Dannemiller Anesthesiology Review Course

Policy on Joint Sponsorship

1. POLICY

The Dannemiller Memorial Educational Foundation (Dannemiller) holds the activities it jointly sponsors to the same standards that it applies to those directly sponsored. The following describes conditions that must be met in any joint sponsorship into which Dannemiller may enter:

1.1 The proposed activity must be consistent with the Dannemiller Memorial Educational Foundation's CME mission statement.

1.2 Dannemiller must be involved in the planning and development of any jointly sponsored activity it designates for credit. A representative of Dannemiller must review and approve the learning objectives, design of the educational activity, final faculty selection, intended audience and evaluation methodology. The needs assessment will be conducted by the Dannemiller Foundation.

1.3 All jointly sponsored activities must comply with the ACCME Essential Areas and policies. Any funds solicited on behalf of the activity must be received by Dannemiller or must be authorized in writing to be delivered to the joint sponsor who shall provide full budgets and updates to the Dannemiller Memorial Educational Foundation in writing. The non-accredited sponsor may solicit funds with the approval and direction of Dannemiller, but may not make any representations or commitments to funding sources as to content, choice of speakers, or anything else not allowed by the Essential Areas and policies of the ACCME. All commercial supporters must sign the Dannemiller Memorial Educational Foundation's standard letter of agreement or if approved by the Executive Director, a commercial supporter's form may be used if it complies with the ACCME Standards for Commercial Support of Continuing Education. The commercial supporter must be acknowledged in the activity's materials. All faculty will be required to disclose significant relationships with the commercial supporter or the manufacturer(s) of any other products they discuss.

1.4 The Dannemiller Memorial Educational Foundation will review the budget for any proposed jointly sponsored activity to ensure that adequate resources have been devoted to the development of an activity consistent with meeting the activity's objectives. The Dannemiller Foundation will withdraw from an activity if resources are inadequate for the development of a high quality activity.

1.5 The Dannemiller Memorial Educational Foundation must review and approve all materials associated with the activity prior to their release. The Dannemiller Memorial Educational Foundation must be clearly recognized as a joint sponsor. The following joint sponsorship statement must appear on all materials.

IF A JOINTLY SPONSORED ACTIVITY WITH AN UNACCREDITED SPONSOR:
This activity has been planned and implemented in accordance with the Essential Areas and policies of the Accreditation Council for Continuing Medical Education through the joint sponsorship of the Dannemiller Memorial Educational Foundation and <name of non-accredited sponsor>. The Dannemiller Memorial Educational Foundation is accredited by the ACCME to provide continuing medical education for physicians.

1.6 The responsibilities of the non-accredited sponsor will be clearly enumerated in a joint sponsorship agreement between the non-accredited sponsor and Dannemiller (Acknowledgment of Responsibilities of Joint Sponsorship). The Dannemiller Memorial Educational Foundation will withdraw from any joint sponsorship if the non-accredited sponsor fails to meet its obligations as described in the Acknowledgment of Responsibilities of Joint Sponsorship form or fails to comply with Dannemiller policies (CME Manual).

1.7 The Dannemiller Memorial Educational Foundation holds its jointly-sponsored activities to the same standards as the activities it directly sponsors with regard to fulfillment of its CME mission, needs assessment, setting of objectives, use of systematic planning processes, evaluation, documentation, and the ACCME Essential Areas and policies. The Dannemiller Memorial Educational Foundation's Executive Director, whose decision in any dispute is final, will resolve any confusion regarding Dannemiller policies.

1.8 The Dannemiller Memorial Educational Foundation's policies, procedures and formats as contained in the Dannemiller's CME Manual, must be followed by the joint sponsor.

1.9 All potential joint sponsorships will be examined on their individual merits. Although all CME activities jointly sponsored with the Dannemiller Memorial Educational Foundation must comply with this policy, Dannemiller reserves the right to refuse to enter into a joint sponsorship with a non-accredited organization, regardless of that organization's willingness to comply with this policy.

1.10 It is imperative that in the development and conduct of any CME activity, that the joint sponsor represent the interests of the Dannemiller Foundation. As such, the joint sponsor cannot represent the interests of any commercial source, such as a pharmaceutical or device manufacturer within this activity. If the joint sponsor has a relationship with a pharmaceutical or device manufacturer that would preclude them from acting independently from that manufacturer, a conflict of interest exists, making it impossible for them to serve as a joint sponsor for that specific activity.

