Managing Conflicts of Interest © ACCME

Fair use of this presentation The ACCME is developing materials to help accredited providers raise awareness and educate individuals on ACCME’s Updated Standards for Commercial Support. This presentation is a resource to serve that purpose. Providers may find the presentation useful when providing training to staff, committees, teachers/authors, or other volunteers. The presentation is held as a copyrighted © by the Accreditation Council for Continuing Medical Education. Through this notice, the ACCME grants permission for its use to its accredited providers, recognized state medical societies for educational purposes, and intrastate accredited providers and any other organizations using the presentation for educational purposes. These materials may not be used, in whole or in part, for any commercial purposes, including but not limited to courses or seminars related to compliance with ACCME accreditation criteria, without the prior permission in writing from the copyright owner.

Three fundamental values 1.The CME industry’s interest in the health and well being of the public is more important then any economic interest. 2.Some economic interests of CME providers, or their agents, are substantial enough to be in conflict with this public interest. 3.If a conflict of interest is present it must be managed in a manner that is in the best interest of the public.

 Everyone discloses to Provider  Continue with persons who disclose  Implement a mechanism to identify and resolve conflicts of interest Standard 2: Resolution of Personal COI

Process STANDARD 2:Resolution of Personal Conflicts of interest The provider must have implemented a mechanism to identify and resolve all conflicts of interest prior to the education activity being delivered to learners. Process STANDARD 2:Resolution of Personal Conflicts of interest The provider must have implemented a mechanism to identify and resolve all conflicts of interest prior to the education activity being delivered to learners. The ACCME considers financial relationships to create actual conflicts of interest in CME when individuals have both and A financial relationship with a commercial interest and The opportunity to affect the content of CME about the products or services of that commercial interest.  How do these circumstances create a conflict of interest? The potential for maintaining or increasing the value of the financial relationship with the commercial interest creates an incentive to influence the content of the CME – an incentive to insert commercial bias.

Process STANDARD 2:Resolution of Personal Conflicts of interest The provider must have implemented a mechanism to identify and resolve all conflicts of interest prior to the education activity being delivered to learners. Process STANDARD 2:Resolution of Personal Conflicts of interest The provider must have implemented a mechanism to identify and resolve all conflicts of interest prior to the education activity being delivered to learners. The ACCME considers financial relationships to create actual conflicts of interest in CME when individuals have both and A financial relationship with a commercial interest and The opportunity to affect the content of CME about the products or services of that commercial interest.  Any amount … within the past 12 months … Salary Royalty Intellectual property rights Consulting fee Honoraria Ownership interest (e.g., stocks, stock options or other ownership interest, excluding diversified mutual funds) Other financial benefit …Of person, spouse or partner. 

Roles that may result in financial benefits… Employment Management position Independent contractor (including contracted research), Consulting, Speaking and teaching, Advisory committees or review panels, Board membership, Other activities from which remuneration is received, or expected.

SCS Element 2.3 The provider must have implemented a mechanism to identify and resolve all conflicts of interest prior to the education activity being delivered to learners. SCS Element 2.3 The provider must have implemented a mechanism to identify and resolve all conflicts of interest prior to the education activity being delivered to learners. …one can help fulfill the other SCS Element 2.1 The provider must be able to show that everyone who is in a position to control the content of an education activity has disclosed all relevant financial relationships to the provider. SCS Element 2.1 The provider must be able to show that everyone who is in a position to control the content of an education activity has disclosed all relevant financial relationships to the provider.

Providers’ choice of “mechanism(s)” may involve: Faculty Planners Managers Staff Reviewers Authors

Specific examples Sometimes the mechanism involves specifying, “Who does what?” within an activity Sometimes the mechanism involves content validation

Providers’ choice of “mechanism(s)” may involve: Planners Managers Staff Reviewers

Providers’ choice of “mechanism(s)” may involve: Faculty Staff Reviewers Authors

Providers’ choice of “mechanism(s)” may involve: Faculty Planners

Providers’ choice of “mechanism(s)” must involve: Engagement by the provider in a process that goes beyond simple disclosure, with necessary interventions to resolve conflict of interest implemented before the activity.

Faculty Planners Managers Staff Reviewers Authors

When thinking about your organization’s mechanism(s), ask yourself: What are we ALREADY DOING to plan and implement our CME activities to ensure there is no commercial bias?