ACCME’s Exception 2 to Standard 3 states that accredited providers do not need to identify, mitigate, or disclose relevant financial relationships for “accredited education where the learner group is in control of content, such as spontaneous case conversations among peers.”
To better understand the exception, let’s examine the meaning of “spontaneous case conversation.” A spontaneous case conversation is a conversation between two or more learners that was not planned ahead of time. Two physicians have an impromptu conversation in the hallway, write down what they learned, and report the change that resulted to their accredited provider in order to gain CE credit. The provider does not need to identify, mitigate, or disclose financial relationships since the learners were in control of content and the activity was spontaneous.
What is not a “spontaneous case conversation?”
Anything that was planned ahead, where learners are not in control of the content, is not a spontaneous case conversation. Examples include:
- case conferences
- regularly scheduled series
- department rounds
- tumor boards
For each of these activities, providers should identify, mitigate, and disclose the relevant financial relationships.
Tip: Report an activity that was planned or organized into PARS, and don’t assume that all conversations among peers fit the exception to Standard 3. In the examples provided above, someone planned the activity, leaving open the possibility of commercial influence, and learners were not in control of content.
