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Approved Provider Questions

Q. Who is eligible to apply for MONA approval for CNE activities?
A. Any provider whose headquarters is located in the State of Missouri and who does not meet the definition of a commercial interest is eligible to seek approval of appropriate CNE activities or apply for Approved Provider status. Applications from providers whose headquarters are in another state are accepted only if the state nurses association in the provider's state is not accredited as an approver of CNE by the American Nurses Credentialing Center (ANCC) Commission on Accreditation (COA).

Q. My agency does not have registered nurses on planning committees for CNE activities. Can we still apply to MONA for CNE approval?
A. No. The Missouri Nurses Association CE Approver Unit Committee will not review any application submitted for approval if there are no registered nurses serve on the planning committee. According to the criteria, there must be at least one RN with a minimum of a baccalaureate degree in nursing on the planning committee identified as the lead Nurse Planner and at least one other who has relevant content expertise and/or represents the target audience.

Q. What address do I mail our application copies to and also to whom do I make the check payable?
A. Please make all checks payable to the Missouri Nurses Association.
 

If you are using regular mail to send your application, use the following address: P.O. Box 105228, Jefferson City, MO 65110.

If you are using FedEx or UPS services to send your application, use the following address: 1904 Bubba Lane, Jefferson City, MO 65109.

Q. Can an RN who has a bachelor's degree in social work serve as the "Nurse Planner" for CNE activities in our organization?
A. Registered nurses with a baccalaureate or higher degree in nursing may serve as the "Nurse Planner" who is responsible for planning, developing, implementing, and evaluating a provider's continuing education activities (ANCC COA, 2009). At least one of the RNs on the planning committee for an educational activity must have a baccalaureate or higher degree in nursing.

This requirement means that the RN must have a baccalaureate degree in nursing (typically a BSN), master's degree in nursing (may be an MS, MSN, or MA with a major in nursing), or a doctorate in nursing (typically a Ph.D. or Doctorate in Nursing Science). An RN who has an associate degree in nursing or is a graduate of a diploma school of nursing and does not have a baccalaureate or higher degree in nursing would not qualify as the "Nurse Planner" for purposes of an Approved Provider.

Q. How long is the approval period?
A. If you are applying for approval of a single educational activity, the approval period is two years. If you are applying for provider approval, the approval period is three years.

Q. Are all educational activities of a staff development/continuing education department appropriate for CNE credit? What's the difference between continuing education, in-service, and staff development?
A. No, not all educational activities are suitable for CNE credit. For example, in-service educational activities are those learning experiences designed to help nurses acquire, maintain or increase their competence in fulfilling their responsibilities to deliver quality health care (ANA, 2000) and do not always qualify as CNE.

For example, the following activities are not appropriate for CNE contact hours:
     • Recertification courses where little or no new information is presented,
     • Orientation that focuses on facility policies and procedures, or documentation systems
     • Basic Life Support courses, and
     • In-service education on the use of a specific piece of equipment

Sometimes it is difficult to distinguish between CNE, in-service, basic knowledge and staff development.  According to the Scope and Standards of Practice for Nursing Professional Development (2000), nursing professional development activities exist in the overlapping areas of continuing nursing education, staff development, and academic education. The concepts of continuing competence and lifelong learning are central to all nursing professional activities (p. 4). "Continuing education refers to systematic professional learning, experiences designed to augment the knowledge, skills, and attitudes of nurses and therefore enrich the nurses' contributions to quality health care and their pursuit of professional career goals. Staff development is the systematic process of assessment, planning, development, and evaluation that enhances the performance or professional development of health care providers and their continuing competence. Staff development activities, which generally are provided by nurses' employers and focus on competence assessment and development, include continuing education, orientation, and in-service educational activities"(p.5).

Educational activities for CNE build on and expand the basic knowledge acquired in nursing educational programs, provide new information relevant to nursing practice, and relate to the process and content of professional nursing. An educational activity for CNE might be developed for RNs who are involved in caring for patients with multiple organ failure, and would qualify as CNE; an activity teaching nurses how to use a new care path developed by the employer would be in-service, and would not qualify for CNE.

Q. My agency wants to provide an educational activity that may conflict with MONA's philosophy. Can we still receive approval for the educational activity?
A. MONA will not review any application submitted for approval if the activity is in conflict with the Missouri Nurses Association's philosophy.

