Whether you are an accredited provider such as i3 Health or you are an educational partner working with an accredited provider, it's still important to understand the American Nurses Credentialing Center (ANCC) criteria that underlie nursing continuing professional development (NCPD) activities. This is part of a periodic series of posts looking at what each criterion means in general and what it might mean for you.
The third set of ANCC accreditation criteria focus on the educational design process (EDP) of the activities within an NCPD program. Educational design includes the planning, design, assessment, and evaluation of each activity. There are seven (7) criteria within this section. The fourth criterion overlaps with a topic that has been covered separately: The Standards for Integrity and Independence in Accredited Continuing Education (Standards).
Criterion EDP4 states:
The process for identification, mitigation, and disclosure of relevant financial relationships of all individuals who control the content of the continuing education activity.
The ANCC was one of the organizations involved in the creation of the new Standards, so it makes sense that they are also one of the organizations to have adopted them into their accreditation criteria. Criterion EDP4 focuses on Standard 3: Identify, Mitigate, and Disclose Relevant Financial Relationships.
In order to meet this criterion, NCPD programs must have a process to collect information about financial relationships for everyone in control of the content of an educational activity. This means all faculty, all nurse planners, the Accredited Provider Program Director, any outside reviewers, and so on. While faculty and NPs are standard for each activity, some activities are more complex and may involve other roles. It's always better to have people to err on the side of caution when deciding who should disclose their financial relationships with ineligible companies.
There are not specific requirements as to how disclosure information is collected. A small program may find it easiest to collect this information verbally and maintain a spreadsheet. Large programs may use accreditation management software that requires individuals to log in and complete a form. What matters is that all financial relationships with ineligible companies over the past 24 months are disclosed to the NCPD program.
Because all financial relationships are collected, the NCPD program needs a process to determine which ones are relevant to the activity. A relationship with a company that manufactures pacemakers is not likely to be relevant to an activity about prostate cancer. No steps are needed to mitigate that relationship because it is not relevant.
Once relevant relationships are identified, then the program needs to take steps to mitigate. The ANCC's self-learning guide provides a variety of suggested strategies that could be used to mitigate relevant financial relationships depending on the individual's role in the activity.
The final part of this criterion requires relevant financial relationships to be disclosed to learners. There is much debate in the field of healthcare continuing education about this disclosure process. Should you disclose everything an individual has disclosed to you? Or should you just disclose the relationships you have deemed to be relevant? I do not have an answer for you because it all depends on your comfort with grey areas. I can say that accreditors prefer that we just disclose the relationships deemed to be relevant, but at this time, they are not considering a program to be non-compliant if all relationships are disclosed.
Above I give an example of a relationship that is black-and-white. A cardiac medical device manufacturer has no stake in an activity on prostate cancer. But what about a company that manufactures analgesics? They may not be used directly to treat cancer, but they could be used to treat pain associated with the cancer. This is that grey area that I mentioned. Different programs may be more comfortable with considering this relationship to be irrelevant than others. If you are an accredited provider, it is up to you to determine your policy related to these sorts of relationships. If you are working jointly with an accredited provider such as i3 Health, you will want to follow their policies in the process of identifying, mitigating, and disclosing relevant financial relationships.
While there is much detail required to meet this criterion, once your process for meeting it is up and running, the majority of the time it should be fairly simple to just follow your process, making it easy to stay in compliance with EDP4 and the Standards.
Other Posts in This Series
Educational Design Process 2 (EDP2)
Educational Design Process 3 (EDP3)
ACCME (2022). Standards for Integrity and Independence in Accredited Continuing Education. Available at: https://www.accme.org/accreditation-rules/standards-for-integrity-independence-accredited-ce
ANCC (2021). Writing to the ANCC NCPD Accreditation Criteria Self-Learning Guide. Available at: https://www.nursingworld.org/~4b0217/globalassets/docs/ancc/manuals/ancc-2784-ncpd-writing-to-the-ancc-criteria-final-v-1.0-9.27.21.pdf
ANCC (2021). ANCC NCPD Accredited Provider Applicant Journey Guide. Available at: https://www.nursingworld.org/~4b0217/globalassets/docs/ancc/manuals/ancc-2530-ncpd-applicant-journey-toolkit-final-v-1.0-9.27.21.pdf