VP&S Continuing Medical Education (CME)

Conflict of Interest Policy

Overview/Rationale

This policy ensures that all Continuing Medical Education (CME) activities at VP&S are independent, transparent, and free from commercial bias. The policy:

Meets Accreditation Council for Continuing Medical Education (ACCME) Standard 3: Identify, Mitigate, and Disclose Relevant Financial Relationships, which requires proactive disclosure, mitigation, and communication of financial conflicts of interest.
Complies with Liaison Committee on Medical Education (LCME) Standard 1.2 (Conflict of Interest Policies), which requires medical schools to have policies and procedures that effectively address conflicts of interest in the medical education program.

Together, these standards safeguard the integrity of medical education, foster public trust, and protect learners from undue influence.

Accreditation Standards

ACCME Standard 3: All CME activities must identify, mitigate, and disclose relevant financial relationships.
LCME Standard 1.2: Medical schools must have and enforce conflict of interest policies for individuals who participate in medical education, including CME. These policies must ensure that decisions affecting the education program are free from undue influence.

Stakeholders

This policy applies to all individuals involved in CME activities, including (but are not limited to):

Planners, moderators, speakers, content reviewers, activity directors, writers/authors of enduring materials, authors of research articles who present the research in an accredited CME activity, committee members, editors, staff and any individual controlling educational content.
Administrators and institutional leaders overseeing CME operations.

Definitions

Ineligible Company: Companies that are ineligible to be accredited in the ACCME System (ineligible companies) are those whose primary business is producing, marketing, selling, re-selling, or distributing healthcare products used by or on patients.
Relevant Financial Relationship: Relevant financial relationships are financial relationships of any amount with ineligible companies if the educational content is related to the business lines or products of the ineligible company.
Conflict of Interest (COI): A situation where an individual’s financial or personal interests may compromise, or appear to compromise, their role in CME.

Policy

Identification
- All persons controlling CME content must disclose all financial relationships with ineligible companies within the previous 24 months using the VP&S disclosure form or other verifiable methods. There is no minimum financial threshold; individuals must disclose all financial relationships, regardless of the amount, with ineligible companies. Individuals must disclose regardless of their view of the relevance of the relationship to the education.
- Review the information about financial relationships to determine which relationships are relevant. Financial relationships are relevant if the educational content an individual can control is related to the business lines or products of the ineligible company.
Exclusions
- Owners or employees of ineligible companies are prohibited from controlling content or participating as planners or faculty in accredited education, except under limited ACCME-defined circumstances (e.g., basic science methodology, non-clinical roles).
- Individuals who own stock (not through a mutual fund or pension plan) in privately held ineligible companies are considered owners or employees and therefore must be excluded from controlling content or participating as planners or faculty in accredited CE, unless they meet the exceptions to the exclusion.
- Individuals who own stock in publicly traded ineligible companies are not considered owners or employees.
Mitigation
- Relevant financial relationships must be mitigated before the individual assumes their role. Steps taken to mitigate relevant financial relationships must be appropriate to the role of the individual and must be documented. Some examples of mitigation strategies include:
  - Recusal from relevant decisions
  - Independent peer review of content

Learners must receive disclosure in a verifiable format prior to participation. This includes:

Names of individuals with relevant relationships
Names of the ineligible companies with which they have relationships and nature of relationship(s)
A statement that all relevant financial relationships have been mitigated.
Disclose absence of relevant financial relationships: Inform learners about planners, faculty, and others in control of content (either individually or as a group) with no relevant financial relationships with ineligible companies.

Identify ineligible companies by their name only: Disclosure to learners must not include ineligible companies’ corporate or product logos, trade names, or product group messages.

Procedures

Collection of disclosures before activity planning begins.
Review of disclosures by the provider to determine relevance.
Mitigation of conflicts with documented strategies.
Documentation of Mitigation, submitted to the CME office by planners/coordinators.
Disclosure to learners in written or digital form.
Archiving records for compliance review (minimum six years).

Quality Improvement

Biennial review of CME COI processes by the CME Office and Vice Dean for Education
Alignment of COI compliance with LCME and ACCME accreditation review cycles.

Policy History/ Approval Date: The CME Conflict of Interest policy was taken from print-version of handbooks and online formats.  These documents were reformatted and codified into policy where specific procedures and edits were added.  The policy was reviewed and approved by the Committee on Educational Policy and Curriculum on September 12, 2028.