1.11 The Dannemiller Memorial Educational Foundation will charge a fee for its services. This fee and the terms for its payment will be mutually agreed to and stipulated in writing.

2. PROCEDURES AND OPERATIONAL GUIDELINES

2.1 Involvement with the Dannemiller Memorial Educational Foundation

2.1.1 A course chair or faculty member appointed by Dannemiller or member of Dannemiller's Education Committee/Medical Specialty Review Board must be involved in the planning of the program to ensure that the activity meets the CME Mission of Dannemiller and to ensure quality and scientific integrity of the jointly sponsored activity.

2.1.2 A member of the staff from Dannemiller will serve on the planning committee in order for an activity to be sponsored by the Dannemiller Memorial Educational Foundation. Staff involvement at the level of planning is required so that input into the process can be provided relating to the ACCME Essential Areas and policies, and compliance with AMA requirements prior to promotional materials being printed.

2.2 Determination of Need

The need for each CME activity must be substantiated. Identification and assessment of CME needs provide the basis for formulating educational objectives and planning educational activities. These needs may come from any number of sources (more than one method is required). The Dannemiller Foundation will conduct the needs assessment. Documentation used will include:
  1. Recent research from peer-reviewed publications or other literature review
  2. Previous evaluation summaries from activities on a similar subject
  3. Recommendations of AHRQ or other regulatory bodies
  4. New techniques or protocols
  5. Expert opinion (experts could be the course chair or other experts in the field)
  6. Faculty perceptions
  7. Applicable physician survey
  8. Medical audits and reviews
  9. Consensus report, i.e., roundtable, etc
  10. Formal requests by members of the target audience
  11. Education Committee/Medical Specialty Review Board (MSRB)
2.3 Explicit Statement of Learning Objectives

2.3.1 Every CME activity must state the learning objectives or purpose in writing in either the printed brochure or other promotional material and in the syllabus or handout materials.

2.3.2 Objectives should be derived from the needs assessment, relate to the intended audience, and able to be measured post-activity in terms of outcomes measures. Learning objectives should be stated in terms of what the attendee can expect to "take away" from the activity, and those statements should normally begin with an action verb (a list of verbs used in objectives is located in the CME Manual). Normally, the learning objectives should be bulleted and begin with phrase such as: "At the conclusion of this education activity, the participant should be able to:"

2.3.3 Learning objectives need to be clear and in sufficient detail in order to (1) assist the planner in designing the activity, (2) assist the faculty in preparing presentations that fit with the overall objectives, (3) provide a benchmark for the evaluation of the activity, and (4) assist participants in deciding whether or not to attend the activity.

2.4 Educational Design

2.4.1 The choice of program design must be based on the needs, the type of professional attending the program and their learning preferences, and the other logistical and financial considerations. The educational design must be linked to need, objectives, and target audience.

2.4.2 When planning a live educational activity sponsored by the Dannemiller Memorial Educational Foundation, presentations should be amplified by good use of audio-visual materials, appropriate handout materials, and interactive sessions whenever possible.

2.4.3 All the recommendations involving clinical medicine in a CME activity must be based on evidence that is accepted within the profession of medicine as adequate justification for their indications and contraindications in the care of patients.

2.4.4 All scientific research referred to, reported or used in CME in support or justification of a patient care recommendation must conform to the generally accepted standards of experimental design, data, collection and analysis.

2.5 Activity Materials

2.5.1 After the Dannemiller Foundation has agreed to jointly sponsor an activity; Dannemiller must approve all materials, either blue line or other draft, in writing before it is printed and distributed to potential participants. Checklists have been developed to assist joint sponsors in complying with the Essential Areas and policies of the ACCME, as well as Dannemiller requirements (see CME Manual for checklists and Policy on Clinical Content Review and Validation).

2.5.2 The joint sponsor is responsible for obtaining all applicable copyright releases and providing documentation to the Dannemiller Foundation.

2.6 Certification Fee Structure

The fee structure for jointly sponsored activities has two components.

2.6.1 Accreditation Fee
The Accreditation Fee represents the oversight and involvement in the planning process by members of the Dannemiller Memorial Educational Foundation's staff, Education Committee/Medical Specialty Review Board; the expertise and maintenance of expertise in the rules and responsibilities of sponsors of continuing medical education as derived from the ACCME and AMA, and the fees required to maintain that accreditation.

2.6.2 Certification Fee
The certification fee represents the costs to the Dannemiller Memorial Educational Foundation associated with the maintenance of detailed records of physician participation in CME activities sponsored by The Dannemiller Memorial Educational Foundation, and the cost of certificate production and distribution. Certification Fees also will be negotiated with each joint sponsor applicant.

