The current ACCME Standards for Commercial Support state that faculty relationships with commercial entities constitute conflicts of interest (COIs), and that ACCME-accredited providers must have policies in place to resolve such conflicts effectively. Of note, the ACCME does not state that faculty with COIs cannot participate in continuing medical education (CME) activities; rather, they require that faculty with such COIs are not in control of the content, and that an effective mechanism is in place to ensure that such COIs do not influence the content of the program. Clinical Care Options (CCO) jointly sponsors CME activities with accredited providers.
Following extensive discussions with ACCME, Clinical Care Options has adopted the following procedures for developing medical education programs, to ensure that faculty COIs are effectively resolved prior to submitting the content to the accredited provider for review and approval:
1. The CCO editorial team exercises final control over the selection of faculty, topics, and final content for each CME program. The CCO editor in control of the content for a continuing education activity will not have any personal conflicts of interest with the supporter(s) for that CME program. The faculty and members of the content review process are selected by CCO, with no input from the commercial supporter.
2. Faculty members are instructed to restrict their material to evidence-based discussion of the topic in question. Where there is debate in the field, competing points of view should be presented, and any expressions of the author's opinion (as opposed to fact) must be clearly identified as such, and the data that lead the author to hold that opinion must be discussed and referenced.
3. To resolve faculty COIs, the draft content for all continuing education activities is peer-reviewed by an independent reviewer with appropriate expertise in the content matter. Peer reviewers are instructed to ensure that the content is evidence based, objective, balanced, and free from commercial bias. Peer reviewers may not themselves have any COI with the commercial supporter of the activity in question or any other pharmaceutical company actively involved in the specialty area. The editorial team then works with the author to ensure that peer review comments are all addressed in the final content.
4. Specific record is kept of peer review comments, and the steps taken by the editorial team in conjunction with the author to address their comments. Both the final draft of the content, and this documentation of the peer review process and revisions, is reviewed by the specialty Editorial Director and/or the CCO Vice-President, Editorial prior to submission to the accredited provider. The material is only submitted to the accredited provider for certification after the CCO specialty Editorial Director and/or the CCO Vice-President, Editorial is satisfied both that the material is evidence-based, objective, balanced, and free from commercial bias, and that the peer review and faculty recommendations were adequately addressed.
5. Finally, as required by the ACCME, the accredited provider is responsible for undertaking its own final review of content to ensure that it is balanced and lacks any commercial bias.