Q. What should I do if my agency decides not to pursue contact hour approval once an application has already been submitted?
A. An application can be withdrawn by the applicant at any time in the review process prior to the time a decision is made by the MONA CE Approver Unit Committee review team. If the application is withdrawn during pre-review (prior to submission to the Approver Unit reviewers), the application and fee will be returned minus administrative costs. Once the review is initiated (e.g., the application is sent to the reviewers) the fee is non-refundable. The withdrawn application will be returned to the provider.

Q: Can contact hours be awarded to participants of ACLS, PALS, BLS, and BLS Instructor courses?
A. Awarding contact hours for initial ACLS, PALS and other advanced "canned" courses is still permitted.

The Commission on Accreditation decided that contact hours for BLS and other basic "canned" courses may not be awarded. Any courses currently being presented (by either accredited providers or approved providers) must cease to award contact hours by June 1, 2011.

The Commission also decided that contact hours for renewal of ACLS, PALS and other advanced "canned" courses may not be awarded. Any courses currently being presented (by either accredited providers or approved providers) must cease to award contact hours by June 1, 2011.

Q. How will participants know that an educational activity has been awarded contact hours approved by the Missouri Nurses Association?
A. The following statement must be found on the certificate of attendance and on all written materials related to an approved educational activity:
This continuing nursing education activity was approved by the Missouri Nurses Association, an accredited approver by the American Nurses Credentialing Center's Commission on Accreditation.

The following statement must be used on the certificates of attendance and on all written materials related to the educational activities of the Approved Provider:
(Name of Approved Provider) is an approved provider of continuing nursing education by the Missouri Nurses Association, an accredited approver by the American Nurses Credentialing Center's Commission on Accreditation.

Q. What is the difference between a contact hour and CNE unit? Are they the same?
A. A contact hour and a CEU are not the same. The ANCC COA uses the "contact hour" as the unit of measure for approved nursing education activities. A contact hour is defined as “a unit of measure that describes 60 minutes (1.0 hours) of an organized learning activity that is either didactic or clinical experience. Contact hours may be awarded only for those portions of an educational activity devoted to didactic or clinical experience and/or to the time participants spend evaluating the activity.” (ANCC COA, 2009, pg. 7). The ANCC COA allows accredited approvers and providers of CNE to award contact hours for 60 minutes of participation in an approved educational activity. Besides didactic or clinical experience, contact hours can also be awarded for learner-directed and learner-paced independent studies.

The International Association for Continuing Education and Training is an international organization that allows agencies such as colleges, universities, and professional agencies to award a Continuing Education Unit (CEU) for their educational programs. Criteria for awarding CEU provider status include evidence of responsible providership, capable direction, and qualified instruction. One CEU represents ten contact hours of participation (600 minutes) in an organized continuing education experience; 0.1 CEU is equal to 60 minutes (ANCC COA, 1991; ANCC COA, 1996).

Staff development departments in a large health care or educational setting might be approved to offer both CEUs and contact hours. Since the CEU and contact hour are different units of measure, staff developers need to review their math when determining the amount of the unit to award participants. For example, if a program were 360 minutes long, the CEUs awarded would be 360 minutes or 6 hours ÷ 10 hours/CEU, or 0.6 CEUs. The contact hours awarded would be 360 minutes ÷ 60-minutes/contact hour, or 6.0 contact hours. It is important to note that the terms CEU and contact hour are not interchangeable.

Q. My agency is planning to offer continuing education programs and will be seeking MONA contact hours for our educational activities. How can we get help in preparing the application?
A. One of the MONA CE manuals, Continuing Education Excellence in Missouri: Approved Provider Manual, is designed to assist providers in meeting the criteria for approval of educational activities for contact hours. If, after reading the manual, further assistance or clarification is needed, the prospective provider should contact the Missouri Nurses Association where a CE staff member is available. Members of the CE Approver Unit Committee may also be available to meet with providers in their area of the state to assist in designing appropriate educational activities and to guide the provider in application preparation.

Q. My agency recently received provider approval. Several area-nursing organizations have asked us to approve their programs for contact hours. Is this acceptable?
A. No. An organization with provider approval can only issue contact hours for educational activities designed by that organization. Provider approval does not allow the Approved Provider to review educational activities and award contact hours. Nor can an Approved Provider award contact hours for educational activities provided by the agency if no member of the Approved Provider Unit has participated on the planning committee. If contact hours are to be awarded for an educational activity, a nurse member of the Approved Provider must be on the planning committee. Key points for providers to remember are that Providers provide but not approve activities. Providers can only provide activities in which the Approved Provider’s Primary Nurse Planner(s) assume(s) an active role in the entire process, from “assessing needs, planning, implementing and evaluating continuing nursing education activities.” (ANCC COA, 2009, p. 29).

