Manage Commercial Support Appropriately
Accredited providers (i.e., your UConn approved CME activity) that choose to accept commercial support (defined as financial or in-kind support from ineligible companies) are responsible for ensuring that the education remains independent of the ineligible company and that the support does not result in commercial bias or commercial influence in the education. The support does not establish a financial relationship between the ineligible company and planners, faculty, and others in control of content of the education.
- Decision-making and disbursement: The accredited provider must make all decisions regarding the receipt and disbursement of the commercial support.
- Ineligible companies must not pay directly for any of the expenses related to the education or the learners.
- The accredited provider may use commercial support to fund honoraria or travel expenses of planners, faculty, and others in control of content for those roles only.
- The accredited provider must not use commercial support to pay for travel, lodging, honoraria, or personal expenses for individual learners or groups of learners in accredited education.
- The accredited provider may use commercial support to defray or eliminate the cost of the education for all learners.
- Agreement: The terms, conditions, and purposes of the commercial support must be documented in an agreement between the ineligible company and the accredited provider. The agreement must be executed prior to the start of the accredited education. An accredited provider can sign onto an existing agreement between an accredited provider and a commercial supporter by indicating its acceptance of the terms, conditions, and amount of commercial support it will receive.
- Accountability: The accredited provider must keep a record of the amount or kind of commercial support received and how it was used, and must produce that accounting, upon request, by the accrediting body or by the ineligible company that provided the commercial support.
- Disclosure to learners: The accredited provider must disclose to the learners the name(s) of the ineligible company(ies) that gave the commercial support, and the nature of the support if it was in-kind, prior to the learners engaging in the education. Disclosure must not include the ineligible companies’ corporate or product logos, trade names, or product group messages.
Refer to: ACCME Standard 4
UConn Direct Providership or Joint Providership
Commercial support is any financial or in-kind contribution given by a commercial interest to support the cost – in whole or in part – of a CME activity. A “commercial interest” is any entity (e.g., pharmaceutical company, medical device manufacturer) producing, marketing, re-selling, or distributing health care goods or services consumed by, or used on, patients. For each company providing commercial support either a Letter of Agreement for Commercial Support for Direct Providership OR a Letter of Agreement for Commercial Support for Joint Providership must be executed and sent to the CME Office prior to the activity.
- Letter of Agreement for Commercial Support for Direct Providership
- Letter of Agreement for Commercial Support for Joint Providership
Commercial Exhibitors/Vendors and Advertisement
Commercial exhibits or vendors who advertise are not continuing medical education. The fees paid by commercial interest to providers for exhibits and advertisements are not considered to be commercial support, however providers must meet certain requirements if commercial exhibits or advertisements accompany CME activities.
Manage Ancillary Activities Offered in Conjunction with Accredited Continuing Education
Accredited providers(i.e., your UConn approved CME activity) are responsible for ensuring that education is separate from marketing by ineligible companies—including advertising, sales, exhibits, and promotion—and from nonaccredited education offered in conjunction with accredited continuing education.
- Arrangements to allow ineligible companies to market or exhibit in association with accredited education must not:
- Influence any decisions related to the planning, delivery, and evaluation of the education.
- Interfere with the presentation of the education.
- Be a condition of the provision of financial or in-kind support from ineligible companies for the education.
- The accredited provider must ensure that learners can easily distinguish between accredited education and other activities.
- Live continuing education activities: Marketing, exhibits, and nonaccredited education developed by or with influence from an ineligible company or with planners or faculty with unmitigated financial relationships must not occur in the educational space within 30 minutes before or after an accredited education activity. Activities that are part of the event but are not accredited for continuing education must be clearly labeled and communicated as such.
- Print, online, or digital continuing education activities: Learners must not be presented with marketing while engaged in the accredited education activity. Learners must be able to engage with the accredited education without having to click through, watch, listen to, or be presented with product promotion or product-specific advertisement.
- Educational materials that are part of accredited education (such as slides, abstracts, handouts, evaluation mechanisms, or disclosure information) must not contain any marketing produced by or for an ineligible company, including corporate or product logos, trade names, or product group messages.
- Information distributed about accredited education that does not include educational content, such as schedules and logistical information, may include marketing by or for an ineligible company.
- Ineligible companies may not provide access to, or distribute, accredited education to learners
Refer to: ACCME Standard 5