2.6.3 All fees will be negotiated with the Executive Director or the Director, CME Department.

2.7 Joint Sponsorship Agreement
Joint sponsors will be required to sign and abide by the provisions of the "Acknowledgment of Responsibilities of Joint Sponsorship" form.

2.8 Additional Accreditation
In the event that an activity is appropriate for specialties other than those for which Dannemiller Foundation is accredited to provide credit, the Foundation will work with other accredited agencies to obtain applicable approval. The Dannemiller Foundation routinely works with the American Association of Nurse Anesthetists, the American Academy of Nurse Practitioners, the American Academy of Family Physicians, and organizations accredited by the American Council on Pharmaceutical Education (ACPE) to obtain their approval for activities we are sponsoring for physicians. In the event that activity approval is requested by other accredited agencies, i.e., ACPE, the joint sponsor is responsible for complying with all requirements imposed by the applicable accredited agency. The Dannemiller Foundation will serve as the coordinator.

3. Delegation of responsibility for receiving and disbursing educational grants to a Joint Sponsor

3.1 In accordance with ACCME Policy 99-A-14, the Dannemiller Foundation may authorize a Joint Sponsor to invoice and receive payments from an educational grant in support of CME activities accredited by the Dannemiller Foundation. This authority must be in writing and may only be approved by the Executive Director. Joint Sponsors may be delegated this responsibility if they:
  1. Express a desire to perform this function
  2. Have the administrative staff to properly perform this function and to keep an accurate accounting for all funds received
  3. Agree to abide by all ACCME Essential Areas and policies and with all Dannemiller Foundation CME Policies and Procedures
  4. Agree to provide full documentation of this process to include a final accounting for all educational grant funds received in support of the CME activity
3.2 The following procedures will be followed when Joint Sponsors are authorized to invoice and receive educational grants:
  1. Authorization must be obtained in writing from the Executive Director. This is usually in the form of a response letter to the Joint Sponsor from the Executive Director. This response letter will also indicate that the Joint Sponsor is required to provide a full and complete accounting for all funds received from the educational grant to the Dannemiller Foundation within 30 days of the completion of the activity.
  2. Upon approval of this authorization, the Executive Director will, in coordination with the Director of the CME Department, request the educational grant from the Commercial Supporter and provide a three-party Letter of Agreement as an enclosure to that letter. (The three-party Letter of Agreement must be signed by the Joint Sponsor, Commercial Supporter and the Dannemiller Foundation.) The grant request letter will include information that the Joint Sponsor will provide necessary invoice(s) and should be paid directly by the Commercial Supporter. The grant request letter will also ensure that the Commercial Supporter must sign a Letter of Agreement with the accredited sponsor (Dannemiller) and that final approval of the activity will not be granted until the Letter of Agreement is signed and returned to Dannemiller.
  3. The Director of the CME Department will ensure that this responsibility is included in the Acknowledgement of Joint Sponsors Responsibilities form that the Joint Sponsor must sign.
  4. All significant modifications to the original proposed budget must be reviewed and approved by the Dannemiller Foundation. Supplemental or additional educational grants in support of the same activity must be reviewed, approved and requested by the Dannemiller Foundation and will include another Letter of Agreement for the additional amount of the grant requested. If there are excess funds from an educational grant that is paid to a Joint Sponsor, this should be reflected in the final accounting. These funds should be returned to the Commercial Supporter or may be dedicated to another project/activity if preferred by the Commercial Supporter.
  5. Upon final approval of the final activity or upon the conduct of a live activity, a letter will be provided to the Joint Sponsor reminding them of their requirement to provide a full and final accounting of all funds received from the Commercial Supporter in support of that activity. The Accounts Manager will keep a copy of this letter on file and will follow-up with the Joint Sponsor for any activity for which a full and complete accounting has not been received within 30 days.
  6. Upon receipt of the final accounting from the Joint Sponsor, the Executive Director will carefully review the accounting to ensure it is in accordance with the approved budget for the activity. The Executive Director will investigate any significant discrepancies with the Joint Sponsor.
  7. An activity file will not be closed until a full accounting has been received and reviewed and approved by the Executive Director. Once approved, the full accounting will be placed as a permanent document in the activity file.
  8. Joint Sponsors who do not comply with this policy will not be approved as a Joint Sponsor by the Dannemiller Foundation in the future.
 
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