CME Conflicts of Interest Policy

Responsible Unit: Office of the Provost | Executive lead: Provost 
Created: 10/23/2015 | Reviewed/Revised: 9/27/23 | Effective: 9/27/23 
Compliance: N/A 
Approving Body: PPC | Classification: Institution-Wide 


Policy:  
It is the policy of PNWU’s Office of University Continuing Medical Education (OUCME) to ensure balance, independence, objectivity and scientific rigor in all CME/CE activities. The desired outcome of this policy is to conduct educational activities that are free of the appearance of or actual conflicts of interest (“COI”) and the introduction/demonstration of bias in favor or against a commercial product, service, or device in return for known or unknown personal and professional gain. The intent of this policy is to ensure that any potential conflict will be identified openly so that the activity participants may form their own judgments about the presentation with the full disclosure of facts. 

All individuals in a position to influence the content of a certified CME/CE activity must disclose any relevant financial relationship that might affect independent involvement in the proposed CME/CE activity. Any speaker or planning committee member who refuses to disclose financial relationships will be disqualified from participating in the planning and implementation of the activity. 
  
The CME application requires complete documentation, including completion of all standard disclosure statements from the beginning stages of the educational process, indicating no COI or COIs that have been resolved. 

Definitions:  

  • Conflict of interest: Circumstances create a COI when an individual has an opportunity to affect CME content about products or services of a commercial interest with which he/she has a financial relationship. 
     
  • Relevant financial relationship: Financial benefit that the person involved in the CME activity, spouse, or a partner has had within the past 12 months. This pertains to salaries, royalties, intellectual property rights, consulting fees, honoraria, ownership interest or other financial benefits with pharmaceutical companies, biomedical device manufacturers or other corporations whose products or services are related to the subject matter of the presentation topic. 

Procedure:  

Required elements of avoiding conflict include: 

  • Thoughtful review of the planning and content of CME/CE activities; 
  • Full disclosure of relevant financial relationships to participants; and 
  • Audience evaluation of potential bias in CME/CE presentations. 
  • Planning Committee: All members of an activity planning committee disclose any relevant financial relationships with any commercial interest to the OUCME. 
    • At the first meeting of the planning committee, all members must disclose any relevant financial relationships.
    • All members who have no relationships should be documented in the minutes of the committee meeting.
    • In the event of an identified COI, appropriate action should be taken to ensure its resolution. Acceptable alternatives include
      • The member may withdraw from the planning committee.
      • The member may be excluded from planning any portions of the activity which are related to the COI.
      • The activity may be subject to peer review by the remainder of the planning committee to ensure the absence of bias in its content.
      • The activity may be submitted for peer review by the director of CME to ensure absence of the bis in its content. 
    • All actions to identify and resolve conflicts of interest among planning committee members should be documented in the minutes of the planning committee and submitted to the OUCME.
    • Planning committee disclosures should be included in the initial application packet submitted to the OUCME.
  • Speakers/Activity Faculty: All speakers/activity faculty in an approved CME/CE activity must disclose any relevant financial relationships with any commercial interest to the OUCME. 
    • When a speaker accepts the invitation to present at a CME/CE activity, the planning committee must obtain disclosure of any relevant financial relationships.
    • In the event of an identified COI, appropriate action should be taken to ensure its resolution. Acceptable alternatives include:
      • The speaker may withdraw from the activity.
      • The content of the presentation may be subject to peer review by the planning committee to ensure the absence of bias in its content.
      • Evaluation of best available evidence on the topic, to ensure that the content of the presentation is consistent with the current literature.
      • The presentation may be submitted for peer review by the director of CME to ensure the absence of bias in its content. 
      • All actions to identify and resolve conflicts of interest among the speakers/activity faculty should be documented in the minutes of the committee meeting and submitted to the OUCME. 
      • Speaker disclosures must be submitted no later than two weeks prior to a CME/CE activity.
  • Unresolved Conflicts of Interest:
    • If a COI is identified for any speaker/activity faculty or planning committee member and cannot be resolved by the mechanisms described above, further action must be taken to prevent the introduction of bias into the activity. Such actions may include: 
      • Removal of the speaker/activity faculty or planning committee member from the activity. e activity.
      • Withdrawal of CME/CE credit for the activity.
  • These requirements are also applicable to a speaker or planning committee member who refuses to disclose financial relationships. These individuals are considered to be in conflict until appropriate disclosures are completed.

Related Documents: 
N/A 

Policy Resources


For assistance with policies and procedures contact:

Dee Dennis
ddennis@pnwu.edu