New CERP Application Forms Emphasize Self-Assessment and Performance in Practice
ADA CERP recognition is based on a provider's demonstrated compliance with ADA CERP Recognition Standards and Criteria, through a review of documentation and information about the provider's continuing education program. CERP's goals for revising the application forms were two-fold: to facilitate the assessment process for CE providers and CERP reviewers alike, and to ensure that recognition decisions are based on evidence of compliance with key criteria in the CERP Recognition Standards. The new application forms have been restructured to accomplish this by replacing the lengthy questionnaire of the current forms with a shorter "Self-assessment Rubric," and by placing a greater emphasis on documentation of a provider's practices, through the addition of an "Activity File."
The Self-assessment Rubric is a scoring tool that explicitly states the performance expectations for specific Recognition Criteria. After assembling the required documentation, providers will use the self-assessment rubric to evaluate whether their documentation and practices meet, partially meet or do not meet specific CERP Recognition Standards. The CERP Committee will use the same rubric to evaluate the applications. The self-assessment questionnaire is designed to be informative for providers, describing what is needed to meet individual criteria and helping to identify areas where improvements are needed, and to encourage reflective practice and continuous quality improvement in continuing education. The rubric also supports greater transparency regarding CERP recognition decisions, since providers and reviewers will use the same evaluation criteria.
For the Activity Files, providers will assemble documentation related to specific CE activities which the provider will be able to select. The Standard Application requires documentation for two CE activities; the Abbreviated Application requires documentation for one. Documents will include the publicity materials, needs assessment, course materials such as handouts or presentation slides, evaluation and assessment forms and summaries, instructions/guidance for instructors, signed conflict of interest forms, published disclosure, letters of agreement for commercial support, and verification of participation for each activity. Providers applying for CERP recognition have been asked to supply examples of these documents in the past, but it was not required that the documents relate to a single course. CERP believes that a review of the full spectrum of planning and implementation documents related to one or more specific CE activities will provide a clearer understanding of a provider's performance in practice.
The application forms contain the following sections: Provider Information, Self-assessment Rubric, and Activity Files. Providers that offer self-study activities or courses in which patients are treated will complete additional supplements. By focusing on essential criteria, the redesigned applications contain 30% fewer questions than the current forms.
Providers submitting applications in Spring 2014, due January 4, 2014, will use the new forms. The new Standard Application form and informational materials will be available at www.ada.org/cerp beginning July 1. In preparation for submitting applications for continued recognition, providers are encouraged to review course files to be sure that they are complete.
Call for Comments on Proposal to Create a Commission on Continuing Dental Education Accreditation to Oversee CERP
Separating CERP from CDEL would reflect best practices in continuing education accreditation. The Council's decision to explore a new model was made after reviewing the organizational structures of other accrediting agencies in continuing education for the healthcare professions, analyzing CERP's current structure and CE environment, and assessing the advantages and disadvantages of several alternate models.
The Council is requesting comments from the broad communities of interest to the proposal. Draft additions to the ADA Bylaws establishing a new commission and proposed operating rules are appended to the Call for Comments. All interested parties are invited to submit written comments on the proposal by September 1. Comments should be addressed to Dr. Ronald Venezie, chair, Council on Dental Education and Licensure, and may be submitted by e-mail, fax or mail to firstname.lastname@example.org, Fax: 312-440-2915, or ADA CERP, 211 East Chicago Ave, Chicago, IL 60611. If you have any questions, please contact the ADA CERP manager, Ms. Mary Borysewicz, at email@example.com or 800-622-8099, x2704.
Physicians Transparency Program: Reporting Exemption Related to Accredited CE
ADA CERP's existing requirements for disclosure and transparency have been acknowledged in the CMS rule, along with those of four other accrediting agencies for continuing healthcare education, by the creation of a reporting exemption related to CE activities. Section 42 CFR §403.904(g) of the Final Ruling specifically applies to continuing education that is accredited or certified for credit.
Under the new rule, manufacturers must report transfers of value to individual physicians and dentists. This includes transfers of value that are made through a third party, such as a dental association or a continuing education provider. However, the Open Payments rule exempts manufacturers from the reporting requirement if funds are given to an accredited provider of continuing education to pay a "covered recipient" who is a speaker in a CE activity, if all of the following conditions to ensure independence and transparency are met:
Another reporting exemption that may be of interest to CE providers relates to commercial support for meals at CE activities. Under the Open Payments rule, funds given by a manufacturer to a third party, such as a CE provider or dental organization, that are used to support coffee breaks or buffet meals that are open to all participants in a large meeting do not have to be reported. However, if the funds are used to support a meal for a select group of individuals whose identities the manufacturer may establish, and the value of the meal is over $10, then the names of the individual doctors and dentists who participated and the value of the meal would need to be reported.
CE providers should note that responsibility for reporting payments rests with the applicable manufacturers. However, since manufacturers must report payments and transfers of value they make to covered recipients through a third party, with certain exceptions such as those described above, third party organizations accepting and distributing funds may be asked to assist the manufacturer in fulfilling its reporting responsibility by supplying the names and National Provider Identifier (NPI) for the physicians and dentists who ultimately received the transfers of value.
CERP Standards regarding acceptance and disclosure of commercial support have not changed. CERP approved providers must continue to publish disclosure of any commercial support received for CE activities, as well as disclosures of any relevant financial relationships that instructors and planners in the provider's CE activities have had in the last 12 months.
More information about Open Payments and its implications for CERP approved providers and ADA members will be made available in future newsletters, ADA News and on ADA.org.
Provider Annual Reports and Fees Due July 1
Provider Workshop Planned for New Orleans
CERP Recognition Actions—Spring 2013
Providers Awarded 4-year Terms of Recognition
Providers Awarded 3-year Terms of Recognition
Fall 2013 Application Deadline
If you do not intend to apply for continued recognition, please submit written notice of your intent to withdraw voluntarily from the program on your organization's letterhead.
Comments, Suggestions, or Questions about ADA CERP
ADA CERP Committee