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Resolution of Personal Conflicts of Interest

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...
How do these circumstances create a conflict of interest?
The potential for increasing the value of the financial relationship with the commercial interest creates an incentive to influence the content of the CME - an incentive to insert commercial...
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.
Can a provider leave it up to an individual who controls content to determine if his/her relevant financial relationship creates a conflict of interest that needs to be resolved?
No. The provider cannot delegate the responsibility for resolving the conflict of interest to the person with the conflict of interest. However, an individual who controls CME content can be...
Can a provider choose to implement a mechanism to resolve conflicts of interest only for relationships they deem to have created "substantial" conflicts of interest?
No. If there is any relevant financial relationship, there is a conflict of interest. A mechanism to resolve conflicts of interest must be implemented in all such cases.
What do we do when we appoint a person to speak at the last minute and we have not had time to analyze disclosure information, never mind try to resolve any conflicts of interest?
The ACCME expects that this is a rare event and expects that providers would have plans to manage this contingency as part of their institutional mechanisms for resolving conflicts of...
Does ACCME have any other examples of mechanisms for resolving conflict of interests that go beyond the five examples in "Identifying and Resolving Conflicts of Interest in Continuing Medical Education?"
Yes. Please keep in mind that these are only suggested mechanisms. Each provider will want to design and adopt a mechanism that works best for its structure and type of...
How does a provider implement a mechanism for resolving conflicts of interest?
What follows is an example of how several tactics can be tied together by the Provider into a mechanism to resolve conflicts of interest that could demonstrate the Provider's compliance...
If disclosure information cannot be analyzed in a timely fashion, is it appropriate for the activity or presentation to go on without formal CME credit?
ACCME has never recommended withholding CME credit at the last minute as an alternative to producing CME that is in compliance with accreditation requirements. It does not seem fair to...
Can faculty take an active role in the provider's mechanism(s) to resolve conflicts of interest?
Yes . Resolving conflicts of interest means individuals taking explicit actions prior to the educational activity to create CME content that is valid and free of commercial bias -- even...
Is "peer review" - e.g. reading the content of each presentation, looking for commercial bias and content that is not supported by evidence - an acceptable mechanism to resolve conflicts of interest?
No . "We read the content of each presentation, looking for commercial bias and content that is not supported by evidence" is a mechanism to identify commercial bias and invalid...
If we have taken appropriate steps to resolve conflicts of interest what is there left to disclose?
Informed learners are the final safeguards in assuring that a CME activity is independent from commercial influence. Regarding personal conflicts of interest, CME providers are to have in place mechanisms...
What do I need to understand about conflicts of interest (COI?)
An important step in establishing the validity or the credibility of accredited continuing medical education is to ensure that all persons with conflicts of interest know they have a conflict...
Who needs to disclose relevant financial relationships to me and to the learners who participate in my activities?
After evaluating over 300 accredited providers, using the 2006 Accreditation Criteria, we find that about 50% of providers are out of compliance with one of the Criteria one through fifteen,...