Content Validity
What does Conduent mean when it says that CPE content is "valid"?
Why it matters: The reviewers need to know whether “valid” has a consistent operational meaning rather than being used as a general quality statement.
Recommended response: For our program, valid content is content that is accurate, current, fair, balanced, evidence-based, appropriate for pharmacists and pharmacy technicians, and free from unsupported or promotional claims. Qualified SMEs validate the scientific or regulatory substance, while the Instructional Designer and CE Committee verify instructional alignment, documentation, disclosures, and the absence of marketing content before release.
Evidence expected:
Policy CE-001.
Content Validity Tool.
Standard Intake Questionnaire.
SME qualification records.
Bibliographies and supporting references.
SME content review and sign-off forms.
Final quality review or prelaunch checklist.
Approved course materials.
Suggested owner: CE Program Manager or qualified SME.
What is Conduent’s basic rule concerning marketing in accredited CPE activities?
Why it matters:
The team should be able to communicate the rule clearly and consistently without relying on lengthy policy language.
Recommended response:
Accredited CPE must be developed and delivered as education, not as a marketing or sales channel. Advertising, product promotion, sales messaging, company endorsements, and promotional branding are not permitted within accredited educational content, assessments, handouts, or the active learning environment. Educational decisions remain under the control of the accredited provider.
Evidence expected:
Suggested owner: CE Program Manager.
Who is required to complete a financial-relationship disclosure?
Why it matters:
The disclosure process must cover everyone who can control educational content, not just the principal author or presenting SME.
Recommended response:
All individuals who control educational content are required to disclose applicable financial relationships. This includes planners, faculty, SMEs, authors, reviewers, and relevant Conduent team members involved in educational decisions. The activity cannot proceed until the complete population of content controllers has been identified and the required forms have been collected.
Evidence expected:
Suggested owner: CE Program Manager.
Did Conduent receive commercial support for any accredited CPE activity during the review period?
Why it matters:
This establishes whether reviewers should inspect actual supported activities or evaluate only the organization’s readiness to manage future support.
Recommended response:
No. Conduent did not receive commercial support for accredited CPE activities during the review period. Our policy and process remain in place so that any future financial or in-kind commercial support is identified, evaluated, controlled, disclosed, and documented before the activity is released.
Evidence expected:
Suggested owner: CE Director or Finance representative.
What is an ancillary activity in the context of Conduent’s CPE program?
Why it matters:
Staff must be able to recognize ancillary activity before they can apply separation controls.
Recommended response:
An ancillary activity is a nonaccredited, informational, commercial, promotional, or exhibit-related activity offered alongside or in connection with accredited CPE. Examples may include advertising, virtual exhibits, sponsor information, promotional links, or other content that is not part of the accredited educational activity.
Evidence expected:
Suggested owner: CE Program Manager.
How is a subject matter expert selected and determined to be qualified to validate a particular activity?
Why it matters:
A reviewer will not assume that an individual is qualified merely because the individual is called an SME. The expertise must relate directly to the activity topic and intended audience.
Recommended response:
During intake, we define the topic, learning objectives, intended audience, and applicable regulatory or practice requirements. We then collect and review the proposed SME’s credentials, degrees, professional title, relevant experience, and prior content-development experience. The SME’s expertise must align with the subject matter being reviewed. The qualification and assignment decision is documented before the SME begins controlling educational content.
Evidence expected:
Suggested owner: CE Program Manager.
Who controls decisions about activity planning, SME selection, content, delivery, and evaluation?
Why it matters:
This directly addresses the concern previously raised about influence from owners or employees of ineligible companies.
Recommended response:
Conduent’s CE leadership and CE Committee retain control of accredited educational decisions. The CE Program Manager, Instructional Designers, qualified SMEs, and designated reviewers perform their defined roles. Ineligible companies, their owners, and their employees do not control planning, SME selection, content development, delivery, assessment, or evaluation outcomes. If an outside party proposes content or resources, those materials remain subject to independent review and provider approval.
