Frequently Asked Questions
ARBO New Standards for Commercial Support of COPE Approved Continuing Education (March 2008)
General
Instructor Specific
CE Administrator Specific
ARBO New Standards for Commercial Support of COPE Approved Continuing Education (March 2008)
Why is COPE setting new standards for support?
- COPE is being proactive
The federal government has taken renewed interest in the relationships between industry and healthcare. Since 2000, new regulatory policies aimed at consumer protection and controlling healthcare costs have placed new restrictions on industry interactions with healthcare professionals. Many previously accepted activities are now being questioned. As a result, more industry support has been moved into grants for continuing education activities creating potential conflicts of interest issues for all healthcare professionals. In 2004 the Accreditation Council for Continuing Medical Education (ACCME) addressed these issues by releasing their "Standards for Commercial Support" and in December of 2006 there was federal scrutiny of the effectiveness of these standards. In response, CE accrediting organizations are implementing guidelines implemented guidelines to appropriately manage industry relationships and support of CE activities to ensure transparency, fair balance, content free of commercial bias and an effective system of oversight.
COPE has taken notice of these events and is being proactive.
- To provide a structured environment
Parallel to government inquiry, various Industry groups developed their own voluntary codes on relationships with healthcare professionals. PhRMA and AdvaMed have been in existence since 2003 and have proven to be subject to differences in interpretation. Boundaries need clarification and non-biased interpretation. To operate in a fair and impartial manner, COPE can provide a safe environment for all to operate. Therefore COPE is strengthening the existing guidelines and providing a system of oversight.
- There is a general consensus
In 2006, leaders from the AOA, NBEO, ASCO and ARBO gathered in Chicago Illinois to … "develop a profession-wide consensus-driven approach to the future of continuing education and optometric competence for the benefit of the public" From this meeting, there was agreement that new guidelines were needed for commercial support of optometric continuing education events.
COPE is acting on these recommendations.
- It's the right thing to do
The integrity of our CE system has played an important historical role in the advancement of our profession.
Mandatory continuing education is a requirement of licensure recognized by all fifty state boards. Continued improvement and protection of the integrity of this system is important for our profession and the public welfare to ensure continued competence.
Do these guidelines apply to all commercially supported events?
These guidelines apply only to COPE APPROVED CE events. They do not necessarily apply to state board approved CE events. In addition, industry remains able to organize speaker bureaus and conduct regional and state informational seminars that are not COPE approved.
Are these guideline in effect now?
No, the guidelines recently released are still in draft form. COPE released them in draft form to allow for stakeholder input. While we anticipate that the core principles of the guidelines will remain intact, we encourage discussion and review and will remain receptive to suggestions that may decrease administrative burden or associated costs as well as address logistical concerns while maintaining the objectives of independence, transparency, and educational content free of commercial bias.
Does this mean that a commercial entity can no longer act as a COPE administrator?
In order to ensure that Industry support of CE does not influence content, there must be separation between financial support and the control of all processes that occur in the administration of the CE event. Processes that carry potential for commercial bias include speaker and topic selection, distribution of promotional materials, and the development of presentation materials. Due to this potential conflict of interest, commercial entities will no longer be approved as COPE administrators. Commercial support of a COPE approved CE event can only occur through an unrestricted grant to a COPE-approved administrator. This is a major change from current COPE policy.
Does COPE desire to reduce or eliminate corporate support of CE?
No, the mission of COPE is to assist our member state Boards by providing a standardized method by which optometric CE is approved and administered. Encouraging or discouraging corporate support is not a part of the mission.
COPE recognizes that industry-subsidized continuing education can be effective and free of commercial bias. The requirement that industry support of COPE approved CE events is only secured through unrestricted educational grants reduces the potential for industry to influence content and delivery. This solution can lower costs and increase the availability of CE for Optometrists while ensuring transparency and content that is free of commercial bias. If managed appropriately, it can enable lifelong learning … improve patient care … and benefit the public welfare.
Does COPE anticipate that the increased burden imposed by the new standards will reduce commercial support of optometric CE?
No. This issue of concern is not unique to optometry. Other health care professions that have incorporated similar standards have documented a substantial increase in corporate support. These standards create the safe harbor as defined by the government for industry to provide support without fear of reprisal.
