DATE: Wednesday, June 08, 2011

RE: NAMEC’S RESPONSE TO the ACCME Call for Comment

I am writing as President-elect of the National Association of Medical Education Companies (NAMEC). NAMEC thanks the ACCME for this call for comment on changing the ACCME policy regarding commercial support attribution. NAMEC believes that the current ACCME policy achieves its desired objectives and should not be changed. NAMEC puts forth that the current ACCME policy works because it is clear to providers what is allowed and what is not and charges providers with the definitive responsibility for establishing and enforcing their policy and procedures consistent with the ACCME’s requirements. NAMEC feels that ACCME’s requirement to providers that commercial support attribution be at the corporate level only, with prohibition of any use of or reference to product names, meets learners’ and the public’s expectations for provider transparency and disclosure as well as ensuring appropriate firewalls between education and promotion. NAMEC believes that with ACCME's support and continued guidance providers can work within the existing ACCME standards to ensure that the commercial support policy is adhered to and that firewalls are maintained and strengthened. Thank you.

-Marissa Seligman, PharmD, CCMEP

NAMEC