Evidence expected:
Suggested owner: CE Director or CE Program Manager.
What information is collected on the financial-disclosure form?
Why it matters:
This allows the reviewer to determine whether the updated mechanism responds to the prior document request.
Recommended response:
The form captures the contributor’s identity and role, financial relationships with ineligible companies during the previous 24 months, the name of the company, and the nature of each relationship. It also allows the contributor to state that no relationships exist and includes a signed and dated attestation that the information is accurate. Refusal to disclose disqualifies the individual from controlling educational content.
Evidence expected:
Suggested owner: CE Program Manager or Accreditation Coordinator.
How would Conduent identify potential commercial support during activity intake?
Why it matters:
A support arrangement cannot be controlled if it is not identified early.
Recommended response:
The intake process asks whether an external entity is providing money, services, resources, technology, or other in-kind assistance for the activity. Any positive response is flagged for CE leadership review before planning proceeds. The supporter, type and amount or value of support, restrictions, and proposed use are documented in the activity record.
Evidence expected:
Suggested owner: CE Program Manager.
How does Conduent separate accredited education from promotional or nonaccredited content?
Why it matters:
Learners must be able to distinguish education from marketing without ambiguity.
Recommended response:
The separation is physical or digital, temporal, and functional. Promotional material is not embedded in modules, assessments, educational handouts, or active course navigation. If nonaccredited content exists, it is clearly labeled and accessed separately from the accredited experience. Learners do not have to view or interact with promotional content to enter, complete, or receive credit for the CPE activity.
Evidence expected:
Suggested owner: Instructional Designer or LMS Administrator.
What happens if the prerelease review identifies an unsupported claim, outdated information, promotional language, or an inappropriate company reference?
Why it matters:
The reviewer is testing whether the review has enforcement authority and whether deficiencies must be resolved before launch.
Recommended response:
The item is documented and the activity is paused from approval or release. The Instructional Designer and SME determine whether the issue requires a corrected reference, revised wording, removal of content, additional independent review, or escalation to the CE Committee. The revised material is reviewed again, and the activity is not approved until the concern has been resolved and the final decision has been documented.
Evidence expected:
Suggested owner: Instructional Designer, supported by the SME.
How does Conduent prevent learner names and contact information from being shared with ineligible companies?
Why it matters:
Learner-data protection was one of the three specific elements identified in the prior ACPE feedback.
Recommended response:
Learner information is managed within approved Conduent learning and reporting systems and is accessible only to authorized parties for legitimate educational, administrative, or compliance purposes. Conduent does not provide learner names or contact information to ineligible companies or their agents for marketing purposes. Any permitted disclosure would require a documented legal basis, applicable privacy review, and learner consent when required.
Evidence expected:
Suggested owner: CE Program Manager, supported by Privacy or Data Governance.
How does Conduent determine whether a disclosed financial relationship is relevant to the activity?
Why it matters:
A relationship is not automatically relevant merely because it exists. The decision must be tied to the person’s role and the educational content they control.
Recommended response:
The designated reviewer considers the nature of the relationship, the ineligible company involved, the activity topic, and the contributor’s ability to influence content concerning that company’s products or business lines. The CE Director or Program Manager documents whether the relationship is relevant and whether mitigation is required. The basis for the decision is entered in the Conflict Review Log or equivalent record.
Evidence expected:
Suggested owner: CE Director or Program Manager.
If commercial support were offered, who would control its acceptance and use?
Why it matters:
The accredited provider must retain independent authority over educational and financial decisions.
Recommended response:
The CE Director or designated authorized leader would decide whether the support could be accepted and how it could be used, in accordance with policy. The supporter would not select SMEs, direct content, influence delivery, determine assessment or evaluation methods, or control educational outcomes. Any agreement would document these limits before funds or in-kind support were accepted.
Evidence expected:
Suggested owner: CE Director.
