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Ensuring Independence

How does ACCME define Commercial Support?
Commercial Support for a CME activity is financial, or in-kind, contributions given by a commercial interest, which is used to pay all or part of the costs of a CME activity....
How do we report in-kind support?
In March 2011, the ACCME modified the requirement for reporting in-kind commercial support, in response to feedback from accredited providers. Below is a description of how to report in-kind commercial...
Does an accredited provider have to report commercial support that is paid directly to a joint sponsor for an activity?
Yes, the accredited provider must report the full amount of commercial support received, even if the commercial support is distributed to other non-accredited joint sponsors.
If a live activity is turned into an enduring material, do faculty disclosure and acknowledgement of commercial support still need to be made?.
Yes. The new CME activity, must demonstrate compliance with all applicable ACCME accreditation requirements, including faculty disclosure and acknowledgement of any commercial support (SCS 6). For CME activities including those in...
What is a commercial interest?
See the ACCME's definition of a commercial interest.
Why will the ACCME not allow commercial interests to act as joint sponsors?
Joint sponsors are expected to routinely have a role in making decisions about the elements of the planning process specified in SCS 1.1. Since these decisions must be "made free...
How did the change in the definition of a commercial interest announced in August 2007 affect already accredited providers that might be owned by a commercial interest?
As of August 2007 the ACCME defined a commercial interest as "any entity producing, marketing, re-selling, or distributing health care goods or services consumed by, or used on, patients." The...
What is an example of a corporate structure that meets the ACCME's requirements for independence?
The ACCME offered several alternatives for corporate restructuring that met its requirements. For example, the ACCME determined that an accredited CME provider can have a sister corporation that is a...
Can an accredited provider ask a commercial interest for suggestions related to topics or or speakers for CME?
No. There is no reason for the CME provider to request suggestions for speakers or topics from commercial interests -- since it is unacceptable to act upon their suggestions. The...
What is the provider to do if a commercial supporter of an activity says the content of the activity is not accurate -- or unreasonably favors their product?
There is no CME reason for commercial supporters to review and comment on CME content prior to its delivery to learners. The ACCME believes that CME can receive commercial support...
Can employees of commercial interests serve as planners or speakers in our accredited CME activities?
If the content of CME that the employee of the commercial interest controls relates to the business lines and products of its employer - NO. If the content of CME that...
What kind of topics do not relate to the business lines or products of the employer?
The ACCME has worked closely with accredited providers as they have adapted their CME programs to comply with the ACCME policy regarding the role of commercial interest employees in accredited...
Can a provider allow oral or written reporting of scientific research by an employee of a commercial interest during a CME activity?
Yes, as long as the CME activity complies with the ACCME's Accreditation Criteria, including the ACCME® Standards for Commercial SupportSM. It is understood and accepted that industry conducts its own...
Can providers exclude presentations from the accredited CME program rather than getting involved in maintaining control of content or ensuring factors are in place to prevent conflict of interest?
YES. The provider always has the option to exclude some presentations or abstracts from their accredited program of CME or present this content in a track that is outside of...
Can a provider offer education on medical devices and still be in compliance with the ACCME Accreditation Criteria?
Further explanation: One of our CME courses is an intensive hands-on course that trains physicians to perform vascular interventions in a laboratory setting. The training is primarily about newer medical devices...
Can individuals disclose relevant financial information to a provider verbally?
Yes. Verbal disclosure to the provider is acceptable as long as the provider can verify for the ACCME at accreditation what information was collected for the conflict of interest identification...
Is it necessary to collect disclosure information on relevant financial relationships from a speaker each and every time the speaker participates in a CME activity?
No. It is not necessary to collect disclosure information on relevant financial relationships from a speaker, planner, or author each and every time that individual has control over the content...
What financial relationships need to be disclosed to the accredited provider?
Financial relationships are those relationships in which the individual benefits by receiving , royalty, intellectual property rights, consulting fee, honoraria, ownership interest (e.g., stocks, stock options or other ownership interest,...
When do relationships create "conflicts of interest?"
The ACCME considers financial relationships to create actual conflicts of interest in CME when individuals have both a financial relationship with a commercial interest and the opportunity to affect the...
Where is the "conflict?"
In accredited CME, when an individual's interests are aligned with those of a commercial interest, the interests of the provider are in "conflict" with the interests of the public. The...
If all planning committee members disclose any relevant financial relationships at an initial planning meeting and that information is reflected in the minutes of the meeting, is that enough documentation that disclosure was sought?
Yes. That documentation would verify that the first step of a mechanism for identifying conflicts of interest is in place. That would document for ACCME that the Provider knew the...
Do we need committee members to sign a disclosure statement at every meeting while planning the same activity?
No. Compliance with SCS 2.1 requires that disclosure is made. Disclosing the same information repeatedly to the same Provider is not necessary. With the original disclosure information, the Provider is...
Is failure to return or provide disclosure information on relevant financial relationships the same as a refusal to disclose?
Yes. Refusal to disclosure is not limited to the explicit act of saying "no" to a provider's request for such information. Unresponsiveness that precludes the provider from implementing a mechanism...
Is it acceptable to provide some latitude in disqualifying individuals who "refuse" to disclose by giving everyone one chance to refuse to disclose before actually disqualifying them?
No. The ACCME expects providers to disqualify all individuals each time they refuse to provide information on their relevant financial relationships.
What do we do when we appoint a person to speak at the last minute and when the person arrives at the activity they refuse to disclose relationship information?
You must not carry on with the activity under these circumstances. The person cannot participate if they refuse to disclose because conflicts of interest can neither be identified nor resolved.

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