How should providers manage individuals who report that they own stock in an ineligible company?

ALL individuals in a position to control content are expected to disclose all financial relationships with ineligible companies within the past 24 months.  What should a provider do if the individual discloses stock ownership?  The answer depends on whether or not the company is publicly traded or privately held.  If the individual owns stock in a privately held ineligible company, they are considered owners or employees and therefore cannot serve in a position that places them in control of accredited CE content (i.e., planners/faculty).  The exception to this would be if the individual were to meet one of the three ACCME exclusions described in Standard 3.2.  If, however, the individual owns stock in publicly traded ineligible company(ies), they are NOT considered to be owners or employees, so may participate in a position to control accredited CE content, so long as the provider takes appropriate steps to mitigate any relationship deemed relevant and disclose the relationship to learners.


Weekly Compliance Tip

What constitutes “non-clinical” education?  

Some good examples of non-clinical education are…

More >


Phone: (303) 557-0859
AOE Consulting, LLC
8156-E S. Wadsworth Blvd.
Suite 198
Littleton, CO 80128