How are external links, banners, pop-ups, logos, and product images assessed before course release?
Why it matters:
Digital promotional material can enter the learning environment through platform configuration as well as through course content.
Recommended response:
The content package and learner-facing LMS environment are reviewed before activation. The reviewer checks modules, handouts, assessments, navigation elements, catalog pages, links, graphics, and evaluation forms. Inappropriate marketing content is removed or moved outside the accredited environment. The decision and final verification are documented in the activity’s compliance checklist.
Evidence expected:
Suggested owner: Quality Reviewer or Instructional Designer, with LMS support.
How does Conduent demonstrate that content-validity controls are applied consistently to all activities rather than only to the examples selected for the review?
Why it matters:
One complete course file shows that a process can work. It does not establish that the process operates consistently across the entire portfolio.
Recommended response:
We use a standardized activity-file structure and required documentation checklist for every accredited activity. Each file should contain the applicable intake record, contributor qualifications, disclosures, content-validity review, references, SME sign-off, quality review, approval, and version information. The CE Committee or Program Manager monitors completion across the accredited portfolio and follows up on missing or incomplete records before release or republication.
Evidence expected:
Suggested owner: Accreditation Coordinator or CE Program Manager.
How does Conduent detect possible commercial bias before, during, and after an activity?
Why it matters:
The CESAR refers to monitoring at different stages. Reviewers may ask the team to define exactly what occurs at each stage and who performs it.
Recommended response:
Before release, disclosures, references, course materials, branding, product terminology, and claims are reviewed. During delivery, the controlled LMS package and learner-facing environment are checked for inappropriate advertising, links, logos, or promotional elements. After delivery, learner evaluations and narrative comments are reviewed quarterly for perceptions of bias. Potential red flags are investigated, documented, escalated when necessary, and followed through corrective action and subsequent monitoring.
Evidence expected:
Suggested owner: Instructional Designer for prerelease controls and CE Program Manager for monitoring and escalation.
What mitigation options are available, and how does Conduent verify that mitigation was completed before the individual controlled content?
Why it matters:
The timing of mitigation is critical. A review after uncontrolled content creation may not provide adequate protection.
Recommended response:
Depending on the risk, mitigation may include changing the individual’s role, using an independent nonconflicted reviewer, revising or removing content, limiting the scope of participation, transferring planning authority, or excluding the individual. The selected measure is documented, assigned, and completed before the individual is permitted to control the relevant content. Completion is verified through dated review records and final approval.
Evidence expected:
Suggested owner: CE Director or Program Manager.
How would learners be informed of commercial support without turning the disclosure into advertising?
Why it matters:
Disclosure is required for transparency, but it must not introduce promotional branding into accredited education.
Recommended response:
A standardized factual statement would identify the source and nature of the support before the learner begins the activity. The disclosure would not include a promotional message, product claim, slogan, trade dress, or supporter logo. The course file would retain both the approved language and evidence showing where and when learners saw it.
Evidence expected:
Suggested owner: Instructional Designer, approved by the CE Program Manager.
How does Conduent maintain required separation when a business partner or client controls part of the learner-facing environment?
Why it matters:
The CESAR refers to monitoring delivery and making recommendations to business partners. A reviewer may ask whether recommendations are enforceable and how compliance is confirmed on client-hosted environments.
Recommended response:
Accreditation requirements are communicated to the partner through documented specifications or contractual requirements. Before launch, Conduent reviews or tests the learner journey to confirm that accredited content is not surrounded by inappropriate marketing and that learners are not required to pass through promotional material. If the environment does not meet requirements, the activity is not approved for accredited delivery until the issue is corrected or an alternative compliant configuration is established.
Evidence expected:
Suggested owner: CE Program Manager, supported by the Service Delivery Manager and LMS Administrator.
How can Conduent prove that its content-validity process is effective, not merely that the required forms were completed?
Why it matters:
Completed forms demonstrate process execution, but ACPE reviewers may ask whether the control actually detects and corrects content risks.
