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Hot Topics. Commercial Support. What is Commercial Support?. Commercial Support is financial or in-kind contributions given by a commercial interest which is used to pay all or part of the costs of a CME activity.
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Hot Topics Commercial Support
What is Commercial Support? • Commercial Support is financial or in-kind contributions given by a commercial interest which is used to pay all or part of the costs of a CME activity.
Commercial Support from Industry/Control on the Content of the CME Activity (SCS 1.1) • In past years it may have been acceptable to ask a commercial entity to suggest a speaker or a topic, while the activity still maintained ultimate control. Recently, the accrediting body for CME has changed the regulation. • CME providers can receive commercial support from industry. CME providers cannot receive or request any advice or guidance, either nuanced or direct, on the content of the activity or on who should deliver that content. CME providers must ensure the content of the activity remains beyond the control of any commercial interest.
LOA’S/FINANCIAL • When seeking commercial support, an LOA (letter of agreement) must be completed and signed by the Director for CME. • The original will be sent to the commercial supporter and a copy will be retained for the accreditation file for the RSC. • Monies that come through our office will be deposited into a budget created by us for the purpose of paying expenses associated with the activity. FUTURE ALL funds will have to come to the Office of CME.
Commercial Support • All honoraria payments and reimbursement of expenses must be made in accordance with SUNY Downstate OCME Policies. • Commercial Support can be acknowledged by making the statement “we gratefully acknowledge {name of company} for their generous support of this educational activity”.
Food at CME Accredited Events • A commercial supporter cannot provide food directly or arrange its delivery. Policy requires that an LOA must be signed, the funds provided to the provider (CME office budget for RSC) and then the RSC sponsor (the department/division) orders and arranges delivery and pays for the food –Dennis Lott, Manager Accreditation, ACCME July 2005
Commercial Support • This does NOT mean that you cannot have Food and Beverages at your activity. It just means that the commercial supporter must give you the money and you then must pay the caterer. • Money MUST come through the department and CANNOT be paid directly to any speaker or to directly purchase any food or beverage.
Who Has to “Disclose”? For CME purposes, any person who interacts with the audience in the educational portion of a CME activity (e.g. planner, presenter, moderator, instructor) is considered part of the “activity faculty” and must provide disclosure information.
Why is “Disclosure” so important? • Because, the audience has the right to know what influences a speaker’s presentation. • The audience can then decide if the presentation was balanced and free from bias.
Disclosures • All speakers (internal or external) must sign a disclosure form before the lecture begins. • If the activity is an open forum discussion in design, then only the moderator or facilitator must fill out the disclosure form in advance. • Disclosure must be made to learner in advance of learning. The paperwork only does not suffice. • A copy of actual disclosure that was made to learners is required in the file (slide, printed sheet, etc).
Disclosures • By signing the disclosure agreement, the faculty or planning member is attesting to his/her commitment to ensuring that the activity complies with all CME requirements. • It is the responsibility of the Activity Director to review the disclosure information to determine if there is the potential for a conflict of interest, and if the potential exists, to take steps to resolve it.
Sources • www.accme.org • Updated Accreditation Criteria http://www.accme.org/dir_docs/doc_upload/b03aa5cc • www.ama.org • www.abms.org • www.jointcommission.org • www.cmebaylor.org • www.mssm.edu • cme.uwisc.org • www.hopkinscme.org • www.cme.med.umich.edu