Tips on Complying with the Updated Standards for Commercial Support

What Else Needs to Be Disclosed

Once you have identified and tweaked current procedures, panel members suggested that you ask what else might be needed. For example, ACOG now requires that the committee meetings be documented in writing. The organization also developed a new disclosure form that includes an agreement to abide by ACOG's code of ethics.

The American Academy of Ophthal-mology now requires disclosure from everyone who could affect content, said William Hering, PhD, director of CME and Programs with the San Francisco — based AAO. And they have to disclose not only any financial relationships they have, but also those of their business partners, employers, and families, including their spouse, domestic partner, parent, child, and spouse of a child, and siblings and siblings' spouses. (The scope of disclosure brought some gasps from the audience.) The AAO put its disclosure form online, where relevant CME stakeholders can pick from a drop-down menu the pharma/device companies with which they have relationships.

The disclosure statements stay online, which caused some discussion among the participants about privacy issues for nonpresenters. “We want to be sure that everyone who needs to know, knows everything,” said Hering.

The question of who has to go public with disclosures, as opposed to disclosing just to the provider, was a hot, albeit unresolved, issue at one of the breakout sessions. AAO sends the disclosures to a committee of peers to review for relevance to an activity. It also has a peer-review committee for enduring materials. If, after a warning, someone doesn't disclose, they are barred from participation in that activity. The academy also uses a “Documentation Checklist for CME Activities” form similar to the ACCME surveyors' form that must be completed before the activity can move forward.

To ensure bias doesn't creep into live activities, AAO notifies the chair, faculty, and panelists that the first slide has to contain disclosure of any financial relationships, and it has monitors scouting the content at its annual meeting.

The Society of American Gastro-intestinal Endoscopic Surgeons also made some changes, including changing the software it uses for abstract submission, so disclosures have to be complete or the abstract won't be accepted for review, said Erin Schwarz, manager, programs and education, with the Los Angeles — based SAGES. The submissions then go through a blind selection process, followed by one including disclosures. A volunteer task force reviews the disclosures to see if they relate to the presentation's content.