Financial Disclosure

The Purpose of Disclosure

The purpose of disclosure is to ensure that the educational material presented to the learners is free and separate from commercial interests. Any individual that can affect the educational content of the activity must disclose whether or not they have financial relationships with an ineligible company.

Click here to review the ACCME's definition an ineligible company.

The Standard

According to the Standards for Integrity and Independence:

“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 with any commercial interest to participants.”

Disclosure must be made of all financial relationships with ineligible companies within the past 24 months.

• Planners and presenters with no financial relationships with ineligible companies must disclose that fact
  
• Planners and presenters with financial relationships with ineligible companies must disclose that fact
• This information must be presented to learners prior to the session

This disclosure is part of CME’s accountability to the public – by providing participants of a CME activity with information that may inform their perspectives on the content of that educational activity.  To be compliant with this expectation, providers need to communicate to the participants both those relevant financial relationships that they discovered in their process of complying with the standard, as well as the source of all financial support – both monetary and in-kind – given to the provider from commercial interests for the activity.  In addition, this information must be conveyed to the learners prior to the start of the activity.

Any individual that refuses to disclose their financial relationships will be disqualified from being involved with the CME activity as a planner, author, or teacher and can not have control or responsibility for the planning, implementation, or evaluation of the CME activity.

The determination of whether a financial relationship is "relevant" lies with the Division of CME, so our form asks individuals who have any type of control over the content of an activity to disclose ALL of their financial relationships with commercial entities.

So who is "in a position to control content"?

This can vary between activities. In general, such individuals may include:

• • Course planners/directors/committee members
  • Presenters
  • Faculty authors
  • Content reviewers
  • Content editors

"Content reviewers" can include department chairs or division directors if, for example, these individuals are called upon to complete a conflict of interest resolution for a course director of a regularly scheduled series. Here's the scenario:

1. Course director identifies a financial relationship with a commercial entity on her/his disclosure form
2. The course director is the sole planner of the activity OR Co-director(s) for the activity also discloses a financial relationship with a commercial interest
3. The department chair or division director is then asked to complete a conflict of interest (COI) resolution form in which she/he may identify that:
   1. 1. No resolution is required
      2. The content does not need to be changed in any way
      3. Specific content changes are made to resolve the identified conflict

In this instance, we must provide disclosures for the presenter, the course director(s), and the department chair/division director to participants prior to the event.