In 1990, an
inter-organizational task force, the Task Force on CME
and Industry Collaboration, was formed to foster
better informed collaboration between commercial supporters
and all major accredited sponsors of continuing medical
education. Included in the membership of the Task Force on CME
and Industry Collaboration are senior staff members of major
pharmaceutical and device manufacturers, and leaders of
continuing medical education in the United States.
The Task Force has blended the diverse
knowledge, interests, and talents of its members to produce
these Guidelines which address all aspects of continuing
medical education, not just relationships with commercial
supporters.
These Guidelines will provide a credible standard to which the
health professions may compare their criteria for accrediting
continuing medical education. The AOA believes that much
mutual benefit will flow from the unity among the professions
through application of these policies and procedures.
The AOA has adopted, with minor changes, the Uniform
Guidelines for Accrediting Agencies of Continuing Medical
Education. These Uniform Guidelines have been adopted as a
part of the Continuing Medical Education Guide of the American
Osteopathic Association.
Although members of the Task Force are associated with most of
the major players in the CME and the health-related commercial
interests in the U.S., the Task Force has no official status
in government, industry, or education.
The AOA Council and its staff members
are available to help with interpretation of the task force
actions and implementation of the AOA guidelines.
I. Introduction
The purpose of continuing medical education (CME) is to
enhance the physician's ability to care for patients. It is
the responsibility of the accredited sponsor of a CME activity
to assure that the educational activity is designed primarily
for that purpose.
Accredited sponsors often receive financial and other support
from commercial organizations. Such support can contribute
significantly to the quality of CME activities.
The purpose of the "Uniform Guidelines" is to
describe appropriate behaviors expected of accredited sponsors
in planning, designing, implementing, and evaluating CME
activities. Further, the "Uniform Guidelines" apply
to those continuing medical education activities for which an
accredited sponsor receives commercial support.
II. Management of CME
Activities
A. Mission Statement
An accredited sponsor shall define the role, scope and
intended audience of its educational functions by having a
written statement of its CME mission formally approved by its
governing body.
B. Management Support
An accredited sponsor shall provide evidence that management
procedures and other necessary resources are available and
effectively used to fulfill its CME mission.
C. Joint Educational Activities
An accredited sponsor that provides educational activities
jointly with a non-accredited entity shall assure that such
activities are conducted entirely according to these
"Uniform Guidelines".
D. Enduring Materials
An accredited sponsor that offers instructional materials,
that in themselves constitute a planned activity of CME, shall
develop and administer those materials entirely according to
these "Uniform
Guidelines."
E. Funding Arrangements
The ultimate decision regarding funding arrangements for CME
activities must be the responsibility of the accredited
sponsor. Funds from a commercial source should be in the form
of an educational
grant for the support of programming made payable to the
accredited sponsor. The terms of the grant must be set forth
in a written agreement. There shall be no other funds paid to
faculty, CME
program directors, or others involved with the supported
program except as provided in the written agreement. All
support associated with an educational activity must be made
under the direction of, and with the full knowledge and
Approval of, the accredited sponsor.
Payment of reasonable honoraria and reimbursement of
out-of-pocket expenses for faculty is customary and proper.
Commercial support must be acknowledged in printed
announcements and brochures; however, reference must not be
made to specific commercial products. Following the CME
activity, upon request, the accredited sponsor must be
prepared to report to each commercial supporter, information
concerning the expenditure of funds each has provided.
F. Marketing CME Activities
A CME sponsor may authorize a commercial supporter to
disseminate to the medical community information about a CME
activity. However, the content of such information must always
be
explicitly approved by, but not necessarily prepared by, the
accredited sponsor, and must always identify the educational
activity as produced by the accredited sponsor.
G. Expenses for Attendees
In connection with an educational activity, it is not
permissible to use funds originating from a commercial source
to pay travel, lodging, registration fees, honoraria, or
personal expenses for non-faculty attendees. Subsidies for
hospitality should not be provided outside of modest meals or
social events that are held as a part of the educational
activity.
Scholarship or other special funding to permit medical
students, interns, or residents and fellows to attend selected
educational conferences may be provided, as long as the
selection of students,
interns or residents and fellows who will receive the funds is
made either by the academic or training institution, or by the
accredited sponsor, with the full concurrence of the academic
or training
institution.
III. Educational Standards and Practices
A. Needs Assessment
An accredited sponsor shall systematically identify the CME
needs of prospective participants and use that information in
planning CME activities.
B. Objectives
An accredited sponsor shall, for each CME event, develop
objectives based on identified educational needs.
C. Educational Design
1. Objectives
Influence Design An accredited sponsor shall use the
objectives developed for an educational activity to select the
content, and design the educational methods, for that
activity.
