Vanderbilt University Medical Center
Policy: Continuing Medical Education for Physicians Not employed by VU
Under current law, Vanderbilt University Medical Center may only provide continuing medical education
(“CME”) activities to physicians who are not employed by Vanderbilt University1 (“Non-VU Physicians”)
under limited circumstances. In order to comply with applicable law, Vanderbilt University Medical
Center has adopted the following policy regarding the provision of CME activities for Non-VU Physicians.
1. Policy: All Non-VU Physicians who attend or participate in CME activities that are certified for CME
credit2 by Vanderbilt University in any manner (including without limitation the School of Medicine,
or other administrative or clinic units of Vanderbilt University Medical Center) shall be required to
pay an applicable registration fee in an amount equal to the fair market value of the activity.3
a. Such fee shall be inclusive of any food, materials, or other goods, items, or services are provided
by Vanderbilt University at the CME activity.
b. Further, Vanderbilt shall not reimburse any Non-VU Physician for any registration fees, meals,
lodging, travel expenses, or any other out-of-pocket costs related to such Non-VU Physicians
attendance at a CME activity.
2. Exceptions
a. The reimbursement limitations set forth above shall not apply to any Non-VU Physicians who
are speakers or presenters at a CME activity and may be receiving reimbursement in accordance
with applicable policies of Vanderbilt University for their speaking or presenting services. To the
extent that such individuals participate in other CME-activities other than the specific activity at
which he/she is speaking, such participation shall be governed by the policy set forth above.
b. Vanderbilt will not be required to charge a registration fee for any CME-certified activity offered
to the local community, including Non-VU Physicians, at a location in such local community for
which the primary purpose is compliance training.4
1
For the purposes of this policy, employed by Vanderbilt University means any one to whom Vanderbilt University issues a
Form W-2 Wage and Tax Statement and for whom CME activities are an obligation for maintaining and obtaining his/her
faculty appointment. Part time employees who do not receive full benefits shall not be considered VU employees for
purposes of this policy.
2 The AMA has defined Certified CME as: ‘1. Non-promotional learning activities certified for credit prior to the activity by an
organization authorized by the credit system owner, or 2. Non-promotional learning activities for which the credit system
owner directly awards credit.’ This definition includes all activities certified for credit, prior to the activity, through the
medical profession’s three major credit systems owned by three professional organizations: the American Academy of Family
Physicians (AAFP credit), the AMA [AMA Physician Recognition Award (PRA) Credit], and the American Osteopathic
Association (AOA credit). [National Task Force on CME Provider/Industry Collaboration FACT SHEET Volume 3, Issue 1]
3 The fair market value to be used to be compliant with this policy is $25.00 per credit, effective for all CME activities approved
on or after July 1, 2012. Fair market value will be updated every year in June to be effective the following July 1.
4 “Compliance training” means “training regarding the basic elements of a compliance program (for example, establishing
policies and procedures, training of staff, internal monitoring, or reporting); specific training regarding the requirements of
Federal and State health care programs (for example, billing, coding, reasonable and necessary services, documentation, or
unlawful referral arrangements); or training regarding other Federal, State, or local laws, regulations, or rules governing the
conduct of the party for whom the training is provided.” Fed. Reg. 51095 (Sept. 5, 2007).
c. Vanderbilt will not be required to charge a registration fee for attendance or participation in a
CME-certified activity that is wholly funded by a third party non-profit entity where a VU
employed physician may be a speaker or presenter.
d. Vanderbilt will not be required to charge a registration fee to Non-VU Physicians for CMEcertified activities for which a non-profit organization is ultimately responsible for the planning
and implementation.
e. Vanderbilt will not be required to charge a registration fee to Non-VU Physicians who are
members of Vanderbilt alumni groups or associations for CME-certified activities so long as
(1) the opportunity to earn CME credit is advertised to such individuals as a benefit of
membership, and
(2) the sponsoring alumni group or association pays Vanderbilt the fair market value of the
CME-certified activity for the activities of its members.
f. Vanderbilt will not be required to charge a registration fee to Non-VU Physicians for CMEcertified activities for which governmental support has been awarded to Vanderbilt and such
support is intended to be used to reduce or eliminate the cost of a registration fee (i.e., federal
grants for educational initiatives).