If an educational activity is offered by two or more organizations (i.e. co-provided), the Approved Provider or organization awarded provider status by MONA may grant contact hours for the co-provided activity. However, the provider must have a co-provider policy that was included in the provider application submitted to MONA and that policy must be followed whenever co providing occurs. It is also imperative that the educational activity is planned and implemented with the direct involvement of at least one of the two nurse members of the agency's Approved Provider Unit.

Q. Must a member of the CE Unit in my agency be involved in all planning committees if we award contact hours?
A. Yes. In order to award contact hours for educational activities provided by an agency that has received provider approval, the Nurse Planner(s) of the Approved Provider Unit must be involved in the planning communication or each planning committee meeting for each educational activity receiving contact hours. The individual must be an RN with a minimum of a baccalaureate degree in nursing. However, planning can take place by telephone, mail, e-mail, as well as face-to-face meetings.
 
Q. There is a requirement for the nurse planner to "have education or experience in the field of education or adult learning". What kind of experience do you mean?
A. These are examples and are certainly NOT comprehensive:
     • Engagement on several CNE planning committees,
     • Academic education focused on education (Masters in Education, for example), or participation in a training session for Nurse Planners

Q. A number of speakers for our convention have submitted resumes. May we submit these resumes instead of the MONA Biographical Data Form included in the education activity application?
A. The MONA Biographical Data Form may be used but is not required. The applicant's goal is to submit the documentation in a clear, concise form, so that reviewers can readily identify the role played by, and the educational and experiential expertise of the presenters.

It is recommended that when using resumes or CVs that you provide an additional description identifying the role each of the presenters played through their participation in the activity since the CV or resume alone would not identify the person’s role in the activity, i.e. the check boxes located at the top of the sample biographical data form. When submitting Sally Smith, PharmD, MSN, RN’s vitae, it would be appropriate to include a separate piece of paper with the following information listed: Sally Smith, PharmD, MSN, RN, Instructor, Content Expert & Member of Target Audience.

Q. In my agency, we usually only have time for a 30 minute program. Can we offer continuing education contact hours for these short educational activities?
A. No, contact hours can only be awarded by MONA to educational activities 60 minutes or more in length. Programs of less than 60 minutes cannot be awarded contact hours.

Q. My agency is reluctant to submit budget information. How can we meet the criteria regarding financial support?
A. The intent of the criteria regarding budgeting is designed to demonstrate that the Approved Provider can financially support its CNE activities for the three (3) year approval period. A detailed budget is not required. The criterion states; "Submit a brief description of the provider unit’s current sources of financial support and projections for how financial support will be sustained throughout the period of accreditation.” (ANCC COA, 2009, p. 122).

Q. Our MONA district does not have an office. Our CNE documents travel from one officer to the next officer at the end of the biennium. We don't have a system for record keeping. What can we do?
A. All providers of CNE must have a system for record filing, storage, retrieval, and retention, and a system to ensure record security and confidentiality. It is important for your district to develop an appropriate record keeping system. Perhaps the district could purchase storage boxes and file folders to organize a filing system. The district should develop a written policy and procedure describing the filing system and rotation of the files.  It is also important to maintain these records for at least six years.

Q. Our agency offers workshops, seminars, and lecture series. We also offer learner-paced activities. In our application for provider approval, can we submit examples of three on-site educational activities?
A. Since the 1996 criteria, there is a single educational design, even though independent study or learner-directed activities are planned and implemented differently. If the Approved Provider offers both provider-directed and learner-directed learning activities, they should submit a sample of each type.

Q. If there is a single educational design; does that mean that pilot testing is no longer required for learner-paced activities?
A. The criteria do not require a pilot test specifically, but do require supporting documentation for the number of contact hours awarded (ANCC COA, 2009, p. 118).

