Using ACCME’s Flowchart for Identifying and Resolving Personal Conflicts of Interest

ACCME requirements are designed to ensure that accredited continuing medical education (CME) provides a safe place for learning—independent of commercial interests and commercial influence. We prepared this tutorial and flowchart to help you navigate the identification of relevant financial relationships and the resolution of conflicts of interests in CME activities.

Use of these resources is optional. Please note that the tutorial and flowchart do not address all of the expectations of ACCME requirements for independence from commercial interests. 

Ensuring Independence

ACCME expects accredited organizations to ensure independence by: 

  1. Identifying relevant financial relationships between commercial interests and those who plan, teach, and implement CME
  2. Resolving conflicts of interest that arise when those with relevant financial relationships with commercial interests have the opportunity to control CME content related to the products or services of those commercial interests
  3. Disclosing to learners the (identified) relevant financial relationships for those in control of CME content prior to the educational activity or disclosing that there were no relevant financial relationships.

These expectations are laid out in Standards 1, 2, and 6 of ACCME’s Standards for Commercial Support: Standards to Ensure the Independence of CME Activities.

Let’s Get Started

Please note: PDF and PowerPoint versions of the flowchart are available here.
 
Start early! Use this flowchart early in your planning process to make sure you can implement your approaches to ensure independence during the planning process and before the educational activity occurs.
 
Begin on the upper left corner of the flowchart at A.
 

Is the content of the CME activity related to the products or business lines of an ACCME-defined commercial interest

If your answer is “yes,” proceed to B.

If your answer is "no," there are no relevant financial relationships to identify. Before the CME activity, disclose to learners that there are no relevant financial relationships with ACCME-defined commercial interests for anyone who is in control of the content of the activity. The flowchart ends here—you’re done!

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Helpful Tip: Make sure that you are using the correct definition of a commercial interest in your processes and forms. Otherwise, you may not get the information you need to ensure independence from commercial interests.

Beginning at B, use the flowchart for each person in control of the content of the CME activity. These may include planning committee members, staff, authors, content reviewers, and faculty.

Is the person an employee/owner of an ACCME-defined commercial interest?

If the answer is “no,” proceed to C.

If the answer is “yes,” proceed no further. Employees of ACCME-defined commercial interests are prohibited from having any role in the planning or implementation of CME activities related to the commercial interest’s business lines or products. (There are a few special-use cases where employees may have a specific, limited role.)

Helpful Tip: Have you checked for relevant financial relationships for all persons in control of content? Don’t forget staff, reviewers, and planning committee members in addition to authors and speakers/presenters.

Does the person have a relevant financial relationship with an ACCME-defined commercial interest?

The flowchart provides a four-question checklist to determine whether a relevant financial relationship exists—per ACCME expectations—therefore creating a conflict of interest. A relevant financial relationship exists only if you affirm all four statements.

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