2. Basic
design requirements for CME activities In designing
educational activities, the accredited sponsor must assure
that the activities have the following characteristics:
They must be free of bias for or
against any commercial
product;
They must be designed and produced so
that content
and educational methods are ultimately determined by
the accredited sponsor;
If the activities are concerned with
commercial products,
the program must present objective information about
such products based on scientific methods generally
accepted in the medical community.
3. Independence
of Accredited Sponsors The design and production of
educational activities shall be the ultimate responsibility of
the accredited sponsor. Commercial supporters of such
activities shall not control the planning, content or
execution of the activity. To assure compliance with the
"Uniform Guidelines" the following requirements must
be adhered to:
a.
Help
with the preparation of educational materials
The content of slides and reference materials must remain the
ultimate responsibility of the faculty of
accredited sponsor. This responsibility may be shared with the
faculty of the accredited sponsor. The accredited sponsor may
ask a commercial supporter to help with the preparation of
conference related educational materials, but these shall not
specifically promote the proprietary interests of the
commercial supporter.
b.
Assistance
with Educational Planning
An accredited sponsor must maintain responsibility for and
control over the selection of content, schedule, faculty,
attendees, and educational methods and materials in all of its
CME activities.
An accredited sponsor may obtain information that will assist
in planning and producing an educational activity from any
outside source whether commercial or not. However, acceptance
by an accredited sponsor of advice or services concerning
speakers, invitees or other educational matters, including
content, shall not be among the conditions for the provision
of support by a
commercial organization.
c. Distribution of advertising
No commercial promotional materials shall be displayed or
distributed in the same room immediately before, during, or
immediately after an accredited educational activity.
Representatives of commercial supporters may attend an
educational activity for which they have provided support, but
may not engage in sales activities while in the room where the
educational activity takes place.
d. Exhibits
When commercial exhibits are part of an overall program,
arrangements for these must not influence
educational planning or interfere with the presentation of CME
activities. Exhibit placement must not be a condition of
support for a CME activity.
e. Proprietary Names of Products
While the use of proprietary names of products is permissible
during educational activities, generic names should be used by
the faculty whenever possible. Moreover, it is the
responsibility of the accredited sponsor to assure that
presentations give a balanced view of diagnostic, therapeutic,
or appliance options. If proprietary names are used, those of
several companies that make relevant products must be used
rather than only those of a single company.
IV. Other Guidelines for
Relationships between Accredited Sponsors and Commercial
Supporters of CME
A. Communicating Results of
Scientific Research
Objective, rigorous, scientific research conducted by
commercial companies is an essential part of the process of
developing new pharmaceutical or other medical products or
devices. It is highly
desirable that direct reports of such research be communicated
to the medical community. An offer by a commercial supporter
to provide a presentation reporting the results of scientific
research shall be accompanied by a detailed outline of the
presentation which shall be used by the accredited sponsor to
confirm the scientific objectivity of the presentation. Such
information must conform to the generally accepted standards
of experimental design, data collection and analysis.
B. Disclosure
An accredited sponsor shall have a policy requiring disclosure
of the existence of any significant financial interest or
other relationship a CME faculty member or the sponsor has
with the manufacturer(s) of any commercial product(s)
discussed in an educational presentation. All approved
CME activities shall conform to this policy.
Such faculty or accredited sponsor relationship with
commercial supporters shall be disclosed to participants prior
to educational activities in brief statements in conference
materials such as brochures, syllabi, exhibits, poster
sessions and post meeting publications.
In the case of a regularly scheduled event, such as grand
rounds, disclosure shall be made by the moderator of the
activity after consultation with the faculty member or a
representative of the
accredited sponsor. Written documentation that disclosure
information was given to participants shall be entered in the
file for that activity.
C. Off-label uses of products
When an off-label use of a product, or an investigational use
not yet approved for any purpose, is discussed during an
educational activity, the accredited sponsor shall require the
speaker to disclose that the product is not labeled for the
use under discussion, or that the product is still
investigational. Discussions of such uses shall focus on those
uses that have been subject of objective investigation.
D. Activities that are repeated many times
An accredited sponsor that offers educational activities that
repeat essentially the same information each time they are
given, must demonstrate that every iteration of that activity
meets all of the
provisions found in these "Uniform Guidelines."
E. The accredited sponsor's use of
educational activities or materials prepared by organizations
other than the accredited sponsor
When an accredited sponsor offers an educational activity
based on concepts or materials prepared by an outside
organization, that activity must adhere to these "Uniform
Guidelines" in all respects,
especially in regards to the provisions concerning the
independence of the accredited sponsor in planning, designing,
delivering, and evaluating all of its educational activities
offered for credit.