reporting errors to avoid: CNOM recommendations

October 3, 2024 — published by Pyramidale Communication,
medical communications agency

Collaboration between manufacturers and healthcare professionals: the keys to anticipating, planning, and successfully completing your CNOM declarations!

Are you a product manager or regional scientific manager looking to fully understand the ethical rules governing collaboration with healthcare professionals?

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Declaration errors to avoid: CNOM recommendations

The latest evaluation report on the 2020-2022 “Benefits Framework” system, published by the CNOM, highlights common errors to avoid.

CNOM declaration: common errors to avoid?¹

The French National Medical Council (CNOM) oversees the public service mission related to the “Benefits Framework” system.
The Ministry of Health and Prevention tasked the authorities responsible for implementing the system with producing an evaluation report for the period from October 1, 2020, to December 31, 2022.

After two years of implementation, the CNOM identified several shortcomings and difficulties in processing applications under the various schemes: declaration, authorization, and emergency authorization.

The most frequent errors include:

1. Deadlines

Failure to comply with regulatory submission deadlines

2. Incorrect use of the declaration and authorization schemes

3. Wording of agreements

Using generic terms to describe the services provided by physicians, which often requires CNOM to request additional information.

4. Authorization form for multiple ancillary activities (ACA, Cumul d’Activités Accessoires)

Discrepancy between the information on the form and that in the agreement.

5. Incorrect identification of healthcare professionals

Submission of agreements concerning healthcare professionals outside the CNOM’s scope (e.g., nurses, pharmacists).
Lack of knowledge about the qualifications of invited professionals (e.g., doctors with unrecognized foreign degrees).
Insufficient information provided.

6. Lack of clarity on the scope of services covered

The scope is often not specified, particularly for professional training activities (hospitality costs, training costs, etc.).

7. Re-submission of rejected applications

In its report, the CNOM concludes that the system for regulating benefits appears to be relevant and helps to guarantee the professional independence of doctors.

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