There may be occasions when providers accredited by MMS merge with each other or with non-accredited health care organizations. Should a merger occur, it is the responsibility of the accredited provider to notify MMS of this restructure. Such mergers are considered to be a substantial change and may require the Committee on Accreditation Review to re-evaluate a provider at any time less than the period specified for current accreditation. This re-evaluation may require that an Interim Report be submitted and that the new corporate entity/controlling entity be considered for accreditation as a new provider. In all instances, the usual MMS accreditation procedures will apply.
In all situations where a site survey is required, the new
corporate entity/controlling entity will be given a period of time
set by the Committee on Accreditation Review, in which to submit a
new Accreditation Application. If the new corporate
entity/controlling entity meets the submission deadline, the
Committee will extend the existing accreditation to cover CME
activities offered by the new corporate entity/controlling entity
until a site survey has taken place and an accreditation decision
has been made. If the application is not received by the
deadline, then accreditation will be withdrawn as of that date, and
the new corporate entity/controlling entity will no longer be able
to award AMA PRA Category 1 credit to its CME programs.
Mergers Requiring the Submission of an Interim
Report: Site Survey May be Required
- A new health care corporate entity is created by the merger
between accredited organizations, and the separate organizations
cease to exist.
- A merger occurs between accredited organizations, one of the
organizations assumes corporate control, and while a new corporate
entity is not created, the other accredited organization ceases to
exist as a separate entity.
- A merger occurs between an accredited organization and a
non-accredited organization, the accredited organization assumes
corporate control, and, while a new corporate entity is not
created, the non-accredited organization ceases to exist as a
separate entity.
A site survey may be required for the new corporate entity/controlling entity. In making this decision, factors that the Committee on Accreditation Review will consider are: the degree of change or continuity in the new corporate entity/controlling entity’s CME committee (what percentage of membership of the organization's CME Committee is retained from the previously accredited entity); the relative size of the merging entities (will a large entity assume corporate control of a small entity or vice versa ); changes/continuity in the medical staff (is the majority of the combined medical staff from the accredited organization); the creation of one set of medical staff bylaws; changes in the audience served by the CME program, and the degree to which all physicians' needs are addressed by the new corporate entity/controlling entity's CME needs assessment process.
Mergers Requiring a Current Provider to Seek
Accreditation as a New Provider
In the following merger situation, the Committee on
Accreditation Review will require the new corporate
entity/controlling entity to seek accreditation as a new
provider:
- A new health care corporate entity is created by the merger
between an accredited and a non-accredited organization and the
separate organizations cease to exist.
- A merger occurs between an accredited and a non-accredited
organization, the non-accredited organization assumes corporate
control, and, while a new corporate entity is not created, the
accredited organization ceases to exist as a separate entity.
Should the new corporate entity/controlling entity be successful
in achieving accreditation, it would receive either a one year or a
two year provisional accreditation, which are the accreditation
terms available to new providers. Because this is considered
to be a new application, the standard survey fee will be due upon
submission of the accreditation application.
Mergers Having No Effect On Existing
Accreditation
Finally, if a merger occurs where a new corporate management
structure is created, but health care facilities, and most
importantly, medical staffs, maintain separate identities and
separate medical staff laws, then each accredited organization can
maintain its accreditation and may jointly provide CME activities
with its non-accredited merger partners.