If a conflict is identified, it must be mitigated through a review process conducted either by a course activity planner, a UAB division director or chair, or the director for continuing medical education.
Depending on whether the conflict relates to an individual who is an activity planner or faculty/presenter, the conflict can be mitigated through a few different mechanisms:
| Activity Director or Planner | Faculty/presenter |
| Planner may withdraw from the planning committee | Presenter may withdraw from the activity |
| Planner may recuse her/himself from that portion of the activity for which a conflict exists | The content may be peer-reviewed to ensure it contains no bias |
| The department chair, division director, or other unit leader may review to ensure that event or series content is not relevant to the financial relationship(s) |
The content may be reviewed by the director of CME |
| The committee can document its planning process and submit it and a sampling of content for review by the director of CME to ensure that it contains no content related to the conflict identified |
The series of questions on the following pages will help you to identify conflicts of interest.
Use this series of questions to identify and mitigate potential conflicts of interest for your educational activities.
Is the content related to products or business lines of an entity defined ineligible company?
any entity whose primary business is producing, marketing, selling, re-selling, or distributing healthcare products used by or on patients
Entities that are not considered commercial interests:
| 501-C Non-profit organizations* | Health insurance providers | For-profit nursing homes |
| Government organizations | Group medical practices | Blood banks |
| Non-health care related companies | For-profit hospitals | Diagnostic laboratories |
| Liability insurance providers | For profit rehabilitation centers |
* Be careful of this one: A 501c organization that advocates for commercial interests is considered a commercial interest.
Examples of ineligible organizations include:
- Advertising, marketing, or communication firms whose clients are ineligible companies
- Bio-medical startups that have begun a governmental regulatory approval process
- Compounding pharmacies that manufacture proprietary compounds
- Device manufacturers or distributors
- Diagnostic labs that sell proprietary products
- Growers, distributors, manufacturers or sellers of medical foods and dietary supplements
- Manufacturers of health-related wearable products
- Pharmaceutical companies or distributors
- Pharmacy benefit managers
- Reagent manufacturers or seller
If the answer is "No", then there is no further action needed.
If the answer is "Yes", then we must pursue an appropriate mitigation strategy.
A note on Owners or Employees of an Ineligible Company
Any person employed by an ineligible company cannot participate in planning or presenting a CME activity unless:
- The owner/employee is presenting content that is not related to the business lines or products of their employer
- The content is limited to basic science research (e.g., pre-clinical research, drug discovery) or the processes/methodologies of research, themselves unrelated to a specific disease or compound/drug.
- The owner/employee of ACCME-defined commercial interest is participating as a technician in accredited CME activities that teach the safe and proper use of medical devices.
Additional Resources
ACCME Financial relationships & Conflicts of Interest