Attachment E -- Public Comments

Public Comments and AHRQ’s Response

Comment from Pamela Sardo, Pharm.D:

Dear Ms Lefkowitz,

 

I have a very high regard for the work that your agency produces; however, I was very disappointed to see your latest request in the Federal Register for almost $4 million to create comparative effectiveness continuing education (CE) for health professionals in Volume 76, number 39, p 10900.  Many CE suppliers already produce high quality continuing education programs, via written materials, via live seminars, and over the internet, for a LOT LOWER cost.  As Past President of the New Hampshire Pharmacists Association, and Past President of the Southern Tier New York Health System Pharmacy Association, these organizations could produce, distribute and assess continuing education for a few hundred dollars.

 

Please consider using agencies that already produce the continuing education, such as the American Medical Association, National Community Pharmacists Association, American Pharmacists Association or Academy of Maanged Care Pharmacy, and simply submit a nominal charge for the statistical analysis component of your proposal.

 

Please do not spend my tax dollars in a wasteful manner.  My husband has been out of work for over a year.  Money does not grow on trees.  We all need to do more with less money.  Do not contribute to increasing the deficit.  Please withdraw or modify this proposal DOWNWARD by at least two million dollars.

 

Thank-you for your consideration.

AHRQ’s Response:

Creating compelling and effective continuing education that appeals to adult learners is essential to convey the educational messages regarding comparative effectiveness and the implications for patient care.  While we concur that many organizations are accredited for physicians or pharmacists or nurses, we recognized that the interprofessional team who would benefit from this education extends to all health care disciplines that provide patient care. Our goal in this initiative is to offer multiple discipline accreditation for each course, and include health care providers for whom this information will impact practice and patient care.  As such, we sought an organization that could provide multiple accreditations and certificates. These continuing education activities will be provided free of charge.

Obtaining widespread dissemination of the information and education are also key goals in our initiative. Academic facilities, professional organizations, and societies reach their members and constituents, but have limited ability to reach all of the other healthcare stakeholders for whom the education is designed.  To maximize our dissemination capabilities through medical education and other contractors, we determined that a medical education provider with a significant current subscriber base, access to practice settings and all provider types, and current partnerships with professional organizations and academic partners was critical to ensure consistent and persistent dissemination and access for providers throughout the duration of this initiative.

To demonstrate the effectiveness of the educational program, we required an organization with a sophisticated learning management system with unlimited capacity to collect important data at a variety of intervals, through a variety of entry points. The ability to examine data by provider type, effect of the learning on their clinical practice, attitudes and skills is also a requirement of this contract to ensure our ability to measure the effectiveness of the education in conjunction with other contractors participating in this initiative.

Finally, given the magnitude of the number of educational programs to be produced, we sought an organization whose sole business is accredited medical education and where their in-house capabilities would limit the need for costly subcontractors and time consuming outsourcing to provide innovative and interactive education.  

We hope you will take advantage of our educational offerings and share them among your professional colleagues and within your practice setting. AHRQ already offers free continuing medical education at our Effective Health Care Program Web site:

http://www.effectivehealthcare.ahrq.gov/index.cfm/guides-cmece-and-other-resources-for-clinicians/cmece-activities/

Comment from James E. Tucker, M.D.:

suggestion:  make the modules available on Medscape, ReachMD and by direct e-mail distribution so that providers who don't subscribe to JAMA or the Annals can access them.

 

 

AHRQ’s Response:

 

AHRQ will make all of the continuing education modules freely available via our Effective Health Care Program Web site at http://www.effectivehealthcare.ahrq.gov/index.cfm/guides-cmece-and-other-resources-for-clinicians/cmece-activities/ .

If you will follow this link, you will see that we already provide several fully accredited continuing education activities and we hope that you take advantage of the resources provided.