How can I determine if my organization is an ineligible company (formerly known as a commercial interest)?
The ACCME defines ineligible companies as "those whose primary business is producing, marketing, selling, re-selling, or distributing healthcare products used by or on patients." See ACCME's Standards for Integrity and Independence in Accredited Continuing Education for more information. The ACCME provides a set of self-assessment questions that can help an organization determine whether it falls under the definition of an ineligible company. These questions are listed below:
Structured Self-Assessment Related to ACCME's Definition of an Ineligible Company
- Does your organization, or a part of your organization, produce, market, sell, re-sell, or distribute healthcare products used by or on patients?
- Does your organization advocate for, or on behalf of, an ineligible company?
- Does your organization develop, or assist in the development of, non-accredited education in collaboration/partnership with ineligible companies?
- Does your organization have a parent company that…
- produces, markets, sells, re-sells, or distributes healthcare products used by or on patients, and/or…
- advocates for, or on behalf of, an ineligible company?
- develops, or assists in the development of, non-accredited education in collaboration/partnership with ineligible companies?
- (A "parent company" is a separate legal entity that owns or fiscally controls an organization.)
- Does your organization have a sister company that…
- produces, markets, sells, re-sells, or distributes healthcare products used by or on patients, and/or…
- advocates for, or on behalf of, ineligible companies?
- develops, or assists in the development of, non-accredited education in collaboration/partnership with ineligible companies?
- (A "sister company" is a separate legal entity which is a subsidiary of the same parent company that owns or fiscally controls an organization).
5a. If Yes to 5, does your organization share management, employees, or governance structure with the sister company? (An example of a corporate structure that meets ACCME’s requirements for independence can be found here.)
5b. If Yes to 5, are any owners, employees, or agents of the sister company involved in the planning, development, or implementation of educational content?
5c. If Yes to 5, does the sister company control or influence, in whole or in part, the operations of your organization?
If your organization answers yes to any of these questions, it would likely be defined by ACCME as an ineligible company. If after answering these questions your organization still has questions regarding its status, you may wish to request that the ACCME conduct a corporate structure review. An organization may contact the ACCME directly at info@accme.org if they wish to request that ACCME perform a corporate structure review. There is a fee ($4,000) for organizations that wish to have a corporate structure review conducted.