You are the director of CME in an academic institution and have been asked by a communication company to collaborate on an a educational grant they had recently been promised by one of their pharmaceutical company clients. The timeline on this series of dinner meetings around the country and a CD ROM is very short. The grantor recommended your organization because one of yourhas been involved in some of the key research in this area. The company assumes your faculty will be able to assist in completing the needs assessment.
Before you agree to participate, you decide to do some quick checking on any relevant products the grantor might be, and confirm that the faculty member wants to be involved. The communication company agrees to send you some of the information that has already been developed for the live activities and the enduring material. You know the company wants to do the series so that it can focus attention on an as-yet-unapproved use for one of their drugs.
Much of the content appears at first reading to be somewhat biased in favor of the company’s product and your faculty person has been doing research for this same pharmaceutical company for several years and has spoken many times in promotional programs for the company. It is clear from your discussion with your faculty member that she does not understand her responsibilities as your organization’s content expert in this area, and that you have to clarify the differences between her role as faculty in a promotional activity vs. her role in a certified CME activity. She is totally unaware of the risk she might be putting her organization under if she does not follow all of the regulatory guidelines that affect certified CME. The potential revenue for this series of activities you are considering certifying is substantial, and you are late for your budget meeting with your vice-dean to discuss your current budget deficit. You have three days to decide whether to participate.
What actions should you take?
By Joseph Green, Ph.D., Robert E. Kristofco, MSW, and James C. Leist, Ed.D.