Criterion 7: #180518

Finding
Noncompliance

Prior to the planning of a CME activity, the provider obtains disclosure of relevant financial relationships for the members of its CME committee who will be involved in the selection of the topics, content and presenters. If a committee member discloses a financial relationship with a commercial interest whose products are related to the therapeutic areas that may be addressed in the activity, the provider sends an email to each of those planners instructing them to ensure that their recommendations and decisions about the activity are based on the best available evidence and that they keep in mind the need for a balanced approach to the planning of the activity. The planners are asked to confirm their acceptance of this instruction via email, and these emails are retained by the provider.


Rationale: Asking an individual with a relevant financial relationship to attest to meeting the expectations of the ACCME prior to their involvement would not be acceptable for a planner, as there would not be an opportunity for the provider to review or make changes to the planning decisions, if this was the only mechanism implemented to resolve the conflict of interest.