Q. Our agency provides contact hours to those nurses who view a videotape of a program or conference. Is this appropriate?
A. It is appropriate to use videotapes or audiotapes and award contact hours only if the provider meets all the criteria, including "Describe how the Approved Provider ensures effective design principles are utilized, addressing the: learning goal (purpose), learner objectives, and related content; identified gaps, teaching-learning strategies used, including resources, materials, delivery methods, and learner feedback mechanisms; rationale and criteria for judging successful completion; and, the method selected for verifying participation" (ANCC COA, 2009, p.117-118). Nurses who attend the actual program or conference may receive a certificate specifying the number of contact hours obtained. However, it is not appropriate to award contact hours to individuals who only view a tape of the educational activity. If an agency provides a videotape of an educational activity for staff to review, a learner-directed activity should be developed with a pilot study and posttest questions if contact hours are to be awarded.
 
Q. Can contact hours be awarded to those individuals who are involved in the pilot testing of an educational activity?
A. Yes. Individuals acting as learners for the purpose of a pilot-test may receive contact hours for that educational activity when the appropriate number of contact hours has been established. Pilot testing is important in demonstrating the effectiveness of the teaching or learning materials used in the educational activity and in determining the number of contact hours awarded. The approved agency must maintain records of the data used in deciding the number of contact hours to be awarded for participating in an activity.

Q. Can contact hours be awarded if the individual only attends a portion of an educational activity?
A. A provider needs to determine whether partial credit can be awarded for an educational activity and should have internal policies in place to make a sound decision when these situations occur. If the educational activity is designed to have individual sessions each with its own objectives, contact hours may be awarded only for those sessions attended. If a specific number of contact hours are awarded for attending an entire educational activity, the provider of the educational activity needs to determine if partial contact hours should be awarded, again, based on the provider's own policies and criteria for verifying participation and successful completion of an educational activity. Generally, participants who are absent for a portion of the formal presentation should be held to the same standard as those who attend the total educational activity. The provider must be able to describe how learners were informed of the requirements for completion (ANCC COA, 2009, p. 120).

Q. We did not give a certificate of attendance nor contact hours to the speaker in our one-day conference? Was this correct?
A. A registered participant in the educational activity who presents or facilitates a portion of the total learning experience (e.g., a speaker or faculty member) should not be awarded credit for the portion of the educational activity that he or she presents. If; however, the remainder of the educational activity constitutes a learning experience for the speaker, credit for that portion of the educational activity may be awarded based on the provider's internal policies and criteria for verifying completion of an educational activity.

It is inappropriate for the speaker to receive contact hours for their presentations because they are considered the expert on the topic.  Going back to the definition, continuing education builds upon the nurse’s knowledge.  If the speaker does not have the knowledge, then they would not have been selected to present.

Q. My organization has published a series of home study booklets in 2006 which state that the contact hour is 50-minutes.  Because the 60-minute contact hour must go into effect January 1, 2007, must we throw away our stock of booklets?
A. No. You can continue to sell those booklets with the 50-minute contact hour.  Any new activities produced January 1, 2007 and after must indicate that one contact hour is 60-minutes.

Q. The criterion asks the applicant to identify the number of contact hours to be awarded, with supporting documentation. What supporting documentation are they looking for?
A. The educational objectives and the level and amount of content to be provided dictate the amount of time that will be required when the learners and presenters interact in real time, as in a course, seminar, or videoconference. Each topic area should have a designated time frame. The time allotments for content for each objective should be sufficient to facilitate achievement of the objectives by the learner. Indicating the time allotted for each objective will satisfy this “supporting documentation”. Whether the applicant is using the Educational Documentation Form or a narrative description of objectives, content, and time frame, they must indicate the time allotted for each of the objectives. Too often, adequate time is not allotted for the speaker to cover the content and help the learner achieve the objectives.

Q. The criterion states “Describe the teaching/learning strategies to be used in the activity, including resources, materials, delivery methods, and learner feedback” is confusing. Haven’t I already done this if I am using the educational documentation form?
A. Yes. If the applicant has completed the Educational Documentation Form then the areas of teaching/learning strategies, resources, materials, delivery methods, and learner feedback have been addressed. We no longer have separate application forms for an Educational Design I activity that involves participant attendance and Educational Design II activity that is self-directed by the learner or independent study. They have been combined into one application. Therefore, there are certain areas that have been included within the application that primarily address independent study activities. This criterion is one of those areas. If the applicant is submitting an independent study activity for approval, they would need to elaborate on these five areas more than with an activity that involves participant attendance.

