Ensuring Independence

Last Revised:
November 11, 2011

No, in this scenario the commercial interest is giving commercial support and buying promotional and sales opportunities. The commercial interest should buy advertising and...

Last Revised:
November 11, 2011

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 relevant financial relationships of the Committee...

Last Revised:
November 11, 2011

No they are not prohibited. Working and learning through meal time is an efficiency often included in bona fide CME activities.

Last Revised:
November 11, 2011

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 but in conjunction with accredited CME. This option also...

Last Revised:
February 12, 2014

The ACCME expects that written agreements for commercial support will:

  • be between the accredited provider and commercial supporter. (This means that the accredited...
Last Revised:
November 11, 2011

Yes. Commercial support 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. This is money given to the provider to support the...

Last Revised:
November 11, 2011

Yes. The ACCME accepts electronic signatures as evidence that written agreements are signed.

Last Revised:
November 11, 2011

No. Communication or distribution mechanisms that are owned or controlled by a commercial interest cannot be used to transmit or distribute continuing medical education activities to learners (e.g., a cable...

Last Revised:
November 11, 2011

Yes. A provider can implement practices to designate different categories of commercial supporters for different amounts of commercial support.

Last Revised:
November 11, 2011

Twenty years ago, most CME occurred in a lecture hall. Now, learning activities occur in many different environments including electronic media, and ACCME intends that all of these places and spaces of CME activity need to be...

Last Revised:
November 11, 2011

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.

Last Revised:
November 11, 2011

Yes. ACCME considers meals arranged by the Provider in conjunction with an activity to be an appropriate part of the expenses of a meeting and can be paid for out of the commercial support.

Last Revised:
February 16, 2017

Financial relationships are those relationships in which the individual benefits by receiving a salary, royalty, intellectual property rights, consulting fee, honoraria for promotional speakers’ bureau, ownership interest (e.g.,...

Last Revised:
November 11, 2011

No. All commercial support must be stipulated by a written agreement and must flow through the Provider and/or its educational partner. Only the Provider and/or its educational partner can make payments to...

Last Revised:
November 11, 2011

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 to identify and resolve...

Last Revised:
November 11, 2011

There is no CME reason for commercial supporters to review and comment on CME content prior to its delivery to learners. An accredited provider would be out of compliance with SCS 1.1 and...

Last Revised:
November 11, 2011

In SCS 4.5, the ACCME requires that accredited providers to use their own distribution channels for CME activities. To that extent, having a CME enduring material created for the exclusive purpose of use in promotional visits to...

Last Revised:
November 11, 2011

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 the physician learners. Assuming that in this...

Last Revised:
November 11, 2011

No. The Provider is not accountable to the ACCME for the content of advertising and exhibits. The information transferred in an advertisement or exhibit is not part of the Provider's program of continuing medical education...

Last Revised:
November 11, 2011

No. Compliance with SCS 2.1 requires that disclosure is made. Disclosing the same information repeatedly to the...

Last Revised:
November 11, 2011

Using commercial support to pay for modest meals and social events at CME activities has been allowed for years. However, providers must avoid making meals or social events longer or more important or more costly than the...

Last Revised:
May 19, 2015

Yes, with specific limits and expectations. Education on devices is a special-use case in accredited CME. Some equipment contains labeling requirements set by the Food and Drug Administration (FDA)...

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