Resolution of Personal Conflicts of Interest

The ACCME received a complaint about a live CME activity. One faculty member was listed as having nothing to disclose; however, the complainant claimed that the person did indeed have relevant financial relationships with a commercial interest, as defined by the ACCME. Therefore, the ACCME sent a letter of inquiry to the accredited provider asking about its compliance with Criterion 7 (Standards for Commercial Support℠ 1, 2, and 6). The ACCME asked the provider to describe its planning process and indicate how each step was, in fact, independent, to describe how conflicts of interest were identified and resolved, and to document that the presence or absence of relevant financial relationships was made known to the learners.

The provider did not present evidence to demonstrate the implementation of a mechanism to identify conflicts of interest or to resolve conflicts of interest when relevant financial relationships were identified. For example, one of the speakers had relevant financial relationships with an ACCME-defined commercial interest. The relevant financial relationship was made known to the accredited provider, but it was not clear whether it was disclosed to learners. It was also revealed that individuals with relevant financial relationships were responsible for resolving their own conflicts of interest.

This was insufficient to demonstrate compliance with Standard 2: Resolution of Personal Conflicts of Interest, so the ACCME issued a Notice of Noncompliance and asked the provider to submit a Notice of Corrective Action, including evidence from a recently completed activity demonstrating compliance with Standard 2.

The provider’s Notice of Corrective Action documented changes to its policies and procedures. The provider continues to require that all individuals disclose to the provider and learners, including those with no relevant financial relationships. In addition, activity content is reviewed by content reviewers who have no relevant financial relationships. If necessary, the provider makes changes to activity content as a result of these reviews.

The ACCME accepted the provider’s Notice of Corrective Action. The ACCME will review the information pertaining to the complaint during the provider’s next reaccreditation review to ensure that the provider has continued to comply with Standard 2.

For More Information
ACCME Standards for Commercial Support
Ask ACCME Standards for Commercial Support 1: Independence
Ask ACCME Standards for Commercial Support 2: Resolution of Personal Conflicts of Interest
Ask ACCME Standards for Commercial Support 6: Disclosures Relevant to Potential Commercial Bias
Video FAQ: Avoiding Noncompliance with the Standards for Commercial Support: What Do I Need to Understand about Conflicts of Interest?

Published Date: 
Wednesday, October 26, 2011
Last Revised: 
Wednesday, October 26, 2011
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