Q. When calculating the number of contact hours I find that the number is two digits past the decimal point, or more.  For example, 1.66.  What is the number of contact hours I should use?
A. You can either award contact hours in the hundredths (i.e., two digits past the decimal point) or round down to 1.6.  Do not round up.

Q. How do you calculate contact hours for online or home study programs?
A. These hours must be calculated in a logical and defensible manner. One approach often used is the pilot study. Another approach sometimes used with written materials online is a recognized formula using data such as word count and level of reading and level of technical difficulty.

Q. Our MONA district offers educational activities at each of our monthly meetings. Should we apply for approval for each educational activity or would provider approval be more appropriate?
A. If the district plans to offer a number of educational activities over a three-year period, it may be more cost effective and time efficient to submit an application and receive provider approval. This allows the district to offer educational activities that include seminars, workshops, a lecture series, or individual educational sessions during a three year period and award nursing contact hours to participants. Or the district can submit an application for each educational activity individually using the criteria for approval of an educational activity if they are offering only a few activities.

Q. A program we are planning will have a mixed target population:  Registered Nurses, physicians, social workers, and hospital administrators. How do we address the target population for this program?
A. According to the new criteria, for each activity the provider must, "Describe the roles played by the Approved Provider's designated Nurse Planner(s) and any additional key personnel or groups involved in the process of ensuring the quality of educational activities." (ANCC COA, 2009, p.117). Multidisciplinary partnerships are encouraged, with the planners representing each discipline articulating specific learning needs. For example, a multidisciplinary conference on spinal cord injury was planned by nurses, social workers, and therapists, and all agreed on a need to know about advances in research. The keynote presentations were planned to focus on research and advances in knowledge, with breakout sessions for PT/OT, nurses, and social workers incorporating the advances into their own practice.

If there are no specific breakout sessions for registered nurses then it is the responsibility of the nurse planner to ensure during the planning meetings the topics and content is appropriate for nursing continuing education.  For example, the topic could be a general topic focused on the Institute of Medicine Report on Patient Safety.  This topic is very appropriate for a multidisciplinary audience.

Q. Should a certificate be given to all participants attending a CNE activity even if all of the participants are not RNs?
A. If the provider chooses to do so, certificates verifying attendance and the number of contact hours awarded can be given to all participants who meet the criteria for successful completion, whether the participants are RNs or individuals from other disciplines. Participants should be aware that the contact hours are specific to registered nurses and those other disciplines such as nursing home administration or speech pathology may or may not recognize the contact hours awarded by MONA or a MONA Approved Provider.

Q. What is the appropriate way to list the approval statement and the contact hours on the certificate? We typically list these items in the same sentence. Is that still appropriate?
A. NO. In years past, approved activities could alter the approval statement on their certificates to also include the number of contact hours awarded to the participant. For example: the current educational activity approval statement reads, "This continuing nursing education activity was approved by the Missouri Nurses Association, an accredited approver by the American Nurses Credentialing Center's Commission on Accreditation." Several providers would alter the statement to read "This continuing nursing education activity was approved for ___ contact hours by the Missouri Nurses Association, an accredited approver by the American Nurses Credentialing Center's Commission on Accreditation." to include the number of contact hours. The ANCC COA will no longer allow this alteration to the approval statement.

From this point forward, please list the approval statement separate from the number of contact hours awarded to participants. You are still required to indicate the number of contact hours awarded for attending the activity and include the approval statement, but they can no longer be included in the same sentence. The approval statement must stand alone. In other words it must start and end on a line separate from other text.

Approval statements must be exactly as written in the manual. No additional statements may be attached to the approval statement. If a provider would like to say that another agency has approved the activity, do so with a separate statement.

Formal complaints can be, have been, and continue to be, lodged against organizations where incorrect statements are used. As the Accreditation Program processes and decisions become more outcome-focused and evidence-based, the presence of complaints in an organization's file may, in the near future, result in additional requirements or documentation at the time of re-accreditation.

Q. It is not clear to me if the rules regarding the approval statement say that it needs to be on a separate line or just a self-contained sentence.
A. The approval statement must be both a self-contained sentence and be on a separate line from any other statements or text.

Q. Must the "pending approval" statement stand alone, or can it be on the same line as other information?
A. The pending approval statement must stand alone.

Q. When submitting a provider application with three samples, it seems that the three samples have the same narrative. Is this appropriate?
A. When submitting an application for provider approval, the provider should individualize each of the samples submitted. If the narrative for the educational activity is written generically, this may indicate to the reviewers that the provider does not fully understand concepts affecting educational design. The responses to the statements on the application should demonstrate the uniqueness of each individual educational activity.

