Criterion 07: #55975

Finding: 
Compliance
Published Date: 
September 17, 2013

The provider ensures that everyone in a position to control content discloses relevant financial relationships prior to the activity, utilizing a mixture of online- and paper-based processes. These disclosures can be tracked by staff through the provider’s intranet. The resolution of conflicts of interest is also coordinated and monitored through an online process with three levels of review: staff pre-selection/screening, content leader review, and chair’s final review. This multi-stage process allows for initial screening by staff, leading to a risk appraisal ranging from "No Action Needed" (e.g., no relevant financial relationships) to "Content Review: Highest risk of bias." Content leaders have access to these ratings and provide verification that the strategies selected for each individual are appropriate. Chairs complete final review. Once conflict of interest resolution strategies have been approved, CME staff implement them. The following strategies are utilized: 1) Letter - a letter pointing out the conflict of interest is sent to the individual with a reminder that the individual has signed an agreement to abide by the organization’s policies and instructions related to developing content to utilize evidence-based recommendations. 2) Slide review - an initial review by CME staff with a summary to the content leader or Chair. If changes are warranted the presenter is asked to resubmit their presentation. 3) In addition, the provider may require an Audit, in which case the entire session becomes slated for audit. Audits can result in feedback to the author/presenter, based upon the results of the audit. (SCS 2)

 

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