FAQs About Requirement 3 for CE Providers: Transparency (Requirement 3)
After our Requirement 3 application addendum has been approved, can we wait until July 1, 2012, to begin using our new processes for meeting Requirement 3?
The ASHA Continuing Education Board (CEB) expects the Provider to implement new processes once the Requirement 3 application addendum has been approved. Don't wait until July 1, 2012.
My organization doesn't have products or services, and we don't promote anything in our courses. Do we have to submit an application addendum and adhere to Requirement 3?
Yes. All ASHA Approved CE Providers must submit an application addendum and adhere to Requirement 3.
If we do not charge participants for our courses, what do we disclose?
Regardless of whether a registration fee is charged, all ASHA Approved CE Providers must adhere to the elements of Requirement 3.
When would a CE event be cancelled because of transparency issues?
Following are examples of circumstances under which a course might be cancelled due to transparency issues:
- The course is promotional in nature.
- There are instructional personnel conflicts that can't be resolved by disclosure.
- A financial or in-kind supporter controls the resources for the course.
- The exhibitors or advertisers are somehow participating in the course in a promotional way.
When such circumstances apply, the course may still be offered, but not for ASHA CEUs.
Requirement 3 asks the Provider to have "processes" to manage transparency. What type of response is the CEB looking for?
You can find sample processes that comply with Requirement 3 on ASHA's website.
Does the end-of-course evaluation form need to have a question such as "Did the presenter disclose his or her relationship to a vendor prior to the training?"
No. This is not a requirement. However, it's a good idea to gather feedback from course attendees on whether instructional personnel disclosed financial and nonfinancial relationship(s).
Is there a mechanism at ASHA to deter presenters who have engaged in blatant self-promotion despite requests that they present impartially and scientifically?
The CEB does have a complaint process. Anyone with concerns about a possible violation of any of the CEB's requirements may submit a complaint in care of the Director of CE.
My company offers free training to individuals who purchase our test. Can we limit participation in our training to those who have purchased our tests?
Yes. However, related promotional materials must indicate that the training is open only to those who have previously purchased the tests. Keep in mind that only content that is not promotional in nature can be offered for ASHA CEUs.
We offer a course about our testing materials. In order to participate in the course, one must purchase the test prior to, or as part of, registering for the course. Is this permitted?
If the learner is required to purchase a product or service in order to participate in a course, this must be communicated to the learner prior to registration (see CEB Required Practice 8.4).
What new steps do we need to take when working with a cooperative party in order to be compliant with Requirement 3?
Providers who choose to do a cooperative course must be involved from the start of course planning and use their processes for adhering to Requirement 3 in the development of the course. Key points to keep in mind are:
- The Provider must ensure that the sale and promotion of products or services are not the focus of CE course content and related materials.
- The Provider must use its process for identifying relevant conflicts of interest, determining if such conflicts disqualify individuals from being involved in course planning and delivery, and disclosing conflicts of interest to learners.
- The Provider must manage and disclose all financial and in-kind support.
- The Provider must appropriately manage exhibits and advertisements associated with a CE course.
- The Provider must ensure that all required disclosures are made in promotional materials and at the start of the course.