Compliance Lab

Compliance Cases in Focus

The Gift Card Cost of Participation

Context

An accredited provider planning an accredited CME conference proposed a $50 gift card for the first 100 learners who registered and attended. The cards would be purchased with operating funds, without commercial support. Some learners would pay their own registration fees; others would use employer education allowances. The team believed distributing the cards after attendance would make the incentive acceptable.

Compliance Issue

May the provider offer gift cards to encourage conference registration and attendance? Does the absence of commercial support, the source of registration payment, or distribution after attendance change the determination?

Analysis

ACCME’s gift card policy prohibits providers and their agents from offering personal remuneration tied to CME purchase or registration, regardless of who pays. The proposed guaranteed gift card is therefore prohibited; using operating funds or delivering it after attendance does not change its link to registration. ACCME permits registration discounts without transferring a personal benefit to learners. It also permits modest gift cards for completing evaluations or as raffles.

Strategy

The provider removed the gift card offer before registration opened and revised the invitation to emphasize the conference’s educational value. It considered a registration discount instead and documented the decision. The CME program staff reviewed the registration page and promotional materials for consistency.

Practical Tips

  • Identify what triggers the incentive: registration, evaluation completion, or a raffle.
  • Do not assume self-payment or the absence of commercial support makes a registration-linked gift card permissible.
  • Review promotional arrangements with joint providers, vendors, and agents, as well as the provider’s own materials.