An accredited provider delivered a live course with financial commercial support from an ineligible company. The grant had been requested during planning, but the written letter of agreement (LOA) wasn’t issued for signature until after the activity launched.
What should the accredited provider do? The agreement is a nominal amount, only $1,500. Does an agreement signed after launch satisfy the ACCME Standards for Integrity and Independence in Accredited CE, assuming all required elements appear in the LOA?
Under ACCME Standard 4.2, the terms, conditions, and purposes of commercial support must be documented in an agreement between the ineligible company and the accredited provider, and that agreement must be executed prior to the start of the accredited education. Signatures from both parties must be in place before activity launch. An agreement executed after launch does not meet Standard 4.2.
The provider could not retroactively cure the issue of timing, so the focus shifted to compliance and proactivity. The CE team made the decision to decline the funds and they did not execute the agreement. A root-cause review found no checkpoint tied to LOA status, so the provider revised its procedures, adding a tracking log and an escalation path when signatures are delayed. The provider documented its updated process, ensuring the CE team was fully trained.
