Call for Comment Regarding Disclosure of Commercial Support

Open for comment on : 
April 21, 2011
Closed on: 
June 6, 2011

The ACCME sought comment on a proposal that would prohibit the use of corporate logos and the mention of corporate divisions in disclosures of commercial support. This Call for Comment opened on April 21, 2011 and closed on June 6, 2011.

An audio commentary with ACCME Chief Executive, Murray Kopelow, MD, explaining the call for comment is available here.

A report including the responses as well as the ACCME's analysis of the responses is available here.

The full text of the Call for Comment was as follows:

Call for Comment -- Disclosure of Commercial Support

The ACCME is seeking comment on a proposal that would prohibit the use of corporate logos and the mention of corporate divisions in disclosures of commercial support. 

The ACCME Standards for Commercial Support and related policies are designed to ensure that accredited CME activities are independent, free from commercial influence, and serve the public interest. The Standards for Commercial Support create a firewall between accredited continuing medical education and industry promotion.

This call for comment relates to Standard 6 in the Standards for Commercial Support, which says that providers must disclose to learners the sources of commercial support.

SCS 6.3 The source of all support from commercial interests must be disclosed to learners. When commercial support is ‘in-kind’ the nature of the support must be disclosed to learners.

SCS 6.4 'Disclosure’ must never include the use of a trade name or a product-group message.

Current ACCME policy related to commercial support disclosure reads:

"The provider’s acknowledgment of commercial support as required by SCS 6.3 and 6.4 may state the name, mission, and areas of clinical involvement of the company or institution and may include corporate logos and slogans, if they are not product promotional in nature."

In response to provider feedback and to strengthen the firewall between accredited continuing medical education and promotion, the ACCME is proposing a change in policy to prohibit the use of corporate logos or the mention of corporate divisions in commercial support disclosure statements. For example, if XYZ Pharmaceuticals is the commercial supporter, the accredited provider’s disclosure could not include XYZ Pharmaceuticals’ logo, slogan, or tagline, or a reference to any of its corporate units, such as a medical education division.

The ACCME is seeking comment from the public and the CME enterprise about adopting the following policy.

“The provider’s acknowledgment of commercial support as required by SCS 6.3 and 6.4 under Standard 6 of the ACCME Standards for Commercial SupportSM must only state the name of the company supplying the commercial support, in text format only. Disclosure cannot contain corporate logos and cannot mention or describe any other units within the commercial interest’s corporate structure.”

Audio Commentary

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