Conflict of Interest Policy

In compliance with the ACCME Revised Standards for Commercial Support, CEC will take all necessary steps to identify and resolve potential conflicts of interest of everyone who is in a position to control the content of an educational activity. This includes, but is not limited to, program development faculty, program chairs, onsite speakers, moderators, and panel discussants.

All involved faculty will be required to complete a CEC disclosure form prior to their active involvement. They will need to outline for CEC all relevant financial relationshipsa with commercial supporters that relate to the topic being presented. This includes not only the product(s) of the commercial supporter for that designated program, but also all industry affiliations within the identified therapeutic area that may be in conflict. All activity from the prior 12 months must be disclosed. CEC clinical staff and ancillary resources (e.g., Advisory Board) will determine if the identified relationship has potential impact on the content of the educational activity.b

CEC employs a number of mechanisms to reconcile concerns for specific activities, including, but not limited to:

  • Alteration of faculty role/assignment within content presented (e.g., disease info vs. therapeutic recommendations)
  • Peer review of all current materials by clinical experts not involved in actual presentation
  • Use of referenced information that has undergone peer-review prior to presentation or publication
  • Use of “best available” evidence to ensure content validity, including evidence-based data when available
  • Alteration of content to avoid conflictual areas
  • Limiting researchers to presentation of “reports without recommendations”

Additionally, all faculty sign a Letter of Agreement with CEC agreeing to content validity in data presented and fair balance of therapeutic products, as well as an Attestation Statement regarding material that will be presented verbally. If above attempts are not successful (or viable), the faculty member may be removed from the specified activity of concern. CEC receives participant evaluation forms that solicit feedback about perceived commercial bias from all CME activities. Speakers who have been identified as having commercial bias would be used again only under certain situations where a great deal of communication and coaching has occurred on this topic. Disclosure of relevant relationships is made known to participants verbally in housekeeping announcements at live programs and in print materials (e.g., handout, website) prior to participation in the activity.

aThe ACCME defines a “commercial interest” as any proprietary entity producing, marketing, re-selling, or distributing healthcare goods or services consumed by, or used on, patients, with the exemption of non-profit or government organizations and non-healthcare related companies. Financial relationships are those in which the individual benefits by receiving a salary, fee-for-service, royalty, intellectual property rights, consulting fee, ownership interest (e.g., stocks, excluding mutual funds), or any other financial benefit with a commercial interest for consulting, speaking, or research activities. ACCME considers relationships of the person involved in the CME activity to include financial relationships of a spouse/partner.

bCEC will use criteria obtained from the disclosure form, which identifies the level of involvement the speaker will have with clinical recommendations:

  1. Content related to disease state information only, or
  2. Content related to drug therapy and presentation of clinical data, but no therapeutic recommendations or clinical opinion expressed, or
  3. Content related to drug therapy and presentation of clinical data with therapeutic recommendations and clinical opinion expressed.

Faculty who are involved in scenario #3 will receive the highest level of scrutiny regarding financial relationships with the commercial supporter of those of a therapeutic competitor. Examples of questions that will be asked include:

  • Has this speaker been identified as “biased” on previous activity evaluations?
  • Will the content be peer-reviewed in advance?
  • Will the content be focused on commercial products or clinical data?
  • If the speaker has received research grants, were they given to the institution that employs the speaker or to the speaker directly?
  • Are disclosed speaking fees related to CME activity or promotional activities?
  • Does the speaker have substantial financial holdings in the commercial support.