An individual received a brochure from an accredited provider for an upcoming course and forwarded the brochure to the ACCME, pointing out that one individual who was listed as being a faculty member was also an employee of a company that produces products related to the activity content.
The ACCME sent a Letter of Inquiry to the accredited provider asking about its compliance with Standard for Commercial Support 1: Independence. The ACCME asked about the process the provider used to select faculty for the activity and if the provider has a process in place for identifying whether commercial interest employees are involved in controlling content related to their company's business lines and products. The ACCME also requested copies of the educational material provided to the learners during this activity.
The provider submitted all requested information. However, the provider did not present evidence to demonstrate that the activity was planned free of the control of commercial interests.
- One of the speakers, Dr. Rose(1), is an employee of an ACCME-defined commercial interest.
- During at least one of Dr. Rose’s presentations, s/he discussed content related to the company's business lines and products.
- As an employee of XYZ Pharmaceuticals, Dr. Rose is directly involved in the development of a new therapy related to the activity content.
The provider was not in compliance with Standard 1.1 in the ACCME’s Standards for Commercial SupportSM. Under SCS 1.1, employees of a commercial interest cannot control CME content related to the business lines and products of their employers. The ACCME issued a Notice of Noncompliance.
In response to this Notice of Noncompliance, the provider was asked to submit a Notice of Corrective Action within 30 days. The provider did so and explained in its Notice of Corrective action that 1) It was unaware that an employee of a commercial interest may not deliver content related to its business lines and products, and 2) that it has adopted new policies to disallow employees of commercial interest from delivering content related to their employers' business lines and products, and 3) modified its internal forms to collect information on whether faculty members are employed by a commercial interest.
A letter was then sent to the accredited provider indicating that the matter was closed. The ACCME will review the information pertinent to the complaint at the time of the next reaccreditation review to confirm that it continues to comply with ACCME requirements.
(1) Names have been changed.