ANA Financial Disclosure Policy

The American Neurological Association is accredited by the Accreditation Council for Continuing Medical Education (ACCME) to provide continuing medical education for physicians. As such, we must comply with the ACCME’s polices governing the planning and implementation of continuing medical education, as well as adhere to policies surrounding conflicts of interest. To follow is some helpful information, definitions and policies to aid us in this quest and to assist you in understanding your critical role in our collective success.

Definition of CME: Continuing medical education consists of educational activities which serve to maintain, develop, or increase the knowledge, skills, and professional performance and relationships that a physician uses to provide services for patients, the public, or the profession. The content of CME is that body of knowledge and skills generally recognized and accepted by the profession as within the basic medical sciences, the discipline of clinical medicine, and the provision of health care to the public.

Content Validity: As a provider of continuing medical education (CME) accredited by the ACCME, we have a policy of ensuring that the content and quality of educational activities are balanced, independent, objective, and scientifically rigorous. The scientific content of this activity was developed under the supervision of the Planning Committee, according to the following specifications:

  1. All the recommendations involving clinical medicine in a CME activity must be based on evidence that is accepted within the profession of medicine as adequate justification for their indications and contraindications in the care of patients.
  2. All scientific research referred to, reported, or used in CME in support or justification of a patient care recommendation must conform to the generally accepted standards of experimental design, data collection and analysis.
  3. Providers are not eligible for ACCME accreditation or re-accreditation if they present activities that promote recommendations, treatment, or manners of practicing medicine that are not within the definition of CME, or known to have risks or dangers that outweigh the benefits or known to be ineffective in the treatment of patients. An organization whose program of CME is devoted to advocacy of unscientific modalities of diagnosis or therapy is not eligible to apply for ACCME accreditation.

Statement of Independence: We must rigorously review the content or format of all CME activities and/or related materials to ensure they promote improvements or quality in healthcare and not a specific proprietary business interest of a commercial interest, as well as to confirm that presentations give a balanced view of therapeutic options. Use of generic names will contribute to this impartiality. If the CME educational material or content includes trade names, where available trade names from several companies must be used, not just trade names from a single company.  

The following highlights our policy for identifying and resolving conflicts of interest and to ensure all CME activities meet the requirements as outlined above.

Purpose: The existence of any financial relationship or interest an individual in a position to influence/control content currently has, or has had, within the last year must be disclosed in writing to learners prior to presentation. Disclosure information must be received and reviewed by CME Provider prior to confirmation of the individual’s participation. Any conflicts of interest must be identified and resolved prior to the individual’s confirmation as an activity faculty or other content-influencing/controlling role. The intent of this policy is not to prevent individuals from participating, but rather is to identify and resolve any conflict of interest. 

Because the review, identification, and resolution process must take place prior to the activity, all individuals in a position to influence/control content must return the disclosure information by the due date. The disclosure will be reviewed and, should a conflict be identified, additional information or dialogue may be required. Failure to disclose within the necessary time-frame will result in withdrawal of the invitation to participate. Acknowledgement of all disclosures—i.e., nothing to disclose or existence of affiliation(s), and/or financial relationship(s) or interest(s)—for every individual who serves in a position to influence/control content of the educational activity must be presented in writing to the learners.

Method: All persons (planners, reviewers and faculty/presenters) in position to control the content of this activity are required to disclose any relevant financial relationships (including those of a spouse/partner) occurring within the last 12 months with any commercial interests (as defined by the ACCME) to the provider. Each individual faculty/planner/author/editor/reviewer/staff must complete and return his/her disclosure paperwork. We will proceed through a review of the submitted information and, should any of the disclosed information trigger a concern regarding a possible conflict of interest, reviewers may seek input from the candidate and/or other individuals prior to confirming the candidate’s service. Failure or refusal to disclose, false disclosure, or inability to work with us to resolve an identified conflict of interest will result in withdrawal of the invitation to participate and replacement of the faculty/planner. Should no conflict of interest be identified, the individual may be confirmed in their role in the activity.

Should a conflict of interest be identified, the individual will be contacted and asked for clarification or additional information. Upon receipt and review of this additional information, methods of resolution will be identified and discussed with the individual. Resolution methods may include, but not be limited to, one or more of the following:

  • Peer review of content
  • Assign different faculty
  • Cancellation of the session
  • Disqualification of faculty

Definitions: A commercial interest is any entity producing, marketing, re-selling, or distributing health care goods or services consumed by, or used on, patients. The ACCME does not consider providers of clinical service directly to patients to be commercial interests. 

(http://www.accme.org/requirements/accreditation-requirements-cme-providers/policies-and-definitions/definition-commercial-interest)

Financial Relationships and Conflicts of Interest
Financial relationships are those relationships in which the individual benefits by receiving a salary, royalty, intellectual property rights, consulting fee, honoraria for promotional speakers’ bureau, ownership interest (e.g., stocks, stock options or other ownership interest, excluding diversified mutual funds), or other financial benefit. Financial benefits are usually associated with roles such as employment, management position, independent contractor (including contracted research), consulting, speaking and teaching, membership on advisory committees or review panels, board membership, and other activities from which remuneration is received, or expected. ACCME considers relationships of the person involved in the CME activity to include financial relationships of a spouse or partner. The ACCME has not set a minimum dollar amount for relationships to be significant. Inherent in any amount is the incentive to maintain or increase the value of the relationship. With respect to personal financial relationships, contracted research includes research funding where the institution gets the grant and manages the funds and the person is the principal or named investigator on the grant.

Conflict of Interest: Circumstances create a conflict of interest 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. The ACCME considers financial relationships to create actual conflicts of interest in CME when individuals have both a financial relationship with a commercial interest and the opportunity to affect the content of CME about the products or services of that commercial interest. The ACCME considers “content of CME about the products or services of that commercial interest” to include content about specific agents/devices, but not necessarily about the class of agents/devices, and not necessarily content about the whole disease class in which those agents/devices are used. With respect to financial relationships with commercial interests, when a person divests themselves of a relationship it is immediately not relevant to conflicts of interest but it must be disclosed to the learners for 12 months.

(http://www.accme.org/requirements/accreditation-requirements-cme-providers/policies-and-definitions/financial-relationships-and-conflicts-interest)

Please contact Jen.Hurley@e4enterprise.com, if you have any questions.