The use of employees of ACCME-defined commercial interests as faculty and planners or in other roles where they are in a position to control the content of accredited CME is prohibited, except in the specific situations identified by the ACCME that maintain independence and serve the public interest.
To support your compliance, we have produced this tutorial page, which includes links to FAQs, case examples, videos, and other resources. Please review the relevant resources before you make decisions about the involvement of employees of ACCME-defined commercial interests in your activities. If you have any questions or concerns, please contact us at firstname.lastname@example.org.
The prohibition against allowing employees of ACCME-defined commercial interests to control the content of accredited CME falls under Standard for Commercial Support 1: Independence. Employees have fiduciary responsibility to their employers, creating a conflict of interest that cannot be resolved. Employees are in a different category than those who have relevant financial relationships. Therefore, when involving employees of ACCME-defined commercial interests in accredited CME, providers must follow the guidance described in the resources below to ensure independence. The strategies used to address relevant financial relationships, as stipulated in Standard 2: Resolution of Personal Conflicts of Interest, will not be sufficient to demonstrate compliance when involving employees of ACCME-defined commercial interests.
In every activity, accredited CME providers must comply with all applicable accreditation requirements including the Accreditation Criteria, ACCME Standards for Commercial Support: Standards to Ensure the Independence in CME ActivitiesSM, and Policies.
Definition of ACCME-Defined Commercial Interest
- Definition of ACCME-defined Commercial Interest. The ACCME expanded the definition of commercial interest in 2007. Please make sure you use the current definition in your policies and forms, including disclosure forms. This is a key first step to ensuring that you are identifying employees of ACCME-defined commercial interests.
Ask ACCME Questions
- Are there any circumstances when employees of ACCME-defined commercial interests can be in a position to control the content of accredited CME?
- Can accredited CME include oral presentations or written reporting of scientific research (e.g., abstracts) conducted by ACCME-defined commercial interests?
- Can accredited CME activities that train on the use of medical devices or equipment include employees of ACCME-defined commercial interests?
- Can an accredited provider ask a commercial interest for suggestions related to topics or speakers for CME?
- At our annual meeting, we have sessions that include procedure-based training using surgical devices. We sometimes use technical representatives who are employees of device companies to demonstrate the equipment from their firms under the supervision of our own faculty. Is it permissible for those employees to wear clothing that includes their company logo during the demonstration?
Provider Examples of Compliance and Noncompliance
- The Role of Commercial Interest Employees in CME
- Role of Commercial Interest Employees as Speakers in CME Activities
Other Related Resources
- Tutorial: Resources for Implementing the Standards for Commercial Support
- News Release: Ask ACCME Questions about Independence in Accredited CME
- News Release: ACCME Releases Additional Guidance on Role of Commercial Interest Employees in CME
- Compliance Reminders — Standards for Commercial Support: Standards to Ensure Independence in CME Activities℠
If you have further questions about the appropriate use of employees of ACCME-defined commercial interests in accredited CME, please contact us at email@example.com.