Options for Disclosure

Process Overview

Disclosure Requirements:

Disclosure to learners must include the following:

• The names of all individuals with control over content with relevant financial relationship(s), or no relevant financial relationships, to disclose
• The names of the ineligible companies with which they have relationship(s)
• The nature of the relationship(s)
• A statement that all relevant financial relationships have been mitigated

At each activity session:

Options for Disclosure

All relevant financial relationships must be disclosed to the learners before an activity begins. Individuals that report no relevant relationships must also disclose and that disclosure is shared with the learners prior to the activity taking place.

There are several different ways to disclose the financial relationships for anyone that has a role in the activity to the learners. 

• Include the disclosure information in promotional material distributed to attendees
• Verbally announce the disclosure(s) to the learners before the presenters begin.  This type of disclosure would have to be documented for the file. 
• Provide a handout or an attachment to the brochure/program that has a summary of the disclosures the planners, presenters, etc. have made.
• Second slide of the presentation being delivered to the learners.  This way the learners will be aware of any disclosure information the presenter has and can determine for themselves if the presentation creates any conflicts of interest with the presenter’s financial relationships.

So how might we disclose this information to participants?

We're always looking for ways to make it easier for you and us to keep track of all this, so please feel free to send along any ideas that you have.

Right now, here are some options that are currently in use:

• Place the information in the promotional content distributed to potential participants
• Place the information on or next to the sign-in sheet used to record attendance*
• Place the information on the second slide of visual presentation(s) used to deliver content
• Disclose the information to participants in a document or spreadsheet distributed to all participants*

* This option only applies to regularly scheduled series (grand rounds) that involves presenters from inside its division/department only.

Evidence of how the disclosure was made to the learners must be documented and uploaded into the file.  Examples and templates are provided in the next section.

Random files are chosen for review during reaccreditation (every 4-6 years).  For the file to be complete, all disclosures and evidence of disclosure to the learners must be in the file.  In our most recent reaccreditation, some of that documentation was missing from the files and we were found to be non-compliant for disclosure of the planners of the activities to the learners.

The Disclosure Documentation Process

We must be able to demonstrate that we follow the disclosure requirements for any individual activity or regularly scheduled series. As a course administrator, we must rely on you to help us validate that the programs you manage follow these requirements, and that requirements are met through appropriate documentation.

• Disclosure information is collected for anyone in the position to control the content of the activity (planning committee, speakers, moderators, etc.) before the activity begins
• Any potential commercial conflicts of interest are identified and resolved
• Disclosure (required) and Commercial Resolution Form (if needed) are uploaded into the file before the presentation
• Disclosure of any commercial relationship (or lack thereof) are disclosed to the learners prior to the activity session in one of the approved formats
• Evidence of disclosure to the learners for each activity session is uploaded into the file

We need your help in determining appropriate mechanisms for collecting evidence of disclosure without putting undue burden on you.

The next section provides some mechanisms for documenting disclosure. Please think about ways in which you can document the activities that you oversee; we're here to listen.

A last word on disclosure requirements:

According to the ACCME, the disclosure should occur within the past 24 months of the event (Click here for the policy wording).  If a person is acquiring or terminating a new relevant financial relationship within the 24 month period, it should be disclosed within 30 days of the event. As of 1/1/2021, planners and speakers need not disclose financial relationships of spouses or significant others.

Disclosure Templates and Examples

The table below provides options for disclosure, templates for doing so, and documentation options:

Placement	Immediately after title slide	Any part of a promotion piece	On or next to activity sign-in sheet	Verbal delivery
Examples\ Templates	1.  Powerpoint with multiple disclosure types	1. No financial relationship 2. With financial relationship	1. No financial relationship 2. With financial relationship	Verbal disclosure form
Process to submit	Store and submit all presentations via email	1. Include uab@cme.edu on event promotion communications 2. Upload all promotional flyers to the Activity record	Scan sign-in sheets and submit via email to your CME representative	Scan course director signature and submit via email to your CME representative

For series that will have presenters who are internal to UAB (or primarily internal to UAB), we have the option to custom-build a single disclosure sheet for the course director and all presenters that can be reused for all presentations. Please contact us if you think this option would work for you.

Forms

Financial Disclosure Form

Conflict of Interest Mitigation Form for (page #2) Planners and (page#3) Authors/Presenters

This document contains both conflict of interest resolution forms. Use page 2 for for planners and activity directors, and page 3 for authors and presenters of content.

How CME can Help

We want to make the disclosure recording and documentation process as seamless and painless as we can. We can work with you on the following options, and we're open to suggestions that you have: 

• Provide templates to you for any disclosure option
• Offer online sign-in for divisions or departments
• Provide summary disclosure lists
• Collect disclosure information for you if you use your promotional material to disclose
  • Just add us to your mailing list: cme@uab.edu

Please contact your CME Specialist with questions. We are always available to help you.