Continuing medical education (CME) planners and faculty members may have financial relationships with ineligible companies that create potential conflicts of interest.
This FAQ is a user-friendly version of “Standard 3: Identify, Mitigate, and Disclose Relevant Financial Relationships”, which is available on the Accreditation Council for Continuing Medical Education (ACCME) website.
The ACCME defines ineligible companies as those whose primary business is producing, marketing, selling, reselling, or distributing healthcare products used by or on patients.
Examples of ineligible companies include:
- advertising, marketing, or communications firms whose clients are ineligible companies;
- biomedical startups that have begun a governmental regulatory approval process;
- compounding pharmacies that manufacture proprietary compounds;
- device manufacturers or distributors;
- diagnostic labs that sell proprietary products;
- growers, distributors, manufacturers, or sellers of medical foods and dietary supplements;
- manufacturers of health-related wearable products;
- pharmaceutical companies or distributors;
- pharmacy benefit managers; and
- reagent manufacturers or sellers.
Financial relationships of any dollar amount are defined as relevant if the educational content is related to the business lines or products of an ineligible company.
Before learners engage with accredited continuing education, they must receive disclosure information about relevant financial relationships and the steps taken to mitigate them, in a format that can be verified.
There is no minimum financial threshold; individuals must disclose all financial relationships, regardless of amounts, which they have with ineligible companies.
People must undertake disclosure regardless of their view of the relevance of the relationship to education.
Disclosure information must include:
- The name of the ineligible company with which the person has a financial relationship.
- The nature of that financial relationship.
- Examples of financial relationships include: employee, researcher, consultant, advisor, speaker, independent contractor (including contracted research), royalties or patent beneficiary, executive role, and ownership interest.
- Individual stocks and stock options should be disclosed; diversified mutual funds do not need to be disclosed.
- Research funding from ineligible companies should be disclosed by the principal or named investigator, even if that person’s institution receives the research grant and manages those funds.
The accredited provider is responsible for identifying relevant financial relationships between individuals in control of educational content and ineligible companies, and managing these to ensure they do not introduce commercial bias into education.
When developing accredited continuing education, accredited providers must collect information from all planners, faculty members, and others in control of educational content about all of their financial relationships with ineligible companies within the prior 24 months, regardless of the degree of relationships or relevance to the education.
Yes, but only if the content of the activity is not related to the business lines or products of their employer/company, when the content is limited to basic science research or the methodologies of research, or when they are participating as technicians to teach the safe and proper use of medical devices.