Disclosure Declaration - Conflict of Interest
The Accreditation Council for Continuing Medical
Education (ACCME) has updated its “Standards for Commercial
Support.” One important change relates to identifying and
managing conflict of interest. ACCME has released the
following new Standard: “The provider must have implemented
a mechanism to identify and resolve all conflicts of
interest prior to the education activity being delivered to
learners.” This is an important Standard with regard to
program planning and it requires your active attention.
Conflict of interest of an individual has two components:
- A financial relationship with a commercial interest
(e.g., pharmaceutical company or medical device
manufacturer); and
- the opportunity to influence content of a CME activity
relevant to products and services of that commercial
interest.
Previously, providers of CME needed only to disclose any
conflicts of interest that a planner, speaker, or author may
have had prior to the CME activity. Currently, providers of CME
must also manage, describe, and document a mechanism to
resolve any conflict of interest prior to the activity.
We have revised our
Disclosure Declaration (Word) to obtain more specific
information from those who are completing it. We have
added a box on page 2 of the Disclosure Declaration to
provide Activity Directors with a place to document whether
or not actual conflict of interest exists, and in the event
of actual conflict, to document what safeguards the program
has proactively taken to ensure that no commercial bias
exists within the CME content.
We have created a
template e-mail message (Word) that you can modify and
use in sending the Disclosure Declaration to speakers. The
message highlights that changes have been made to the
document and that conscientious completion will facilitate
the process.
ACCME is not proscriptive about how a provider should manage
conflict of interest; however, ACCME is clear that
documented safeguards should exist to prevent the insertion
of commercial bias.
Acceptable ways to manage conflict may include:
- Restrict involvement of the person to areas outside
of the area of conflict;
- have another speaker address areas that serve as a
conflict for another speaker;
- choose another speaker, planner, or author entirely;
- change the focus of the activity to one that avoids the
conflict; and/or,
- subject all information to peer review.
Depending on the circumstance, other acceptable safeguard
options may exist. Combining two or more safeguards or
developing a unique mechanism may also be appropriate.
For all current and future CME activities, please determine
whether any planner, speaker, or author has a conflict of
interest that requires your attention. Below please find a
flow diagram that you can use to remind you of the new
standard and the steps relating to it. As you implement this
new Standard, please maintain documentation (e.g., planning
notes, committee minutes, e-mail messages) and share it with
us as part of your Application or Final Report.
Please let us know if we can help you in any way
regarding this new standard (Ext. 2904). On behalf of the
entire Office staff, thank you very much for your consideration.
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