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.
A faculty member is confident his financial relationships with ineligible companies aren't relevant to the content of his presentation. Should he still list them on his disclosure form?
We appreciate the confidence, but the ACCME specifies that individuals in a position to control content must disclose all financial relationships with ineligible companies, in any amount, for the last 24 months, regardless of their view of relevance to the education. Advise your faculty member to include all of them, as you are required to determine which ones are relevant.