Will these new standards impose any additional limits on off label discussion of product or services?
No. The standards actually create an environment of independence for the lecturer that insulates them from federal guidelines, prohibiting off-label discussion. Although the lecturer is free to discuss off-label use, there are disclosure requirements that will ensure transparency.
How can an onsite COPE reviewer monitor my course presentation and assess the content when he is not an expert in my field?
The On-Site Reviewer does not peer review the presentation content. Their emphasis is on adherence to the guidelines such as proper disclosure and length of presentation. Content is only reviewed to determine that it is consistent with the original submitted outline and free of commercial bias.
What happens to all the courses that are currently COPE-qualified and good for up to 3 more years? Can we no longer use them since we can't hold events?
The new guidelines will be finalized and implemented by 01-01-2009. Although you may still hold these events, the existing guidelines that prohibit promotion of products are still in effect until the implementation date. Speakers are still required to present lectures that are scientifically valid and without commercial bias. As of January 1, 2009, courses that are not constructed in an independent manner will be prohibited therefore existing speaker bureau type courses will be expired.
Will I/we know when an on-site reviewer is in the audience?
In most cases the reviewer will be attending a course that he/she would normally attend for CE credit and will not be announced. Anonymity insulates the reviewer and enhances their objectivity.
Will I/we receive a copy of the report of the On-Site Review (OSR)?
In the event the review finds non-compliance with guidelines the administrator and or lecturer will be notified of those discrepancies.
What if I/we don't agree with the OSR report? Do I/we have any recourse?
Yes this lecturer will have thirty days to appeal in writing. The appeal will then be presented to the entire COPE committee for review.
Many small societies do not have the infrastructure to comply, what shall we do?
COPE is aware that the new guidelines may impose increased administrative burdens on small state societies making it difficult to continue to offer COPE approved courses.
COPE has considered this issue and is looking at numerous alternatives such as empowering the parent state association to act as an administrator. Policy has not been formulated pending the period for comment. We invite your input on potential solutions that may lessen this burden.
We have a concern that funding of our state meeting will decrease if we implement these requirements.
Although this is an acknowledged possibility, the experience of other professions indicates this is unlikely to occur. Industry has indicated they want to continue to support the profession. They have also indicated they want a level playing field and established boundaries. Although it is not the primary intent of COPE, the guidelines will provide a safe environment where industry funding could grow.
General
What is COPE? What is COPE's Purpose?
Optometric continuing education (CE) is the primary method used by optometric licensing boards to promote the continuing competence of licensed optometrists. There are myriad formats by which each optometry board or licensing jurisdiction approves CE courses, disseminates course information, records course attendance, and retrieves practitioner data on course completion. One state boards duplicates much of the administrative work done by another state board, and many boards approve the same CE courses every year.
The Council on Optometric Practitioner Education (COPE), a national clearinghouse for all CE courses of a state-wide, regional or national scope, was created to remove these duplicative efforts by state boards, instructors, and program administrators.
Courses submitted to COPE are appropriately categorized according to content area, undergo peer review, and are then entered into COPE's database of CE courses. The courses are then shared with state boards, which verify credit certificates against the data we collect; by program planners, who seek courses for future meetings; and by practitioners, who prefer COPE Approved CE as it is often already accepted by their state for credit towards license renewal.
Created in 1995, COPE is a service of the Association of Regulatory Boards of Optometry (ARBO), which is the association that currently represents 50 US optometry boards, 4 US territories/jurisdictions, and 2 Canadian boards. COPE's mission is to:
- coordinate the review and approval of continuing optometric education courses on behalf of state boards on a national basis;
- reduce duplication of effort by state boards;
- create a uniform method of recording continuing education courses on a national basis;
- be the clearinghouse for information about continuing education programs and courses utilized by licensed optometrists to fulfill their continuing education requirements for license renewal; and
- encourage program sponsors to offer high quality CE in appropriate settings with adequate administrative structure.
To create this national clearinghouse, participating state boards have agreed upon standards for administration of continuing education courses; a standard form for submission for course approval; and a standard form for reporting continuing education courses.
What Does COPE Do for State Boards of Optometry?
