How can we mitigate a presenter's relevant financial relationships if she submits her content late?
Is the content "late," or is it simply past your internal deadline? Content delivered to the accredited provider behind schedule but prior to delivery to learners is a logistical snag, but not necessarily non-compliant. Solutions might include:
- An expedited content review by an individual with the appropriate clinical credentials and no relevant financial relationships with ineligible companies
- An expedited review by a planner with no relevant financial relationships, to check for any glaring compliance issues
- Onsite review prior to delivery to screen for any compliance issues (if the activity is live)
How do we mitigate a planner's financial relationships with ineligible companies?
Institute a process and documentation to demonstrate that the planning team took efforts to screen the planner's decisions and contributions for bias. This might include:
- Directing a colleague with no financial relationships to check the planner's work for bias
- Limiting the planner's role (e.g., they focus on educational design but do not participate in faculty selection)
- Removing the planner from their role and replacing them with a qualified individual
In all cases, ensure you document the process so that you can reference it for annual reporting, record retention, and potential audit/reaccreditation purposes.
