American College of Gastroenterology
CME Policies and Procedures for
Identifying and Mitigating Relevant Financial Relationships
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, requires that the content of accredited continuing education provide accurate, balanced, objective, and scientifically justified recommendations. Education must be free of the influence or control of ineligible entities, and protect learners from promotion, marketing, and commercial bias.
All recommendations in CME activities involving clinical medicine must be based on current science, evidence, and clinical reasoning, while giving a fair and balanced view of diagnostic and therapeutic options. All scientific research referred to, reported, or used, in accredited education in support of justification of a patient care recommendation must conform to the generally accepted standards of experimental design, data collection, analysis and interpretation.
ACG is committed to providing accredited education that offers healthcare professionals with a protected space to learn, teach, and engage in scientific discourse free of the influence from organizations that may have an incentive to insert commercial bias into the education. All education must serve the needs of patients and not the interests of industry and adhere to all applicable standards and criteria of the Accreditation Council for Continuing Medical Education (ACCME).
NEW! Ineligible Company
The ACCME defines an "ineligible company" (formerly known as a "commercial interest") as any entity whose primary business is producing, marketing, selling, re-selling, or distributing healthcare products used by or on patients.
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 individual’s institution receives the research grant and manages the funds.
Owners and employees of ineligible companies are considered to have unresolvable financial relationships and will automatically 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 of the ACCME Standards for Integrity and Independence in Accredited Continuing Education:
- When the content of the activity is not related to the business lines or products of their employer/company.
- When the content of the accredited activity is limited to basic science research, such as pre-clinical research and drug discovery, or the methodologies of research, and they do not make care recommendations.
- When they are participating as technicians to teach the safe and proper use of medical devices, and do not recommend whether or when a device is used.
Relevant Financial Relationships
Financial relationships are relevant if the educational content an individual can control is related to the business lines or products of the ineligible company.
Procedures for Managing Integrity and Independence in ACG CME Activities
Identification of Financial Relationships
Everyone who is in a position to control the content of a CME activity (e.g., planners, speakers, authors, reviewers, staff, etc.) must disclose to ACG ALL financial relationships with any ineligible companies over the past 24 months, regardless of amount and if relevant to the content, by completing the Disclosure Declaration prior to assuming their role in an accredited activity. Individuals who refuse to disclose financial relationships will be disqualified from involvement in the planning or implementation of accredited continuing education.
Review and Determination of Relevant Financial Relationships
ACG staff in collaboration with content experts without relevant financial relationships from the Peer Review Subcommittee of the Educational Affairs Committee review all financial relationships to determine if relationships are relevant to the education. Financial relationships are identified to be relevant if:
- A financial relationship, in any amount, exists between the person in control of content and an ineligible company.
- The financial relationship existed during the past 24 months.
- The content of the education is related to the products of an ineligible company with whom the person has a financial relationship.
The identification of relevant financial relationships does not necessarily mean that an individual is unable to participate in the planning and implementation of an educational activity. Rather, the accreditation standards require that relevant financial relationships are mitigated before an individual controlling content assumes his/her role in the accredited activity.
Mitigation of Relevant Financial Relationships
ACG uses review and approval of content as the primary method for resolution of relevant financial relationships in its CME activities. At the planning level, the CME activity and the relevant financial relationships of planners are reviewed prior to the approval and implementation of an activity. All planning decisions must be approved (or modified) by the Board of Trustees or their designate(s) who conduct a peer review of all planning decisions to ensure they are free of any commercial bias, including selection of topics/content, objectives, and faculty. Planners may not proceed with an activity until it has been approved (including any required modifications identified as necessary).
Relevant financial relationships for faculty are mitigated through a content review process prior to the program. ACG staff, working with content experts from the Peer Review Subcommittee, review a speaker’s CME presentation content, which must adhere to ACG’s CME Clinical Content Validation Process and Commercial Bias Review for ACG Peer Reviewers measures. 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. ACG staff ensures that specific edits and actions identified by peer reviewers for mitigation of relevant financial relationships are implemented.
In the circumstance where a presenter or instructor participating in CME will not be presenting content such as slides, handouts, or electronic media (e.g., panelists, case presenters, or moderators), an individual with a relevant financial relationship is instructed, and must agree, to refrain from making recommendations regarding product or patient treatment options related to the ineligible company with whom s/he has a financial relationship.
Disclosure of Financial Relationships to the Learners
All relevant financial relationships and the nature of those relationships, or the absence of relevant financial relationships, will be disclosed to the learners prior to them engaging in the accredited activity, including a statement that all relevant financial relationships have been mitigated. ACG shares this information with learners via the online platform, mobile app, printed program book handout, or on a slide (as appropriate for the activity type).
Monitoring and Oversight
All accredited continuing education activities will be evaluated by participants to determine if the content was free of bias and met acceptable scientific standards. Additionally, the Educational Affairs Committee may assign peer review evaluators to attend, monitor, and audit select presentations. ACG investigates any commercial bias claims from its attendees, faculty, and monitors. Speakers who do not fully comply with ACG’s policies and procedures related to the elimination of commercial bias from its CME programs may be prohibited from participating in future activities.
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.
2021-2022 ACG Board of Trustees
ACG Educational Affairs Committee Disclosure Declaration
View the ACG Educational Affairs Committee disclosure information by clicking on the link below.
2021-2022 ACG Educational Affairs Committee
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 2022, all ACG staff in a position to control CME content have nothing to disclose.