COPE decreases the amount of paper work currently required of licensing agencies to approve the hundreds of optometric continuing education (CE) courses reviewed by state boards annually. By endorsing a representative body (COPE) to review proposed continuing education courses on their behalf, each agency or state board no longer needs to review each individual course. At the same time, as the administration of courses is important to the overall effectiveness of CE, COPE reviews the procedures and policies of program administrators to assure compliance with reasonable standards.
By centralizing and standardizing the method of obtaining CE credit for a course, COPE simplifies the review and approval process, benefiting not only boards of optometry, but also CE providers and practitioners.
How Do States Know What Courses are Approved?
At regular intervals, COPE updates its web site with the latest COPE Qualified Course information, and cross-references it with additional information on meetings and COPE Qualified Administrators. Boards can confirm if a course is COPE Approved by entering the COPE ID number provided on a practitioners CE attendance verification form. Each course listed on this site contains the following information:
- COPE ID#
- course title and hours
- course category
- course presentation
- course format
- course principal instructor
- course administrator
- course presentation date(s) and location
Has COPE Taken Over CE Course Approval from the State Boards?
No. Boards of optometry that participate in COPE are still free to (and the vast majority do) accept or deny CE credit for courses submitted directly to them. In rare cases, participating boards may also deny CE credit for specific COPE Approved courses that do not meet their regulations.
How Do Doctors Know if a Course is Approved?
Promotional information published by administrators of educational events should publish the COPE logo, or a similar, clearly identifiable mark, together with a course description to denote COPE Approval. Each COPE Approved course must have the COPE course identification number and COPE course category clearly visible with the course description. COPE provides the COPE logo to Administrators to use in promotional materials to help doctors easily identify courses that are COPE Approved.
Administrators may only use the following specific terms when advertising program content approved by COPE:
If the program has been filed with COPE, and all submitted courses are qualified:
COPE Approval granted for some or all parts of this program
If the program has been submitted for review to COPE, but review is not yet complete, or the Administrator intends to submit the program for review:
COPE Approval Pending
No other descriptions or terms are permitted as they relate to the COPE logo or the acronym, COPE.
Is COPE a Provider of Continuing Education?
No. COPE's mission is to help set and maintain standards of optometric continuing education (CE). COPE's job is to assist optometry boards with the approval of CE, not to act as a provider of CE.
Is COPE a Separate Organization from ARBO?
No. COPE is a service of ARBO, and is not separately incorporated or organized.
When is a Course Considered Approved For CE Credit?
A course is considered approved by COPE for CE credit after a three-step process:
- The course instructor files a two-page form with COPE, enclosing a course outline, CV and application fee. The course is reviewed by COPE and, if it meets COPE's course criteria, is declared a COPE Qualified Course.
- CE providers file a two-page form with COPE identifying the date and location of an upcoming meeting/conference, and providing a list of courses and COPE ID numbers (if known) scheduled for presentation. Receipt of this form designates the CE provider as a COPE Qualified Administrator.
- COPE Qualified Courses presented at a meeting/conference organized by a COPE Qualified Administrator are then considered COPE Approved for CE credit by all participating boards of optometry.
ALL THREE STEPS MUST BE COMPLETED FOR A COURSE TO BE
CONSIDERED COPE APPROVED
Verification: COPE posts all relevant meeting and course information on the Internet at http://www.arbo.org/ , where it is available for boards of optometry to access. Boards verify attendance certificates distributed to course participants against information posted on COPE's web site.
What Courses Does COPE Approve?
COPE approves courses of a state wide, regional or national scope. COPE usually does not approve courses that are of a limited drawing area, i.e., local in nature, however, COPE will review any application for qualification from any administrator or course instructor.
Who Pays for COPE?
COPE charges instructors a fee to review a course when it is submitted for COPE Qualification. Additionally, a filing fee is charged when the CE Administrator submits the list of selected courses for reporting to boards of optometry. All fees are kept as low as possible, and are set to cover the functioning of COPE only. Boards of optometry are not charged a fee, as COPE is a benefit for members of ARBO.
Once a Course is Considered COPE Approved, Do All Participating Boards Automatically Accept It?
