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, requiring a Progress Report. The majority of these providers that are out of compliance are out of compliance with the elements of the Standards for Commercial SupportSM (SCS). And 90% of the people who are out of compliance with these elements of the SCS are out of compliance with identifying and resolving conflicts of interest, and disclosure of relevant financial relationships. And they are out of compliance because they haven’t considered the planners of their continuing medical education activities to be important to Standard 2 and Standard 6 of the SCS.
The people who are in control of content are the people whose financial relationships you need to identify. And, yes, the teachers and authors are the most prominent (and probably the most important), but also those people who you bring together to say: What subjects should we be talking about? What speakers should we be getting? What elements of this area of care or research should we be pursuing in our continuing medical education activity? — have control of content. They have control of your message. They have control of your curriculum and the curriculum of continuing medical education. And their relationships are relevant to conflict of interest in continuing medical education at that level.
So, we ask that as you are planning your continuing medical education, as you are beginning the process, you seek from the people who have control of content, including the planners, and maybe some of your staff, if they’re taking a role, a strategic role, in deciding what you should be teaching. You get from them the list of financial relationships with commercial interests that are relevant to the content that they have control of. Now, you can get a list of all of their relationships and you can look at that list and you can look at the content that they’re being asked to control and you can decide whether they’re relevant.
You can also say to those people: The financial relationships that we are interested in are the financial relationships that have to do with the content that you have the opportunity to control. Please give us that information. They give you a list. You have a comprehensive list. You look at them. You ensure that they are relevant. You then decide what you’re going to do to resolve the conflict of interest when one exists. Then, downstream, you communicate that information to the learners prior to the educational activity. But, it’s critically important for 90% of the providers, that are found noncompliant in the accreditation process under the updated Criteria, it’s critically important that you include the planners and the people that you get disclosure information from prior to starting your educational activity.
