Safeguarding Educational Content:
Ensuring Independent, Valid, and Commercial Bias-free CME
Learners, patients, the public, and medical professionals expect and demand that continuing medical education activities provide valid content, are evidence-based, and free of commercial bias. This is a core value and priority of the United States and Canadian Academy of Pathology (USCAP).
The Academy protects the integrity of its superb educational program content by strict enforcement of the Accreditation Council for Continuing Medical Education (ACCME) Standards for Commercial Support. USCAP takes the following steps to ensure all CME activities comply with these Standards.
Development and Control of CME Content
Educational activities generated by USCAP are developed and implemented by the Education Committee. These credentialed, respected pathologists exclusively control program content. Presenters, authors, planners and reviewers are instructed to reference evidence or best practices during the planning process and prior to presentation.
Industry has no role in controlling program content or in selecting topics, faculty or course directors, and USCAP does not accept commercial support for any CME activity.
Management of Conflicts of Interest
USCAP expects that everyone (planners, teachers, authors, staff, etc.) who is in a position to control the content of an educational activity will disclose to USCAP all relevant financial relationships with any commercial interest prior to taking an active role in controlling educational content. USCAP has established and implements mechanisms for conflict resolution prior to delivery of the education activity to learners.
- ACCME considers relationships of the person involved in the CME activity to include financial relationships of a spouse or partner.
- Relevant financial relationships are defined by the ACCME as financial relationships in any amount occurring within the past 12 months that create a conflict of interest.
- A conflict of interest occurs when an individual has an opportunity to affect CME content about products or services of a commercial interest with which he/she has a financial relationship.
- An individual who refuses to disclose relevant financial relationships is denied access to control content of an education activity. Individuals divested of such financial relationships are obligated to disclose this status to learners for 12 months.
Members of any USCAP Committee who are in a position to control CME content must disclose such relationships with commercial interests prior to their participation in meetings where decisions are made regarding educational programs (and their content). If any relationship with a commercial interest is deemed relevant, the committee member is expected to recuse him/herself from any discussions and decisions related to the CME activity associated with the relevant relationship. Relevant financial relationships are disclosed to learners.
Management and resolution of speakers’ and authors’ conflicts of interest occurs through peer review by members of the CME Subcommittee (of the Education Committee), who provide feedback and expectations for modification to CME content to be made, if necessary. Effective peer review of content prior to presentation or publication of educational content helps USCAP ensure that content is valid and aligned with the interest of the public. A second tier review of abstracts or papers by individuals with no financial relationships with commercial interests may confer additional protection. In addition, USCAP includes in its COI management process feedback from learners who express need for investigation by assessing objectivity through their evaluations.
Disclosure of Relevant Financial Relationships to Learners
USCAP believes transparency is critical to independent CME and is committed to informing learners if anyone in a position to control CME content has relevant financial relationships with commercial interests. USCAP supports the ACCME’s position that informed learners are final safeguards in assuring that a CME activity is independent from commercial influence.
- The disclosure mechanism identifies if individuals involved in planning or presenting content for a CME activity have financial relationships with commercial interests related to that activity’s content.
- Requiring disclosure of financial interests prior to presentation alerts learners to the possibility of bias, and to the need to evaluate objectivity of the activity in order to characterize further the perceived bias.
- Disclosures are published in meeting materials so that learners are informed prior to the beginning of any CME activity. Disclosures are also projected to learners before the presentations.
Keeping Education and Promotion Separate
USCAP maintains policies on exhibits and commercial promotion associated with educational offerings and takes steps to review and update these polices as the environment and regulations change. USCAP requires that all commercial promotion, including exhibits, is completely separate from USCAP’s education. USCAP requires commercial exhibitors to attest that they have no input into decisions regarding selection of educational programs, program content, or faculty, and that they understand and will comply with exhibitor guidelines.
The Education Committee, CME Subcommittee, Executive Vice President, Education Consultant and operational staff share responsibility for the vigorous investigation, management and documentation of infractions or perceived bias or instances of any promotion detected within USCAP’s education. Assessments from learners, committed volunteers, and skilled staff are final steps to ensure that USCAP’s educational content is independent from commercial interests and free of any commercial bias.