Disclosure Declaration – Conflict of Interest

The Accreditation Council for Continuing Medical Education (ACCME) has updated its “Standards for Commercial Support.” One important change relates to identifying and managing conflict of interest. ACCME has released the following new Standard: “The provider must have implemented a mechanism to identify and resolve all conflicts of interest prior to the education activity being delivered to learners.” This is an important Standard with regard to program planning and it requires your active attention.

Conflict of interest of an individual has two components:

  • A financial relationship with a commercial interest (e.g., pharmaceutical company or medical device manufacturer); and
  • The opportunity to influence content of a CME activity relevant to products and services of that commercial interest.

Previously, providers of CME needed only to disclose any conflicts of interest that a planner, speaker, or author may have had prior to the CME activity. Currently, providers of CME must also manage, describe, and document a mechanism to resolve any conflict of interest prior to the activity.

We have revised our Disclosure Declaration (Word) to obtain more specific information from those who are completing it. We have added a box on page 2 of the Disclosure Declaration to provide Activity Directors with a place to document whether or not actual conflict of interest exists, and in the event of actual conflict, to document what safeguards the program has proactively taken to ensure that no commercial bias exists within the CME content.

We have created a Template Email Message (Word) that you can modify and use in sending the Disclosure Declaration to speakers. The message highlights that changes have been made to the document and that conscientious completion will facilitate the process.

ACCME is not proscriptive about how a provider should manage conflict of interest; however, ACCME is clear that documented safeguards should exist to prevent the insertion of commercial bias.

Acceptable ways to manage conflict may include:

  • Restrict involvement of the person to areas outside of the area of conflict;
  • have another speaker address areas that serve as a conflict for another speaker;
  • choose another speaker, planner, or author entirely;
  • change the focus of the activity to one that avoids the conflict; and/or,
  • subject all information to peer review.

Depending on the circumstance, other acceptable safeguard options may exist. Combining two or more safeguards or developing a unique mechanism may also be appropriate.

For all current and future CME activities, please determine whether the activity director, planners, speakers, or authors have a conflict of interest that requires attention. Below please find a flow diagram that you can use to remind you of the new standard and the steps relating to it. As you implement this new Standard, please maintain documentation (e.g., planning notes, committee minutes, email messages) and share it with us as part of your Application or Final Report.

For questions regarding this new standard, please contact the CME Office at 860-679-2904 or cme@uchc.edu.