/ Policy for Identifying and Resolving Conflicts of Interest in CME

I.Background:

It is importantthat continuing medical education (CME) content be based on needs assessments and not be biased by commercial or marketing influences. This policy is designed to ensure that Mount Sinai School of Medicine develops all CME programming without undue influence by any individuals or groups associated with these CME activities.

Full disclosure of conflicting or potentially conflicting interests is required as part of the CME process, reviewed by committee and this policy is to address the resolution of any real or perceived conflicts in order to promote the integrity of CME activities at our institution.

Teachers/presenters/authors/individuals in control of CME content will be expected to offer CME that is objective, balanced, scientifically rigorous, evidence-based and in compliance with the 2004 Updated ACCME Standards for Commercial Support.

II.Goals:

  • to describe appropriate processes and procedures to identify all actual and/or potential conflicts of interest
  • toidentifymechanisms to resolve any real or perceived conflicts prior to the CME activity
  • to implement the process to reach a resolution assuring that there is no conflict of interest in the educational activity and to verify that the activity is in the best interest of the public

III.Policy: Identification of Conflicts of Interest (COI):

  1. The Page and William Black Post-Graduate School for Continuing Medical Education of Mount Sinai School of Medicinerequires that all individuals in control of CME content including the planning committee complete the application form for CME approval which includes all the necessary ACCME elements and policies including Disclosure Forms.
  2. The Page and William Black Post-Graduate School for Continuing Medical Education of Mount Sinai School of Medicine requires that all individuals participating in CME activities complete the Disclosure Form.
  3. The primary responsibility to identify, address and attempt to resolve any COI belongs to the Activity Director. The Office of Continuing Medical Education staff will be available to assist with this process.
  4. Any disclosure forms of concern identified by the Activity Director will be reviewed by CME staff and the CME review committee. The Director of CME and/or the Associate Dean for CME will be available discuss any conflict with the course director.
  5. The Activity Director will sign off on the educational activity as having reviewed all conflicts to be identified and resolved.
  6. All identified actual and potential COI, along with resolution mechanisms, will be disclosed to CME activity participants.

IV.Policy: Mechanisms for Resolving Conflicts of Interest:

The following are suggested mechanisms for resolving conflicts of interest (COI).

  1. Attestation:

Persons who indicate the existence of potential or actual COI will be asked to agree in writing that said conflicts or

relationships will not bias or otherwise influence their involvement in the CME activity and will be evidence-based.

  1. Evaluation:

Attendees will be asked about bias (or absence of bias) within the activity. Activity Directors and

teachers/authors will receive copies of the evaluation summaries and comments.These evaluations will be used for quality improvement so that our office and the course directors can detect potential conflicts and resolve them prior to future programs.

  1. Peer Evaluation:

An informed learner or peer who is not involved in the planning and/or teaching of the activity will observe the

CME activity. This evaluator will be asked to complete an evaluation to note any bias in the activity.

  1. Independent content evaluation
  2. Altering financial relationships:

An individual may change his/her relationships with commercial interests, however, when individuals divest

themselves of a relationship, it is immediately not relevant to conflicts of interest, but still must be disclosed to

learners for 12 months.

  1. Altering control over content:

Change the focus of the CME content

Choose someone else to control that part of the content

Change the content of the person’s assignment

Limit the content to a report without recommendations

Limit the sources for recommendations

  1. Elimination:

Activity Directors, activity planning committee members, and/or teachers/authors who are perceived as either

manifesting irresolvable COI or being biased may be eliminated from consideration as resources for the CME activity.