The ACCME defines commercial interest as any entity producing, marketing, re-selling, or distributing health care goods or services consumed by, or used on, patients.
The ACCME does not consider providers of clinical service directly to patients to be commercial interests - unless the provider of clinical service is owned, or controlled by, an ACCME-defined commercial interest.
Financial relationships are those relationships in which the individual benefits by receiving a salary, royalty, intellectual property rights, consulting fee, honoraria for promotional speakers’ bureau, ownership interest (e.g., stocks, stock options or other ownership interest, excluding diversified mutual funds), or other financial benefit. Financial benefits are usually associated with roles such as employment, management position, independent contractor (including contracted research), consulting, speaking and teaching, membership on advisory committees or review panels, board membership, and other activities from which remuneration is received, or expected. ACCME considers relationships of the person involved in the CME activity to include financial relationships of a spouse or partner.
The ACCME has not set a minimum dollar amount for relationships to be significant. Inherent in any amount is the incentive to maintain or increase the value of the relationship.
With respect to personal financial relationships, contracted research includes research funding where the institution gets the grant and manages the funds and the person is the principal or named investigator on the grant.
Conflict of Interest (COI)
Circumstances create a conflict of interest when an individual has an opportunity to affect CME content about products or services of a commercial interest with which he/she has a financial relationship.
The ACCME considers financial relationships to create actual conflicts of interest in CME when individuals have both 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. The ACCME considers “content of CME about the products or services of that commercial interest” to include content about specific agents/devices, but not necessarily about the class of agents/devices, and not necessarily content about the whole disease class in which those agents/devices are used.
With respect to financial relationships with commercial interests, when a person divests themselves of a relationship it is immediately not relevant to conflicts of interest but it must be disclosed to the learners for 12 months.
Staff will also initiate one of the below mechanisms for the resolution of COI as appropriate.
In the case a conflict of interest is identified with a course director, activity director or program chair responsible for developing agenda and proposing presenting faculty, a review and feedback by the SHM Education Committee will be provided and in some instances peer review outside of the institution may be sought.
In the case a conflict of interest is identified with a faculty, author, speaker, planning committee member, or any individual control of the content of individual presentations, lectures, and enduring online activities, the following mechanisms may be employed:
Relevant financial relationships of those with control over CME content will be disclosed to learners prior to the continuing medical education activity in a “Disclosure Statement”. When commercial support is “in-kind,” the nature of the support must be disclosed as well.
For online enduring activities, this disclosure statement will appear as the front matter, requiring learners to mark a checkbox acknowledging they have read the disclosure. For live activities, a full list of COI data will be included in the program book and as the first slide of each speaker/author/presenters presentation
Disclosure statements will include: name of individual, name of commercial interest, & nature of the relationship will be provided without trade names, logos, product messages, or any similarly promotional type content.
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