Recommended response:
We demonstrate effectiveness by tracing findings from review or learner feedback through investigation, corrective action, approval, implementation, and follow-up. Examples may include removal of outdated content, clarification of regulatory information, correction of unsupported claims, or revision of language that could be perceived as promotional. We then verify implementation in the released activity and monitor subsequent evaluations. The strongest demonstration is a closed-loop example showing the original concern, the decision, the revised content, approval, release, and follow-up results.
Evidence expected:
Suggested owner: CE Program Manager, with the SME and Instructional Designer.
Learner responses to the bias-screening statement declined from 3.3% to 2.4% and then 2.2%. How did Conduent determine that this reflected a wording issue rather than actual commercial bias?
Why it matters:
The CESAR reaches a causal conclusion, but a reviewer may challenge whether that conclusion is supported by a documented investigation. The direction and denominator of those percentages may also be questioned because the statement uses agree/disagree responses.
Recommended response:
We would first clarify what each percentage represents, including the response category, denominator, reporting period, activities included, and whether lower values indicate fewer negative responses or declining agreement. We would then explain the investigation: review of comments, course-level results, content screens, logos, trade names, links, disclosure language, and any concentration by activity or audience. Only after those checks should we conclude whether the issue was semantic rather than evidence of bias. The wording change, rationale, approval, implementation date, and subsequent results should be documented.
Evidence expected:
Suggested owner: Accreditation Coordinator or CE Program Manager, supported by the Data Analyst.
Walk us through one activity from identification of all content controllers to learner disclosure, including how Conduent established that no undisclosed or unmitigated relationship remained.
Why it matters:
This tests the entire control chain, including population completeness, form collection, relevance review, mitigation, verification, learner disclosure, and record retention.
Recommended response:
We would begin with the activity’s contributor roster and show how each content controller was identified. We would then present each dated disclosure, the completeness check, the relevance determination, and any mitigation decision. If mitigation was required, we would show the completed action and independent verification. Finally, we would show the disclosure learners received before engaging with the activity and the archived activity file. Where no relationships existed, we would show the signed attestations and the documented determination rather than simply stating that no conflicts were found.
Evidence expected:
Suggested owner: CE Program Manager, with the Accreditation Coordinator.
Preparation warning:
The owner terminology should be harmonized. The CESAR refers to the CE Director or Program Manager, while the process report refers in places to the Service Delivery Manager. Reviewers may ask who has final decision authority.
Because no commercial support was received, how can Conduent demonstrate that its process would operate effectively if support were proposed tomorrow?
Why it matters:
A written policy may not establish operational readiness. Reviewers may test whether roles, forms, agreements, financial controls, and disclosure procedures are actually deployable.
Recommended response:
We can demonstrate readiness through a complete prospective workflow. This includes intake screening, eligibility review, decision authority, a written agreement template, separate financial tracking, restrictions on supporter influence, learner-disclosure language, prelaunch verification, and final reconciliation. We should be able to show who performs each step and where the evidence would be retained. We should also distinguish clearly between support for an accredited activity and ordinary client payments or contractual course-development arrangements.
Evidence expected:
Suggested owner: CE Director, supported by Finance and the Accreditation Coordinator.
How does Conduent demonstrate that ancillary-activity controls remain effective after launch and across different platforms, partners, and activity versions?
Why it matters:
A compliant prelaunch review does not eliminate the risk of later platform changes, new banners, altered links, republished packages, or partner configuration changes.
Recommended response:
We use change control and periodic monitoring to confirm that the approved learner environment remains intact. New course versions, package replacements, platform changes, link changes, or client configuration changes trigger reassessment. Learner reports of promotional content are treated as red flags and investigated. Findings, corrective actions, and revalidation are documented, and material concerns are escalated to CE leadership before continued accredited delivery.
Evidence expected:
Suggested owner: CE Program Manager, supported by Quality Assurance and LMS Administration.