Compliance Reminder: Identifying and Resolving Conflicts of Interest for CME Planners
Over the course of several review cycles, the ACCME has observed that some providers are not applying appropriate mechanisms to identify and resolve conflicts of interest for individuals who are engaged in planning CME activities (for example, CME committee members, course directors).
In the ACCME Standards for Commercial Support: Standards to Ensure Independence in CME Activities℠, Standard 2.3 says that “the provider must have implemented a mechanism to identify and resolve all conflicts of interest prior to the education activity being delivered to learners.” This standard applies to all those in control of content — including those who plan the activity. We set that expectation because planners have the opportunity to influence the selection of topics and faculty, and therefore it is critical to make sure that any conflicts of interest they may have are identified and resolved. It is important to initiate this process as you begin planning the activity, to ensure that decisions made during the planning process are independent of commercial influence.
The ACCME expects that accredited providers:
- obtain information from planners about relevant financial relationships;
- resolve any conflicts of interest of those planners;
- disclose the relevant relationships of planners to learners (or inform the learners if the planners have no relevant relationships); and
- be able to show that conflicts of interest were identified and resolved, and disclosure was made to learners for planners.
There are a few key points for accredited providers about obtaining information about relevant financial relationships:
- Information about relevant financial relationships should be sought from all those in control of content, including course directors, committee members, and other planners – as well as faculty, authors, and teachers.
- The information from planners should include relationships from the previous 12 months.
- Accredited providers should ensure that planners are presented with the correct definitions of commercial interest and relevant financial relationships before they are asked to disclose so that they can provide appropriate information back to the provider.
- Providers are not required to use forms to obtain information about relevant financial relationships; however, they must be able to provide the form, tool, or mechanism used to identify relevant financial relationships of the planners, and the information obtained for each individual.
- Employees of ACCME-defined commercial interests cannot have roles as planners in accredited CME, except in very specific circumstances outlined here.
Here are several examples of actions that would meet ACCME’s expectations. Please keep in mind that these are only suggested mechanisms. Each provider should implement mechanisms that work best for its program.
- The planner is recused from planning content related to his/her financial relationship(s).
- The decisions of a planner with a conflict of interest are subject to review by a reviewer who has no conflict of interest and who has sufficient expertise to plan the activity. Accredited providers should be sensitive about relationships that may exist between a reviewer and a planner that could impede an objective review.
- The planner divests him/herself of the relationship.
In addition to obtaining information about relevant financial relationships and resolving these conflicts of interest, providers must ensure that the relationships of planners are disclosed to learners, even if these relationships have been resolved.
- Do I need to use different approaches to resolve conflicts of interest for planners than I use for other persons in control of content, such as authors, speakers and reviewers?
- Flowchart for the Identification and Resolution of Personal Conflicts of Interest
- Using ACCME’s Flowchart for Identifying and Resolving Personal Conflicts of Interest
- Examples of Compliance and Noncompliance