provider should have a mechanism in place for learners to control their data privacy.  
  • Protecting Learners on Social Media: For activities designed for and hosted on social media platforms, the accredited provider must have a mechanism in place to protect the learning environment from interference by owners/employees of ineligible companies. 

Proposed ACCME-Compliant Platform Designation

As a service to the accredited provider community, ACCME plans to offer a designation for companies such as internet platforms, video players, and/or social media channels that wish to host accredited educational content and are willing to demonstrate they meet the ACCME’s expectations. Accredited providers can look for this optional designation and mark to determine which platforms are willing to demonstrate they meet these expectations.

To earn the new designation, a company must stipulate that it does not, as its primary business, produce, market, sell, resell, or distribute products that are consumed on or by patients.

The company must also provide accredited organizations with a hosted content platform that meets ACCME's expectations for:

  • Preventing marketing and advertising from being shown to participants in hosted activities;
  • Preventing unpermitted reposting of materials; 
  • Protecting intellectual property; 
  • Protecting learners’ identity and contact information from being shared without their permission; and 
  • Protecting facilitated conversations from manipulation by ineligible companies.

These commitments may be subject to periodic testing to ensure compliance and the company must be willing to accommodate such testing.