Quick Answers to Frequently Asked Questions
1. Are there special requirements for activities posted on online and social media platforms, beyond those outlined in the ACCME Criteria, Standards and Policies?
No. The current requirements, including the ACCME’s Standards for Integrity and Independence in Accredited Continuing Education (the Standards) apply to all accredited education whether the educational venue is in-person or virtual.
2. Are there ACCME requirements that a provider should pay special attention to when posting an activity on an online or social media platform?
Yes. These are found within Standards 2 and 5 of the ACCME’s Standards for Integrity and Independence. When posting an activity on an internet-based platform, you will want to ensure that:
- Learners do not encounter product-specific marketing while engaged in accredited education.
- 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.
- You have permission of the faculty to post their material on a platform.
- The identity and contact information of learners engaging with your accredited education is not tracked by, visible to, or shared with any ineligible company or its agents without the consent of the individual learner.
3. What steps should a provider take to ensure that our content can go on an online or social media platform?
Providers should ensure that the hosting platform is not an ineligible company, and will not:
- Track or manage learner information without the learners’ permission.
- Use learner information for subsequent targeted advertising without learners’ permission.
- Permit the dissemination, reposting, or processing by an artificial intelligence engine of the intellectual property content of the material without the poster’s consent and approval.
- Allow marketing material to appear around, within or adjacent to the content itself.
- Allow marketing or promotion by or for ineligible companies to appear immediately before or after the accredited activity without an opportunity for the learner to choose not to participate or view the content.
- The platform will continue to follow these expectations for as long as the material is present on their site.
Several platforms offer tools to providers to control how material on their sites are handled. Providers should ensure they have sufficient confidence that the tools offer the service promised, and then select the appropriate controls when posting materials.
4. How can a provider that hosts clinical case or journal discussions convened on social media protect learners from promotional posts by industry staff?
One method that providers have used successfully within social media-assisted accredited education is to start the conversation with a post that requests any employees or owners of ineligible companies to leave, or if not to identify themselves and not to participate in any conversation related to their company’s products or services.
5. In developing accredited CE that will be posted as video on an online or social media platform, are there best practices that an accredited provider should follow to help meet ACCME’s expectations and requirements?
We have seen providers design activities that include the following steps to help them maintain the integrity of their CE when posted on an online platform:
- Nest all required information, such as disclosure of the presence or absence of relevant financial relationships, accreditation statement, disclosure of the source of commercial support (where applicable) within any video content itself (where it is less likely to be separated from the descriptive copy around a video).
- Include contact information for the accredited provider within the content itself so that a learner with questions may contact you directly if they encounter the material in or on an unexpected site.
- Include language regarding copyright and your requirements for reproduction of the material directly within the content.
- 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.
- For activities designed for and hosted on social media platforms, the accredited provider has a mechanism in place to protect the learning environment from interference by owners/employees of ineligible companies. One way this has been accomplished with the use of private invite-only groups within an online or social media platform.
6. If I offer education on an online platform that is viewed within a window on a screen can there be a “sidebar” outside of that window or a banner that includes marketing or promotion?
Per Standard 5.2b, when offering online activities, providers must ensure that any marketing for the products of ineligible companies may not be presented to learners before, during or after an accredited activity. Therefore, a “sidebar” or banner that includes marketing or promotion should not be visible on the screen during an accredited activity.
7. Will ACCME offer an online and social media platform designation to help accredited providers?
Based on feedback from the call for comment, the ACCME does not currently plan to offer a special designation for online platforms. If circumstances warrant such a designation in the future, the ACCME will consider it. Any organization may apply to ACCME for a corporate structure review to determine eligibility.
