SCS 2.1 requires that the accredited provider “must be able to show that everyone who is in a position to control the content of an education activity has disclosed all relevant financial relationships with any commercial interest to the provider.” If someone in connection to the activity has the opportunity to affect the content, they are “in control of content.” Those individuals in a position to control the content of an educational activity might include (but are not limited to) planners, faculty, authors, committee members, content reviewers, editors, and staff depending on the accredited provider’s processes for developing educational activities. A common area of noncompliance with SCS 2 is that providers only collect information about relevant financial relationships from faculty or authors but do not collect that information from others, such as committee members, who may be in control of content.
Please note that SCS 6 requires that the relevant financial relationships of those in control of content be disclosed by the provider to learners prior to the educational activity. If providers do not gather information from all persons in control of content, as required by SCS 2, they will not be able to disclose the appropriate information to their learners for compliance with SCS 6. For more information, see Standard 6.