Boards of optometry are not required to accept all COPE courses without exceptions. Boards may establish in their rules/regulations exactly which COPE courses they will accept. For example, Wisconsin accepts all COPE courses except those submitted as Practice Management. Click here to see a list of COPE's course content areas. Participating boards may specify in their rules/regulations those categories for courses it chooses to accept. Practitioners are advised to confirm directly with their board of optometry those course content areas that are acceptable.
What is a COPE Course Reviewer? How Do I Become One?
A COPE Course Reviewer is a state board-endorsed optometrist who has volunteered with COPE to review courses for qualification. Reviewers serve indefinitely and are not compensated for their service. Reviewers are required to examine in detail course materials that are submitted to COPE, determine if it is in compliance with the Criteria for Course Qualification, and, where necessary, provide appropriate guidance for modification or adjustment. Reviewers typically process about 15-20 courses a year.
If you are interested in serving as a COPE Course Reviewer, send an e-mail to arbo@arbo.org with your name and address and we will send you an application. Once your application is received by COPE, your name will be forwarded to your state board of optometry for consideration. Once your state board has endorsed your application, you may begin service as a COPE Course Reviewer.
What if I have a complaint about a COPE course I attended?
COPE has an process for investigating complaints made about courses or events that do not comply with COPE’s policies.
INSTRUCTOR-SPECIFIC
What Does COPE Do for Course Instructors?
COPE allows an instructor to submit courses for qualification to a central agency that acts on behalf of boards of optometry (which have ultimate authority for the approval of optometric CE for license renewal). While in the past instructors have relied on CE Administrators to obtain state board approval, courses that are already COPE Qualified reduce the amount of work required of Administrators and hence are more attractive to their programs. Also, instructors participating in the COPE program will help improve the standards of optometric CE.
Perhaps the major benefit to instructors is the potential for greater acceptance of their courses by Administrators once they are COPE Qualified. COPE Qualified Courses naturally attract a greater number of meeting attendees who are specifically seeking COPE CE credits that are already accepted by their respective board of optometry.
Additionally, COPE provides a list of all COPE Qualified Courses to CE Administrators on request. Consequently, if a course is Qualified it will receive considerable exposure to CE program planning committees nationwide.
If the Same Course is Presented at Multiple Sites and On Different Dates, Does the Instructor Have to Submit a Course Qualification Application for Each Site?
No. The instructor submits the course only once for Qualification; providing there are no significant changes to the course content, Course Qualification is valid for 36 months. It is the CE Administrator's responsibility to obtain Course Approval.
Is There an Appeals Process for Instructors Whose Course Application is Denied?
Yes. Should the initial reviewer deny Qualification for a course submitted by an instructor, the instructor may rectify the reason for the denial and re-submit the course and/or may request an immediate second review by another COPE reviewer. Should the second reviewer also deny Qualified Course status, the instructor may submit an appeal to the Council on Optometric Practitioner Education (COPE) itself, i.e., the ARBO committee responsible for the administration of COPE. The decision of COPE is final in all cases or circumstances.
What Forms Do You Have Online?
Visit our Downloads page. You can download the Application for Course Qualification in PDF format. You will need Adobe Acrobat Reader, a free download, to view the form and print it out. A link to download the software can be found on the same page.
You can also download the most recent version (December 2000) of the Information & Application for Course Qualification booklet from the same page.
Where Can I Find a Complete List of All My Courses Filed with COPE?
Visit the Course Search feature of the State Board Search, enter your last name into the Instructor field and click Search. A list of all courses ever filed with COPE, where you are listed as Principal Instructor, will display in ID number order. However, not all of these courses may be available for use at future meetings as some may have expired or be tagged as an ASCO-only course. For a list of current and available courses, go to the Course Search feature of the Administrator Search and run the same search again. The difference between the two lists are those courses that have either expired or are tagged for restricted use. Contact the COPE office if you have specific questions about your courses.
Can I Submit an Application for Course Qualification Online?
Instructors may not submit applications online and upload the required documents. Use the link Instructors-Submit Courses to begin the process.
CE ADMINISTRATOR-SPECIFIC
What Does COPE Do for CE Administrators?
While COPE was developed originally to reduce the amount of duplicative work carried out by state boards when reviewing courses for CE credit for license renewal, this program has some major benefits for CE administrators. In the past, CE Administrators often submitted their program to several state boards depending on attendee demographics. National and regional meetings obviously had a greater burden than state meetings. All states had different requirements, and the administrative time needed to obtain approval for a program was usually significant.