Q. What is the difference between a co-sponsor and co-provider?
A. Co-Providership is the planning, developing, and implementing an educational activity by two or more organizations or agencies. ANCC Accreditation criterion requires that the Nurse Planner of the approved organization be fully responsible for the particular aspects of the process to assure adherence to all the ANCC criteria. A written co-provider agreement is completed.
Sponsorship is support (monetary or ‘in kind') furnished to the provider of the educational activity. Sponsorship must be acknowledged to learners. A written agreement is completed and signed by both organizations. When an educational activity is supported by more than one entity, each entity is a co-sponsor. Sponsors and co-sponsors do NOT participate in planning, developing and implementing the educational activity.

Q. Comments from the MONA reviewers on our last provider application indicated our evaluation of the overall provider program was weak. How can we enhance this aspect of our application?
A. Under the current criteria, the emphasis is on continual quality improvement of the Approved Provider's activities and operations. The criterion states: The Approved Provider “engages in an ongoing evaluation process to analyze its overall effectiveness in fulfilling its beliefs, goals and functions, and in providing quality continuing nursing education. Plans and goals for the Approved Provider's future development in continuing nursing education are identified and re-evaluated on a regular basis (ANCC COA, 2009, p.123).

A plan for evaluation indicates that the provider has a systematic method for evaluating its goals, operations, resources, and activities, involving the participation of faculty, planners, and learners. According to Phillips (1994), there are seven steps in developing an evaluation plan: 1) Define the purpose of evaluation; 2) Identify resources and limitations; 3) Decide what is to be evaluated and when; 4) Decide specifically what it is you want to know; 5) Decide how to do it; 6) Draft a plan; and 7) Review and test the plan.

The information found in Chapter 10, Preparing the Application for Provider Approval (under Criterion 4. Provider Unit Evaluation) may be helpful in developing a stronger evaluation plan.

Q. My agency has received provider approval through the Missouri Nurses Association. We are in the process of merging with another agency. How does this affect our approved provider status?
A. The review of the application and the awarding of the Approved Provider status were effective for your agency prior to any merger. Approved Provider status does not transfer to the newly merged, created agency. If an organization wants to continue to have Approved Provider status within the newly formed organization, the MONA CE staff should be contacted for guidance regarding what the organization needs to do to remain an Approved Provider.

Q. When a hospital is approved, but is part of a larger organization system, can they offer programs for the entire system under their name?
A. The Approved Provider can use their approved status only for those activities their provider unit plans, implements and evaluates. However, this provider can co-provide with other hospitals (either within the hospital system or without).

Q. Will other states accept MONA contact hours for re-licensure?
A. Usually, but not necessarily. MONA’s approval is recognized by all other states that are accredited as an approver, as well as by some states requiring mandatory continuing education for licensure renewal. If the state is a mandatory continuing education state then check with that state’s Board of Nursing. It is always best to contact the state's board of nursing or other professional licensing body when one's intent is to attend an educational activity to use the contact hours for re-licensure. The ANCC and MONA voluntary recognition systems are not related to mandatory continuing education requirements. States that require continuing education for re-licensure may have in place additional requirements that are not a part of the ANCC or MONA CE approval process.

Q. May our agency submit a co-provided sample as one of the three samples required in the provider application?
A. Approved Provider applicants may submit co-provided samples as long as the applicant is the primary provider of the educational activity.

Q. Can a first-timer provider applicant submit a co-provided activity as one of the three sample activities?
A. No.

Q: When submitting a provider application with three samples, it seems that the three samples have the same narrative. Is this appropriate?
A: When submitting an application for provider approval, the provider should individualize each of the samples submitted. If the narrative for the educational activity is written generically, this may indicate to the reviewers that the provider does not fully understand concepts affecting educational design. The responses to the statements on the application should demonstrate the uniqueness of each individual educational activity.

Q. The activity is not receiving commercial support and therefore has no conflict of interest, do I have to respond to that criterion within the education activity application and provide a copy of the conflict of interest form?
A. Yes.  Disclosing conflict of interest in the activity is not limited to activities that have received commercial support.  Conflict of interest forms from all planners and presenters must be disclosed for all activities regardless of the presence of commercial support.

