Do I need to replace an individual that has relevant financial relationships with ineligible companies?
Not necessarily. Depending on the individual's specific role, there are various mitigation tactics you can use to ensure the individual doesn't weave commercial bias into accredited CE content. Effective approaches can include a peer review of planning decisions, an independent content review, a formal reminder of policies and instructions, or limiting the individual's role. Replacement is a last resort.
Do we need to take stocks into account when reviewing someone's financial relationships?
Yes. Stock information will help you determine if an individual should be considered an "owner" of an ineligible company, and whether they can participate in your accredited CE activity. According to the ACCME:
- An individual that owns stock in a publicly traded ineligible company is NOT considered an owner.
- An individual that owns stock in a privately traded ineligible company IS considered an owner (but those who simply have stock options in the company are not).
If you determine that the individual is an owner, you must exclude him/her from participating in your accredited CE activity. There are three special (and rare) exceptions, which you can read about here.
