UCSF School of Medicine OCME Program Frequently Asked Questions Faculty Disclosure and Resolution of Conflict of Interest

What are The ACCME Updated Standards for Commercial Support? In September 2004, the ACCME adopted the updated Standards for Commercial Support to strengthen the mechanisms to prevent the potential for commercial bias in CME Activities. The new standards promote the development of effective strategies to ensure full disclosure of faculty relationships with commercial entities and the subsequent resolution of potential conflicts of interest, and the provision of evidence based information to learners.

What is the ACCME’s definition of a Commercial Interest? The ACCME defines a “Commercial Interest” as any proprietary entity producing health care goods or services, with the exception of non-profit or government organizations.

What is a Relevant Financial Relationship? Relevant financial relationships are those relationships in which the individual benefits by receiving salary, royalty, intellectual property rights, consulting fees, honoraria, ownership interest or other financial benefit from a commercial support entity within the past 12 months. ACCME considers relationships of the person involved in a CME activity to include financial relationships of a spouse or partner.

What Types of Financial Relationships Constitute a Conflict of Interest? Circumstances create a conflict of interest when an individual has an opportunity to affect CME content about the products or services of a commercial interest with which he/she has a financial relationship.

How Can Conflict of Interest Be Managed? In order to manage conflict of interest, we must know about relevant financial relationships prior to the activity being developed and delivered to the learners.

Who Has to Disclose? All individuals who are engaged in the planning of a CME activity must complete a faculty disclosure form prior to the rendering of an educational activity. This includes activity directors, program chairs, planning committee members, faculty speakers, authors, moderators and editors.

When is Disclosure Provided? Individuals involved in the planning of a CME activity are required to complete the OCME Faculty disclosure form 6-12 months prior to the activity. Individuals involved in the presentation or teaching of an educational activity are required to complete the OCME faculty disclosure form 4-6 weeks prior to the activity.

Can I Refuse To Disclose? An individual who does not disclose or who refuses to disclose is disqualified from participating in a UCSF CME activity.

How Do We Resolve a Conflict of Interest? All faculty involved with the planning or teaching of a CME activity who disclose a conflict of interest must resolve that conflict prior to the CME activity. Mechanisms for resolution include the following:

Resolution Methods Support the presentation with “Best Available Evidence” Refrain from providing clinical recommendations regarding products or services of a commercial entity Recommend an alternate speaker Submit presentation for peer review Divest oneself of the financial interest

What Happens After a Conflict of Interest Has Been Identified and Resolved? Resolution of the conflict of interest must also be made known to the learners in advance of the educational activity. This can be accomplished via podium announcement, promotional materials, syllabus, first slide or moderator attestation.

Will I Receive Feed-Back on Perceived Bias in My Course or Lecture? All CME activities are systematically surveyed for audience perception of commercial bias as part of the post activity evaluation. The results of the evaluation will be discussed with the activity chair, planning committee members and Governing Board for future planning efforts.

ADDITIONAL RESOURCES ACCME Updated Standards for Commercial Support http://www.accme.org/ UCSF Office of Continuing Medical Education http://www.cme.ucsf.edu

Additional Questions Robert B. Baron, MD, MS Associate Dean for CME Office of Continuing Medical Education (415) 476-4251 Kolette Dye, Manager Accreditation and Educational Development Office of Continuing Medical Education (415) 476-6124