American College of Gastroenterology CME Policies and Procedures for Identifying and Resolving Conflicts of Interest
The American College of Gastroenterology (ACG) is accredited by the Accreditation Council for Continuing Medical Education (ACCME) to provide continuing medical education for physicians. ACG, as an ACCME accredited provider, ensures balance, independence, objectivity, and scientific rigor in all of its directly and jointly provided education activities. All who are in a position to control the content of an education activity (including their spouse or partner) are required to disclose to ACG all relevant financial relationships in any amount occurring in the past 12 months with any commercial interest that may create a conflict of interest related to the subject matter of an education activity. Safeguards against commercial bias have been put in place by ACG. Anyone who refuses to disclose relevant financial relationships will be disqualified. ACG ensures any conflicts of interest are resolved before the educational activity occurs and discloses all relevant financial relationships to the learners prior to the beginning of an education activity.
The ACCME defines a “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.
Financial relationships are those relationships in which the individual benefits by receiving a salary, royalty, intellectual property rights, consulting fee, honoraria, 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.
Relevant Financial Relationships
The ACCME defines ‘relevant’ financial relationships as financial relationships in any amount occurring within the past 12 months that create a conflict of interest. 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. The ACCME considers financial relationshipsto 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.
Conflict of Interest
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.
Procedure for Identifying Conflicts of Interest:
- Everyone who is in a position to control the content of a CME activity (e.g., planners, speakers, authors, etc.) must disclose all relevant financial relationships with a commercial interest to the ACG by completing our Disclosure Declaration prior to the education activity being delivered to learners. Individuals who refuse to disclose relevant financial relationships will be disqualified from being a planning committee member, a teacher or an author of CME, and cannot have control of, or responsibility for, the development, management, presentation or evaluation of the CME activity.
Process for Resolving Conflicts of Interest:
- ACG Course Directors have primary responsibility for resolving conflicts of interest. In addition, the ACG Educational Affairs Committee Chair may also intervene to resolve conflicts of interest or appoint Educational Affairs Committee members with specific topical expertise to assist in a resolution process as needed.
- Conflicts of interest are resolved through an analysis of the information disclosed and an understanding of the planned content for the CME activity. Information is provided to all peer reviewers of speakers who have indicated that a COI may exist such that peer reviewers may compare a speaker’s COI information to said speaker’s CME presentation content. Peer reviewers conclude by indicating (1) content is approved (i.e., without Commercial Bias) (2) not approved or (3) approved with specific edits or action required. Staff ensures that all content from speakers with conflicts of interest is peer reviewed. ACG staff ensures that identified mechanisms for COI resolution are implemented.
- Any conflicts of interest may also be reviewed by the Chair of the Educational Affairs Committee for determination of appropriate action.
- In instances where the Course Director(s) have a conflict of their own, speakers’ conflicts of interest will be reviewed by members of the Educational Affairs Peer Review Subcommittee.
- ACG ensures that individuals disclose to learners any relevant financial relationship(s) including: the name of the individual; the name of the commercial interest(s); the nature of the relationship the person has with each commercial interest.
- For an individual with no relevant financial relationship(s) the learners are informed that no relevant financial relationship(s) exist.
- The source of all support from commercial interests is disclosed to learners. When commercial support is in-kind the nature of the support is also disclosed to learners.
- Disclosures are never to include the use of a corporate logo, trade name or a product-group message of an ACCME-defined commercial interest.
- ACG discloses all the above information to learners prior to the beginning of an educational activity online or in a printed program/document/journal/syllabus or on a slide shown in the meeting room of learners at the beginning of each presentation.
Specific Actions for Resolving Conflicts of Interest:
- Attestation: Presenters are asked to agree in writing that their disclosed relationships will not bias or influence their involvement and that their presentations will be evidence-based.
- Content Validation: This is conducted through an intensive, multi-layered peer review of handout materials and/or slides.
- Evaluations: Attendees are asked to rate if the activity, on a scale from 1 to 5 with 1 = strongly disagree and 5 = strongly agree, was objective, balanced and free of commercial bias. For scores of 1 or 2, ACG requests that attendees describe why they disagree. This data is shared with the current year’s planning committee, Course Directors and faculty, and utilized by the next year’s planning committee and Course Directors in the faculty selection process. Additionally, the Educational Affairs Committee may assign peer review evaluators to attend, monitor and audit select presentations.
- Disqualification: Anyone in a position to control CME content who refuses to disclose relevant financial relationships is disqualified. Those whose conflicts are irreparable or who are perceived to be biased may be eliminated from the program or prohibited from participating in future ACG activities.
Suggested Mechanisms for Resolving COI:
In addition to ACG’s peer review process for identifying and resolving conflicts of interest, we ask that speakers take one or more of the following steps (see below) to resolve a potential conflict. Speakers are able to indicate on ACG’s Disclosure Declaration the additional steps they will take to ensure the absence of bias from their lectures:
- Alter financial relationships
- Limit content to a report without recommendations
- Limit personal opinions to Q&A sessions
- Limit to independent sources for recommendations
Course Directors or other peer reviewers analyze these selections to (1) be certain that the materials speakers have submitted comply with the additional steps they selected, and (2) are appropriate to aid in the conflict resolution. The Course Director or other peer reviewers may direct a speaker to use an alternate or additional step to resolve their conflict (i.e., change the focus of the CME content, select someone else to control that part of the content, revise the content of the person’s assignment, etc.).
ACG Board of Trustees Disclosure Declaration
Oversight of all educational programming content is conducted by the ACG Board of Trustees through a review and approval process. View the ACG Board of Trustees disclosure information by clicking on the link below.
ACG Educational Affairs Committee Disclosure Declaration
View the ACG Educational Affairs Committee disclosure information by clicking on the link below.
All ACG staff who are in a position to control the content of a CME activity are required to complete ACG’s COI form annually. As of January 2015, all ACG staff in a position to control CME content have nothing to disclose.