Q. Under the current criteria, it is a requirement to have our planners and presenters disclose any conflicts by completing a conflict of interest form. What does this form look like? There is no sample included within the application and I want to make sure that I meet the criteria.
A. We do have a sample form located in our 7th edition of the CE Excellence in Missouri: Approved Provider Manual and Education Activity Manual. If you do not have access to the manual you may also view sample forms on our website at www.missourinurses.org.  You may also contact the MONA office and request a copy of the form.  Both planners and presenters must disclose any relevant conflicts of interest by signing a conflict of interest form for each activity they participate in.  Blanket statements and forms signed annually are no longer accepted.

Q. Our agency’s Nurse Planner is married to a pharmaceutical executive whose company sometimes provides educational grants for our CNE program. Does this disqualify her from involvement in planning at those times?
A. The purpose of the more detailed guidelines for Disclosure and Commercial Support is to ensure independence in educational content. You must be able to show that each individual in a position to control the content of an educational activity, i.e. planners and presenters, disclose any financial interest in a commercial entity (Standard 2, ANCC COA, 2009, p. 82).  ANCC COA interprets this as including financial relationships of a family member. The Nurse Planner is not disqualified, but must 1. Disclose the potential conflict of interest in the Conflict of Interest form, which is part of the activity file, and 2. Disclose the potential conflict of interest to learners of any such relationship either present, or within the past 12 months.

Q. What are the requirements for electronic signatures (on disclosure statements, COI statements, etc)?
A. Signatures, electronic or original, are not required. However, if a signature is not used, then documentation that you received the disclosure information from the source of the information will be needed. For example, if the form was faxed, you would need to save the cover sheet with the person's name and phone number on it. You need to use a method that makes you comfortable that documentation has been secured, and which provides verifiable proof after the fact. It is acceptable to use a single form to meet the requirements of multiple accrediting bodies. The individual requirements for each accrediting body must be met by the form.

Q. Our annual Perinatal conference is always generously sponsored by a large formula manufacturer. They pay all the speakers directly. They provide attractive conference bags with their logo, and their excellent print materials are part of the handout packet. They also display product information in the main classroom.  Is this appropriate under the new criteria?
A. You will need to review the new guidelines carefully. You must have a written agreement with each entity providing commercial support, signed by both parties, that follows the ANCC COA guidelines. The provider or co-provider, not the commercial entity, must pay speakers or authors from an unrestricted educational grant. You must take care to keep educational content separate from product advertising; items with company ads or logos cannot be handed out where you register participants and hand out the educational packet, but rather at a separate table. Likewise, commercial advertising or logos can be present in an exhibit room, but not in the room where presentations occur. The presence of commercial support must be disclosed to participants in print or written form or by an announcement prior to the start of the activity.

Q. If there is no conflict of interest; do we need to disclose it?
A. The provider must secure from presenters and planners a statement regarding conflict of interest on a conflict of interest form whether there is a conflict or not.  The presence or lack thereof must be disclosed to the learners.

Q. What is a commercial interest company?
A. Commercial product companies include:
     • Any entity either producing, marketing, re-selling, or distributing health care goods or services consumed by, or used on, patients or
     • An entity that is owned or controlled by an entity that produces, markets, re-sells, or distributes health care goods or services consumed by, or used on, patients.
Exceptions are made for non-profit or government organizations and non-health care related companies.

Q. Can the sponsor logo be used on the certificate of completion?
A. No.

Q. Can a commercial supporter require that only their clients be given credit for an activity?
A. No.

Q. Is paying for food considered to be commercial support?
A. Yes.

Q. Our Oncology Nursing Society chapter often invites expert nurses who are on the speakers’ panel of drug manufacturers. What should we do to maintain compliance with ANCC COA criteria for disclosure and commercial support?
A. The speaker must disclose the relationship on the Conflict of Interest form, and you must inform learners either in print or by verbal announcement prior to the activity. You must keep written documentation that verbal disclosure occurred. Slides and handouts must be free from company logos and advertising. According to criteria, presentations must give a balanced view of therapeutic options, and use of generic names of drugs is preferred; if trade names are used, trade names from several companies should be used.

Q. I am trying to respond to the criterion related to commercial support.  We are not holding exhibits or receiving money from pharmaceutical companies, therefore we are not receiving commercial support for the activity.  However, the activity is being sponsored by another company.  How do I respond to the criterion?
A. You would respond first that there was no commercial support received for the activity. And secondly would indicate that yes, there was sponsorship received for the activity. If you are receiving funds, supplies or in-kind services from an outside agency and that agency is not participating in the planning, developing, and implementing of the educational activity, then you are receiving sponsorship. This sponsorship must be acknowledged to learners and a written agreement is completed between the agencies.

