Ensuring Independence

Last Revised:
November 11, 2011

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 involved...

Last Revised:
November 11, 2011

Yes - but CME providers need to be sure that these people have bona fide teaching roles. In the United States, physician learners are not to be given compensation or reimbursement for attending CME activities (see...

Last Revised:
November 11, 2011

The nature of the relationship means the role they play or service they provide in exchange for some form of compensation (e.g., independent contractor including contracted research, consulting, promotional speaking and...

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. CME providers can receive commercial support from industry.  CME providers cannot receive guidance, either...

Last Revised:
November 11, 2011

Yes. The agreement must describe the terms, conditions and purposes of the commercial support grant and be signed by the commercial supporter and the accredited provider.

Last Revised:
November 11, 2011

Yes. Distributing promotional material such as save the date cards, and not distributing the actual educational activity, would not be restricted by the ACCME's...

Last Revised:
February 12, 2014

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 providers.

Last Revised:
June 25, 2014

No. The Provider or its agents (e.g., staff, managers, educational partners or joint providers) must decide what commercial support will be accepted and how it will be spent or used.

Last Revised:
November 11, 2011

This is a more detailed description of the requirements that must be followed if there is advertising in enduring materials. There can be advertising before and after the CME content of an enduring material but those advertisements...

Last Revised:
November 11, 2011

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...

Last Revised:
November 11, 2011

Commercial support underwrites the provider's expenses for developing and presenting an activity. Commercial support can be used to pay for the expenses of teachers and authors as well others who are working for the provider on the...

Last Revised:
November 11, 2011

Yes. Refusal to disclose 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 to identify and resolve COI is...

Last Revised:
November 11, 2011

Yes. An accredited provider can fulfill the expectations of SCS 3.4 to 3.6 by adopting a previously...

Last Revised:
November 11, 2011

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 and resolution processes.

Last Revised:
November 11, 2011

Discussion of off-label uses are certainly allowed in CME activities. However, providers are no longer required to have a mechanism in place to ensure that off-label or investigational uses are disclosed as such. The ACCME adopted...

Last Revised:
November 11, 2011

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 ACCME worked individually with...

Last Revised:
June 25, 2014

When there is commercial support there must be a written agreement that,

  • Itemizes how the Provider will use the commercial support in the development and presentation of the CME activity;
  • Itemizes the...
Last Revised:
November 11, 2011

It would depend on what the program book, with abstracts, is used for in relation to the CME activity. If the abstracts are referenced during the activity or serve as a component of the content, then there can be no advertising in...

Last Revised:
June 25, 2014

No. The commercial support must go first to the provider or a provider's joint provider or a provider's educational partner.

Last Revised:
November 11, 2011

Yes. It is appropriate for an accounting of how the commercial support has been spent to be included in the written agreement between the Provider and the commercial supporter.

Last Revised:
November 11, 2011

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.

Last Revised:
November 11, 2011

Meals or social events compete with educational events when they happen at the same time in a different location or when they are the main attraction at the educational activity.

Last Revised:
November 11, 2011

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 interests of the...

Last Revised:
November 11, 2011

This allows the learners to distinguish between missing disclosure information and the circumstances where there is nothing to disclose.

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