The Case

Teri Taintor is managing director of Health First Communication Co. (HFCC), an accredited provider. One year ago, she was promoted to the position after serving as senior project manager — a tremendous promotion given her young age and few years in the business. Teri has assembled a highly talented group of writers and editors with PharmD and PhD degrees to develop content and interact with faculty for the company's certified educational activities.

For the last several months, business has slumped and Teri has grown concerned, especially since her performance review with the CEO is scheduled in two months. She is thrilled when HFCC receives a $95,000 grant from Make-It-Better Pharmaceuticals to produce an enduring material on treating growth hormone deficiency. Deidre Daring, PharmD, has been assigned as lead writer for this monograph; she will assist world-renowned endocrinologist Everett P. Tuitary on the content. When reviewing his Full Disclosure Form, Deidre notes that Dr. Tuitary has several types of relationships with a single commercial interest, Make-It-Better Pharma. When Deidre mentions this to her manager, Teri assigns another writer to “peer review” the content before having the monograph certified for credit and distributed to the target audience.

Second Opinions Needed

Is content review by an employee of the provider adequate in terms of peer review?

Overstreet: Peer review is increasingly being used as a mechanism to resolve conflict of interest. I think some providers are having their staff provide “peer review,” but I don't think this really gets the job done. While it is important for a provider's staff to ensure the accuracy of content — for example, to fact-check content against cited references — they can't really be “peer” reviewers.

Parochka: I couldn't agree more, Karen. Providers should adopt additional mechanisms to validate the content as fair, balanced, and scientifically rigorous.

Is there a conflict between the employee reviewer and her boss? Between the provider and the grantor?

Overstreet: There could certainly be important conflicts in this scenario. For instance, the staff reviewer could be frightened of disappointing her supervisor by finding bias or inaccuracies in the document. Teri could be feeling pressured to get additional grants from this supporter, and so she might be hesitant to identify or correct bias.

Parochka: Providers should create a culture in which staff members are able speak freely so the CME provider, commercial supporter, and physician participants are assured that content is free of bias.

How can providers help ensure that content is accurate and fair-balanced?

Parochka: Using external peer review sources can safeguard against the presentation of biased content.

Overstreet: Yes, and those reviewers should be free of conflicts of interest themselves — they need to disclose financial relationships just as faculty and planners do.

Parochka: Asking participants to evaluate certified offerings is the final step in the educational process and should validate/confirm that external peer reviewers did their job.

Karen Overstreet, EdD, RPh, FACME, is president, Indicia Medical Education LLC, North Wales, Pa. Reach her at

Jacqueline Parochka, EdD, FACME, is president and CEO, Excellence in Continuing Education Ltd., Gurnee, Ill. Reach her at

Your Views Welcome / To share your comments on this case, or if you have an “ethical hypothetical” you'd like reviewed, send an e-mail to Editor Tamar Hosansky at