Conflicts of Interest and Transparency Issues. Susan Cantrell Vice President, Resources Development. Focus of Today’s Discussion. Review some of the recent developments related to potential conflicts of interest that are of concern to associations
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Conflicts of Interest and Transparency Issues
Vice President, Resources Development
Institute of Medicine
A conflict of interest is a set of circumstances that creates a risk that professional judgment or actions regarding a primary interest will be unduly influenced by a secondary interest.
Primary interest = goal of the profession
When an individual’s interests are aligned with those of a commercial interest, the interests of the individual are in ‘conflict’ with the interests of the public. The ACCME considers financial relationships to 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.
Any entity producing, marketing, reselling, 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. A commercial interest is not eligible for ACCME accreditation.
Title VI. Transparency and Program Integrity
Enhancing Choices with Full Disclosure of Physician Financial Interests
To prevent conflicts of interests and insure full transparency and information for patients, the Act requires all drug companies, device, and medical supply manufacturers to fully disclose and report any gifts they make or financial arrangements they have with doctors, a physician practice or group.
Source: ACCME Annual Report Data, 2008
Cornish JK, Leist JC. Journal of Continuing Education in the Health Professions. 2006; 26:161-7.
The provider obtains a signed statement that lists relevant faculty (and others with potential to influence content) conflicts of interest that have the potential to influence an activity.
The provider has policies and procedures to ensure that if an individual refuses to disclose conflicts of interest, they are disqualified from any involvement with the CE activity.
The provider has a mechanism to resolve conflicts of interest and documents the resolution prior to delivery of the educational activity.
All individuals who are engaged in the planning of a CPE activity, including:
Consult ACPE regarding language in rubric.
Who determines that a conflict exists?
Resolving Conflict of Interest Decision Tree
Disclosure Form Received?
Disclosure Information Obtained
Another Way Prior to Activity?
Has Control Over Content Discussing
Healthcare Products and Services?
Ineligible to Plan/Present
Ineligibility Communicated to Faculty Member
Has Financial Relationship(s) With
Manufacturers or Service Providers
Relative to Product and Services Discussed?
Eligible to Plan/Present with Restrictions
Restrictions Communicated to Faculty Member
Relationship(s) Disclosed to
Conflict of Interest Identified
Participants Evaluate Potential Presence of Bias
Eligible to Plan/Present without Restrictions
Through: Self-Identification, Peer Review,
Committee Review, or Other Process
Resolving COIs is the responsibility of the provider, not the person who has the conflict.
The following information must be disclosed prior to the delivery of the activity:
Please indicate the extent to which you agree or disagree with the following statement:
“Faculty statements and therapeutic recommendations in this activity were based on supported evidence or professional opinion and did not evidence commercial bias.”
If you answered strongly disagree or disagree to question 8, what commercial bias did you perceive in this activity?