Under the COPE program, instructors submit their course(s) for Qualification once every three years, no matter how many times they are offered, and by developing standardized review criteria, all courses that are Qualified are immediately acceptable to participating boards of optometry when presented by a Qualified Administrator. Having a large number of COPE Approved Courses in a CE program will, naturally, attract a larger attendance.
As a planning resource to CE Administrators, COPE provides, at no charge, a database of all Qualified Courses to assist with the development of CE programs. We currently support a number of standard software packages. Alternatively, CE Administrators may search the listing of Qualified Courses online at this site, again at no charge and with no requirement to register with COPE.
Can I Advertise That My Organization Intends to File With COPE for Approval in Pre-Meeting Promotional Material?
Yes, however, the wording that you may use is very specific. Administrators may only use the following specific terms when advertising program content approved by COPE:
If the program has been filed with COPE, and all submitted courses are qualified:
COPE Approval granted for some or all parts of this program
If the program has been submitted for review to COPE, but review is not yet complete, or the Administrator intends to submit the program for review:
COPE Approval Pending
No other descriptions or terms are permitted as they relate to the COPE logo or the acronym, COPE. Administrators who wish to use COPE's services must agree to use this wording as part of the Criteria for Administrator Qualification. Please note that both the logo and acronym, "COPE," are registered service marks and are protected under the Trademark Act from improper or illegal use.
As a Qualified Administrator, Can I File Courses on Behalf of Instructors and Pay the Fees?
Yes, providing the instructor is informed and understands what you are doing. It is important to note that an Application for Course Qualification is NOT considered complete unless the instructor signs the application form.
Is There an Appeals Process for Administrators Whose Application is Denied?
Yes. Should a CE Event Reporting Form be denied, Administrators may appeal the decision to the Council on Optometric Practitioner Education (COPE) itself, i.e., the ARBO committee responsible for the administration of COPE. The decision of COPE is final in all cases or circumstances.
How Do I Get a Copy of the COPE Logo for My Promotional Materials?
Camera-ready art slicks of the COPE logo are available, without charge, to COPE Qualified Administrators to use in promotional materials to help identify the status of CE approval to your meeting attendees. The logo can also be supplied as an electronic file (jpg). Please contact the COPE office to obtain a free copy of the COPE logo.
Can I Get a Copy of Your Database to Help Me With Planning for My Next Meeting?
Yes. If you prefer not to search for courses online, a copy of the entire COPE database of Qualified Courses can be e-mailed or mailed to you. The database is available in a number of formats, including Access, Excel, dBASE, FoxPro, text file (ASCII) and others. Please contact the COPE office for more details.
What Forms Do You Have Online?
Visit our Downloads page. You can download the CE Event Reporting Form in PDF format. You will need Adobe Acrobat Reader, a free download, to view the form and print it out. A link to download the software can be found on the same page.
You can also download the most recent version (January 2001) of the Information & Application for Administrator Qualification booklet from the same page.
How Can I Verify if My Meeting Has Been Registered By COPE and Reported to State Boards?
Visit the Meeting Search feature of the State Board Search, look for your organization name in the drop-down list and then click Search. A list of all meetings your organization has ever filed with COPE will display in date order. You can click on the meeting title to see a list of the courses registered to that meeting. This is the same information viewed by State Boards when verifying CE credit certificates.
Can I Submit a CE Event Reporting Form Online?
Administrators may now submit events online by going to Administrators-Submit Events.
Are only Doctors of Optometry allowed to participate in the COPE-approved event?
No. COPE Administrators can allow whomever they wish to participate in the COPE-approved event. COPE does have requirement regarding COPE Instructors, but not participants.
Are COPE Administrators required to track the attendance of all participants?
No. For the purposes of COPE approval and accreditation, COPE Administrators must track the attendance of all licensed Doctors of Optometry. It is not necessary to capture the attendance of non O.D.s for COPE approval.
If a participant must leave the room during a live COPE event must they forfeit their credit?
Not necessarily. COPE Administrators must monitor attendance at all COPE courses and ensure that COPE-approved CE credit is provided only to those licensed Doctors of Optometry actually present during at least 90% of any given course. | 
