CME Learning Objectives That Pass Educational Reviewer Standards

The Accreditation Council for Continuing Medical Education (ACCME) accredits more than 1,800 organizations to provide continuing medical education in the United States. Its Standards for Integrity and Independence, updated most recently in 2020, set the requirements that distinguish accredited CME from promotional or non-educational activities. The most commonly misunderstood element of these standards — and the one responsible for the highest rate of application rejection — is the learning objective.

A learning objective in ACCME's framework is not a description of what the activity will cover. It is a statement of what the learner will be able to do differently in their clinical practice as a result of the activity. This distinction is not semantic. It is the difference between an activity designed to transfer information and an activity designed to change professional behavior — and the ACCME's entire accreditation framework is built on the premise that CME's purpose is the latter, not the former.

What a "Practice Gap" Actually Means in ACCME Terminology

ACCME's Standards require that accredited CME activities be designed to address a "professional practice gap" — the difference between what physicians currently do in practice and what they should do based on current evidence and best practices. This concept is operationalized through a three-part framework: the gap, the need, and the activity design.

The gap is an observable difference between current performance and the evidence-based standard. "Physicians in this specialty are initiating treatment for X condition at a rate significantly below the evidence-based recommendation" is a gap statement that is specific, verifiable, and actionable through education. "Physicians need to be more aware of recent advances in X" is not a gap statement — it is a description of an information shortfall that may or may not correspond to a practice behavior that CME can address.

The educational need is the underlying reason for the gap. ACCME identifies three types of needs: knowledge gaps (the physician doesn't know what to do), competence gaps (the physician knows what to do but can't do it consistently), and performance gaps (the physician can do it but doesn't in practice). Each type of gap requires different educational design. A knowledge gap can be addressed through didactic content. A performance gap typically requires strategies like decision support, audit and feedback, or practice change interventions. CME activities that address performance gaps through didactic content alone will not change the behavior they are targeting — and ACCME reviewers assessing whether an activity is designed to produce meaningful outcomes evaluate the alignment between the need type and the educational strategy.

Why Most CME Learning Objectives Are Activity Descriptions

The most common failure in CME learning objective writing is the objective that describes what the activity will do rather than what the learner will be able to do. This failure has a distinctive grammatical signature: the subject of the sentence is the activity, not the learner.

Examples of activity descriptions mistakenly written as learning objectives:

• "This activity will provide an overview of current treatment guidelines for Type 2 diabetes" — this describes the content, not the learner outcome
• "This module will review the pathophysiology of atrial fibrillation" — same failure
• "Participants will be exposed to the latest evidence on X" — "exposed to" is not a behavioral outcome; it is a description of information delivery
• "Attendees will learn about the management of Y condition" — "learn about" does not specify what the learner will be able to do

The correctly written learning objective has the learner as its subject, uses a measurable behavioral verb, and specifies what the learner will be able to do in clinical practice. "After completing this activity, the participant will be able to identify patients with Type 2 diabetes who meet criteria for GLP-1 receptor agonist therapy based on current ADA guidelines and documented comorbidities" is a learner-centered objective. It specifies the action (identify), the context (patients with specific characteristics), and the standard against which performance can be measured (current ADA guidelines).

Bloom's Taxonomy and Measurable Behavioral Verbs

The Bloom's Taxonomy of educational objectives — originally published in 1956 by Benjamin Bloom and collaborators, revised and updated by Anderson and Krathwohl in 2001 — provides a framework for writing learning objectives that target specific cognitive levels and are expressed in observable, measurable behavioral verbs. ACCME's guidance on educational design references the importance of using measurable verbs in learning objectives, and reviewers assessing applications implicitly apply Bloom's levels in evaluating whether objectives are appropriately matched to the educational need.

The six cognitive levels in Bloom's revised taxonomy, with example verbs appropriate for CME learning objectives at each level:

• Remember — list, identify, name, recall. Appropriate for knowledge gap objectives where the target behavior requires retrieval of specific facts (e.g., "list the contraindications to X therapy")
• Understand — explain, describe, summarize, interpret. Appropriate for objectives targeting conceptual understanding (e.g., "explain the mechanism by which X affects Y outcome")
• Apply — implement, use, demonstrate, perform. Appropriate for competence gap objectives where the target behavior is a clinical skill (e.g., "apply the validated scoring tool to stratify patient risk")
• Analyze — differentiate, distinguish, compare. Appropriate for complex decision-making objectives (e.g., "differentiate patients who require immediate intervention from those appropriate for watchful waiting based on specified criteria")
• Evaluate — assess, judge, appraise, select. Appropriate for objectives targeting clinical judgment (e.g., "select the most appropriate treatment strategy for a patient with specified comorbidities based on current evidence")
• Create — design, develop, formulate. Appropriate for objectives targeting the development of individualized care plans or treatment protocols

The verb "understand" is commonly misused in CME learning objectives as if it were a behavioral verb. Understanding is not observable or measurable — a learner cannot demonstrate "understanding" without doing something that demonstrates it. The objective should specify what the learner can do as evidence of understanding.

How ACCME Reviewers Score Independence and Balance

ACCME's Standards for Integrity and Independence require that accredited CME be free from the influence of commercial interests. The Standards define "commercial interest" as any entity producing, marketing, or distributing healthcare goods or services consumed by or used on patients. Medical device manufacturers, pharmaceutical companies, and clinical laboratory companies are commercial interests; non-profit organizations, government agencies, and academic medical centers are not.

Reviewers assessing CME applications for independence and balance apply a specific analytical framework derived from the Standards:

• Is the educational need (the practice gap) defined independently of commercial interests' products or services?
• Are the learning objectives focused on patient outcomes and professional practice, not product selection?
• Is the scientific content based on the best available evidence, not on evidence that selectively supports particular products?
• Are presenters and faculty identified without reference to commercial relationships, and are any commercial relationships disclosed appropriately?
• Is the activity designed to produce outcomes that are clinically meaningful rather than commercially beneficial to a commercial interest?

An application whose learning objectives focus on treatment with specific drug classes or specific devices — rather than on clinical decision-making that encompasses the full range of appropriate options including watchful waiting and non-pharmacologic treatment — signals commercial influence even in the absence of direct commercial funding. ACCME's Non-Accredited Commercial Interest Resolution, published in guidance documents, describes how reviewers identify this pattern and the remediation required to address it.

Disclosure and Conflict-of-Interest Documentation

ACCME Standard 3 requires that all planners, faculty, and authors of accredited CME activities disclose any relevant financial relationships with commercial interests. The disclosure requirement applies to all individuals who can influence the content of the educational activity — not only presenters, but also planning committee members, content reviewers, and activity directors.

The documentation required to satisfy ACCME's disclosure requirements includes: identification of all individuals with the ability to control or influence content, a record of relevant financial relationships collected within 24 months of the activity, documentation of how disclosed relationships were resolved to satisfy the independence requirement, and evidence that learners were informed of the disclosures before the educational content began.

The most common disclosure documentation failure is the incomplete identification of individuals with content influence. Activities that disclose faculty relationships but fail to document planner relationships, or that document relationships only for individuals named in the program but not for individuals who contributed to content design, are activities with gaps that reviewers identify during compliance review.