Q. Our nurse planner is married to a man who works full time for a major pharmaceutical company. He owns stock and receives salary. When our nurse planner completes her disclosure, must we publish (disclose to the audience) this info for EVERY program we do of which she is a part or only those when this pharmaceutical company is financially supporting and/or exhibiting at?
A. You will only need to disclose this information when it could cause - or could cause the perception -that a bias in the continuing education being planned or implemented. In other words, if the activity is related to a product or service of the pharmaceutical company, then this would need to be disclosed. An alternative might be that you train a second nurse planner who would direct the planning committees addressing the educational activities where there might be a relationship with the pharmaceutical company.

Q: Must we limit the promotional activities of companies that are not considered commercial entities?
A. Yes. Promotional activities should never occur within educational activities – regardless of the nature of the company wishing to promote themselves or their product(s).
• Example #1: A speaker has written a book related to the topic that s/he is addressing in the presentation.
Acknowledgement of the speaker's expertise in the area may be made but the speaker may NOT encourage the learners to buy the book ‘in order to learn more' or for any reason. Additionally, if there is to be a 'book signing', it should NOT be mentioned before, during or subsequent to the educational activity and it should occur in an area OTHER THAN the education area.
• Example #2: A not-for-profit healthcare entity agrees to sponsor education. They wish to include ‘an invitation to practice' at their hospital in the educational material provided to the learner.
While the not-for-profit healthcare entity does not meet the definition of "commercial entity", the scenario in question mixes educational activity with promotional activity. This is not allowed. The sponsor must be acknowledged but that acknowledgement cannot result in a promotion of the sponsor. Learners should not feel "pressured" or marketed to by the sponsor of the program or should not receive promotional information because they participated in a CNE activity.

Q. We would like to distribute a list of participant names and contact info to all who attend at our upcoming conference. Is this permitted?
A. Since the names of participants and their contact info is confidential information, it is permitted only if you secure approval before the conference from the individuals whose names are on the list. The registration form might include a question asking for this approval and providing an "opt out" checkbox for those who wish to deny permission.

Q: Please explain the new rule regarding the boundary for approved providers.
A. An organization with a majority of CE activities targeted to nurses
     • from states within their region (see map) OR
     • from within the region where the activity is to be provided or a state contiguous to it
may apply to an approver to become an Approved Provider or may apply to ANCC to become an Accredited Provider, or may continue to apply for individual activity approval from an Accredited Approver.

An organization with a majority of CE activities targeted to an audience of nurses from
    • outside the states of their HHS region (see map below) or states contiguous to that region must apply to ANCC to become an Accredited Provider.

Q. What is the reason for this rule?
A. There have been incidences of providers being denied by one approver who then go to a series of other approvers until they find one that will approve their activity. These come to our attention through complaints from participants. It is therefore more efficient and protects the participants if ANCC reviews and accredits all of the providers reaching the larger audiences, so that they can be monitored more closely.

Q. Must a provider whose majority of CE activities include internet activities/enduring materials or other learner-paced activities that target a nationwide audience apply to ANCC?
A. Yes.

Q. Can providers who target a nationwide audience and are already approved continue with their approval until its expiration date?
A. Yes.

Q: Why do we have Criterion 2: Educational Design and also Criterion 5: Sample Activities. Aren’t they the same thing?
A: NO. The sections appear similar but one asks you to describe your procedure or process of planning all activities and the other is an example of adherence to the procedures you described. Criterion 2: Educational Design focuses on the overall planning of all educational activities within the Approved Provider Unit. You will respond to each Supporting Evidence with general information about all educational activities, not specific information to any one activity that has or will be offered. Criterion 5: Sample Activities is where the applicant will provide three samples of educational activities offered during the previous approval period. In some cases, if planning sheets are set-up accordingly, this can be a complete photocopy of the activity file from the file cabinet. Others may take some organization to submit the necessary paperwork to meet the application requirements. Either way, there will be narrative responses for Supporting Evidence 1-10, specific to that educational activity. These narratives will be followed by the supporting documentation required, i.e. educational documentation form, bios for planners & presenters, conflict of intere

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