Why Requirement 3 Was Developed
As of July 1, 2012, all ASHA Approved CE Providers must be in compliance with Requirement 3: Transparency in Course Planning, Delivery, and Marketing.
Prior to 2012, the CEB had conflict of interest (COI) and disclosure requirements. Requirement 3 strengthened those requirements and added some new required practices.
The movement to strengthen COI requirements across all CE accreditors was prompted by a number of highly visible reports criticizing health care practitioners and health care accredited CE providers as having too many ties to industry (device and product manufacturers, pharmaceuticals, service industry, etc.). The Accreditation Council for Continuing Medical Education (ACCME [PDF]) began to overhaul their COI requirements in 2004, with other revisions coming in 2006 and 2007, and some additional tweaks to their system in subsequent years based on pressure from outside entities. Other health care CE accreditors followed ACCME's lead. The American Nursing Credentialing Council and the Accreditation Council for Pharmacy Education [PDF] actually now use ACCME's standards for commercial support (COI standards [PDF]), and other accreditors in health care and non-health care arenas have variations on the ACCME standards. Reports pertaining to conflict of interest and disclosure were issued by the Senate Finance Committee (2009–2010), the Institute of Medicine (December 2009), the Josiah Macy Jr. Foundation (December 2009), and the Senate Committee on Aging (July 2009), to name just a few.
The CEB spent 8 years carefully observing what other accreditors were doing to strengthen their COI requirements, and the CEB learned from those observations about what best leads to transparency in course development, delivery, and marketing. As the CEB began working to strengthen its existing COI standards, the board also did a great deal of research. In 2007 and 2008, the CEB contracted with two separate consulting firms who had expertise in CE standards and were familiar with COI issues. The CEB asked the consultants to determine what standards existed in all CE accreditors (not just health care) and which of those standards exemplified the outcomes that CEB wanted to achieve with its providers and participants (learners). After extensive research, the consultant groups reached the same independent recommendation, which they then presented to the CEB in the summer of 2008. They recommended that the CEB use the "gold standard" for COI requirements (instead of reinventing the wheel). That benchmark was the ACCME standards.
Following those consultants' recommendations, the CEB embarked on strengthening its existing COI standards modeled after the ACCME standards. In the summer of 2010, those standards (or requirements) were put out for peer review and feedback to over 10,000 people, including all of our CE Administrators and CE Providers. The CEB received over 2,000 responses and spent the next 6–9 months analyzing those responses and making changes to the requirement. The changes were substantial based on the feedback. Although some of the requirement still mirrors the spirit of the ACCME standards [PDF], there are significant differences in the final version.
The complete set [PDF] of the 12 Requirements for ASHA Approved CE Provider Approval can be found on the ASHA CE website.