ACCME Standards for Independence and Integrity I Disclosures & Mitigation:
All individuals in a position to influence the planning, designing, delivery, evaluating, and analyzing education interventions are required to disclose the presence or absence of relationships with ineligible companies, regardless of their profession or career status, including students, residents, fellows, other healthcare workers, community partners, patients, etc.
The Accreditation Council for Continuing Medical Education (ACCME), our accrediting body, defines ineligible companies as companies whose primary business is producing, marketing, selling, re-selling, or distributing healthcare products used by or on patients.
Disclosure forms must be completed and submitted before the individual engages in their role(s). For example, a planner must submit their disclosure before planning the educational intervention.
All of the following must be disclosed. The CCPD team will determine, along with the course director or designee, if the relationship is a relevant financial relationship.
• identify all individuals in a position to influence the content
• obtain the list of all relationships with ineligible companies and the nature of the relationship within the past 24 months
• develop and implement mitigation strategies
• disclose the absence or presence of relevant financial relationships to the learners
By identifying, mitigating, and disclosing relevant financial relationships, we can create a protected space to learn, teach, and engage in scientific discourse free from influence from organizations that may be incentivized to insert commercial bias into education.
If a relationship with an ineligible organization has changed, including but not limited to starting a new relationship, ending a relationship, and the nature of the relationship changes, update your electronic disclosure form as soon as possible.
Disclosures of relationships with ineligible companies does not automatically disqualify them from contributing to the activity. Once the disclosure form has been completed, if a relationship has been disclosed, the CCPD team will determine if the relationship is relevant and develop a mitigation plan if the relationship can be mitigated. If the relationship cannot be mitigated, the individual must be recused from the role, or the activity may not be accredited.
The owners and employees of ineligible companies are considered to have unresolvable financial relationships and must be excluded from participating as planners or faculty, and must not be allowed to influence or control any aspect of the planning, delivery, or evaluation of accredited continuing education, except in the limited circumstances outlined in Standard 3.2.
Owners and employees are individuals who have a legal duty to act in the company's best interests. Owners are defined as individuals who have an ownership interest in a company, except for stockholders of publicly traded companies, or holders of shares through a pension or mutual fund. Employees are defined as individuals hired to work for another person or business (the employer) for compensation and who are subject to the employer's direction as to the details of how to perform the job.
An individual who holds stock options in an ineligible company is not considered an owner or employee of that ineligible company. Disclosure of stock options would follow the review and mitigation expectations as other relationships.
No. The responsibility for identifying relevant financial relationships cannot be delegated to the person with the financial relationship.