CONTINUING MEDICAL EDUCATION
stakeholders could develop conflict-of-interest policies and identify more
consistent funding sources to replace funding from industry stakeholders.164
This entity would replace the ACCME and its Standards for Commercial
Support with more rigorous standards, and the entity would also have a
more active role in seeking out funding for CME providers than the
ACCME currently does.
A public-private structure has advantages over a private structure
operated by professional societies and organizations. For example, a purely
private organization would have fewer incentives to convene regularly, and
there would be less accountability for a private oversight board than there
would be for a public-private structure.165 Similarly, a purely public
organization would be less advantageous than a public-private structure, as
it could not as readily incorporate collaborative decision-making and could
be limited by procedural and financial requirements.166
Though the organization would broadly communicate with and gather
input from the Industry and field members, it would ideally have a
committee that would be accountable to the Secretary of HHS.167 The
organization’s decisions would be based solely on votes of the committee
members.168 The committee might consider adopting a policy similar to the
Educational Review Board (ERB) of the Partners Healthcare policy to
screen any CME programming that involves industry funding.169 It might
also use a slush fund mechanism similar to the Partners President’s Fund
for industry sponsors to donate money without knowing which CME
program their money would go toward, thus reducing topic bias.170
Adopting stricter rules regarding commercial support and seeking out
alternative sources of funding would also mean that CME providers could
develop topics based on quality gaps rather than treatments that involve
drug and device companies’ products, directly benefiting physicians and
D. CME Tax on Healthcare Entities
If the previously mentioned measures are taken to reduce or eliminate
voluntary industry funding, CME providers must find another source of
funding. One solution would be for Congress to impose a “CME tax” on
164. Id. at 7.
165. See id. at 6.
167. See id. at 7.
169. See PARTNERS HEALTHCARE, supra note 129.
170. See id. § 3. 4. 1.