Policies and Procedures for Identifying and Resolving Conflicts of Interest

The ACCME requires that providers establish mechanisms to identify and resolve conflicts of interest (COI) assuring there is no conflict of interest in the activity and to verify that the activity is in the best interest of the public. Providers must be engaged in a system that goes beyond simple disclosure, with necessary interventions to resolve any real or perceived conflicts of interest implemented before the activity.

Commercial Interest
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
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
ACCME focuses on financial relationships with commercial interests in the 12-month period preceding the time that the individual is being asked to assume a role controlling content of the CME activity. ACCME has not set a minimal 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 defines “’relevant’ financial relationships” as financial relationships in any amount occurring within the past 12 months that create a conflict of 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.

Procedures for Identifying Conflicts of Interest:

  1. All planners, speakers and authors in a position to control the content of a CME activity must complete a disclosure declaration in advance of the deadline. Individuals who refuse to disclose are disqualified from any role in planning, management, presentation, or evaluation.
  2. Primary responsibility for identifying, addressing and attempting to resolve any COI rests with the Course Director(s), however the Chair of the Educational Affairs Committee reserves the right to appoint members of the Educational Affairs Committee or members of the College with specific topic expertise to assist with the review process as the need arises.
  3. Conflicts of interest are identified through an analysis of the information disclosed and an understanding of the planned content of the CME.
  4. Any disclosure forms of concern identified will additionally be reviewed by the Chair of the Educational Affairs Committee for determination of appropriate action.
  5. The Course Director or other appointed reviewer will provide certification as to having reviewed all conflict of interest disclosures and determining a mechanism for their resolution.
  6. In instances where the Course Director(s) have a conflict of their own, the disclosure will be reviewed by the Chair of the Educational Affairs Peer Review Subcommittee.
  7. ACG shall convey any information disclosed by the faculty member to the CME program audience by: (1) including a description in the printed program; (2) by display of the information on a slide shown in the meeting room at the time of presentation.

Procedures for Resolving Conflicts of Interest:

  • Attestation (Presenters will be 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 through peer review of handout materials and/or slides (The presentation can not favor the commercial interest, and must include alternatives to drugs/devices manufactured by the commercial interest where possible.)
  • Evaluation (Attendees will be asked to review the activity for the absence of bias, and this information will be made known to the planners. Additionally, the Educational Affairs Committee may assign evaluators to monitor presentations.)
  • Disqualification (Planners, teachers or authors whose conflicts are irresolvable or who are perceived to be biased may be eliminated from the program or prohibited from participating in future ACG-sponsored activities.)

Suggested mechanisms for resolving COI:

    • Limit content to a report without recommendations (i.e., limit it to data and results of research, and assign someone else to address broader implications and recommendations);
    • Limit to independent sources for recommendations (citing all independent references);
    • 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;
    • Limit personal opinions to question and answer sessions;
    • Altering the financial relationship (A presenter may change his or her relationships with commercial interests, however, when individuals divest themselves of a relationship, it is immediately not relevant to conflicts of interest but must still be disclosed to the learner for 12 months.)

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.

2013-2014 ACG Board of Trustees

ACG Educational Affairs Committee Disclosure Declaration
View the ACG Educational Affairs Committee disclosure information by clicking on the link below.

2013-2014 ACG Educational Affairs Committee

ACG Staff
ACG staff are required to disclose conflicts of interest. This information is made available to the ACG Executive Director for the determination of whether any identified conflicts of interest require an individual’s recusal or excusal from certain ACG roles or decision making, or other consideration to ensure staff acts in the best interest of the ACG.