Policies

Policy

With consideration to the recommendation for the Committee, the chair and Committee members’ appointment will be made by the Dean of the College of Medicine.

Procedures

• The term of appointment is two years with the option of renewal without limit.
• Committee members will complete a disclosure annually. No one will be permitted to serve on the Committee if they refuse to disclose.
• If a member has a conflict of interest concerning a CPD educational activity, the member will recuse them self from reviewing the activity application.
• If a Committee member elects to discontinue service on the Committee, another committee member will be appointed.
• If a Committee member does not attend or review CPD applications for one fiscal year, the member is contacted to see if they want to remain a member. If not, they will be released from the Committee and another appointed.

Duties

• Ensure that the Criteria and Standards for Commercial Support of the Accreditation Council for Continuing Medical Education (ACCME), UCF Industry Relations Policy and Guidelines and the UCF/CPD missions are maintained when reviewing CPD activity applications for credit.
• Committee members will have final decision on approval/denial of CPD educational activity applications.
• Review faculty presentations for possible conflicts of interest.
• If no member opposes approval of an educational activity application (regardless of the number of responses) the activity is approved.

Policy

CPD will maintain oversight of the income and expenses for provider, co-provider and joint providership educational activities.

Procedures

• In a co-provider or joint providership arrangement, CPD will designate which party manages the income and expenses with oversight by CPD. The co-provider or joint provider will forward a financial wrap-up of income and expenditures to the CPD office one month from the activity date.
• If CPD develops and submits a grant application and handles all income and expenses for an educational activity, after expenses are paid, any remaining proceeds will remain with CPD for future educational development (this would not be a commercial support grant).
• CPD will not be responsible for any debt incurred for an educational activity.

Policy

CPD will follow ACCME Standards for Integrity and Independence and CPD policies concerning honorarium, out-of-pocket expenses and travel for educational activities.

 Procedures

• Honorarium, out-of-pocket expenses and travel may be paid to planners, faculty and/or authors by the provider, co-provider or joint provider however, if CPD designates an educational partner to pay, documentation of payment must be submitted to CPD.
• If a planner, teacher or author is listed on the agenda as facilitating or conducting a presentation, they may receive honorarium and reimbursement of expenses for that portion of their participation. If they choose to be a learner for the remainder of an activity; they cannot receive any payment for learner participation.
• No other payment is given to the director of the activity, planners, faculty and/or authors, learners, co-provider, joint provider or any others involved with the supported activity.
• If CPD accepted commercial support, it would use commercial support to pay for travel, lodging, honoraria, or personal expenses for bona fide employees and volunteers of the provider, co-provider or joint provider.
• If CPD accepted commercial support, it would not pay for travel, lodging, honoraria, or personal expenses for non-teacher or non-author participants of a CPD activity.
• All decisions regarding honorarium and travel will be done in accordance with ACCME Standards for Integrity and Independence, UCF Industry Relations Policy and Guidelines (https://med.ucf.edu/media/2011/08/UCF-COM-Industry-Relations-Policy-and-Guidelines3-4-14.pdf) and the CPD policies.

Policy

CPD will be a provider, co-provider or joint provider for educational activities that accept ancillary activities.

 Procedures

• CPD makes all decisions regarding the disposition and disbursement of funds collected from ancillary activities.
• Arrangements for ancillary activities or advertisements will not influence the planning or interfere with the presentation, nor be a condition for the provision of commercial support for CPD activities. CPD does not accept commercial support.
• Ancillary Activities must complete the CPD Exhibitor form.
• Exhibit space includes one table and two chairs for two representatives. Additional exhibit space(s) may be purchased.  See the Table of Contents for the page number of the exhibit form.
• Ancillary activities must adhere to ACCME Standards for Integrity and Independence, UCF Industry Relations Policy and Guidelines (https://med.ucf.edu/media/2011/08/UCF-COM-Industry-Relations-Policy-and-Guidelines3-4-14.pdf) and the CPD policies.

Policy

CPD will ensure that its educational activities are free of the control of an ineligible company.

 Procedures

• CPD makes the following decisions free of the control of a ineligible companies:
  • Identification of needs
  • Identification of professional practice gaps
  • Determination of educational objectives
  • Selection and presentation of content
  • Selection of all persons and organizations that will be in a position to control the content of an educational activity
  • Selection of education methods
  • Evaluation of the educational activity
• CPD will not be a provider, co-provider or joint provider for organizations accepting commercial support.
• CPD will ensure a faculty and/or planner employed by an ACCME-defined ineligible company does not participate in a CME activity. (Faculty and/or planners employed by an ACCME-defined ineligible companies are prohibited by University of Central Florida Continuous Professional Development program from participating in an accredited CME activity).
• CPD will ensure no non-accredited partner (in a joint provider relationship) of an ACCME-defined ineligible company participates in an accredited CME activity.
• All person in control of the content will attest on the activity application/planning and disclosure/attestation forms that they are not an employee of an ACCME-defined ineligible company.
• All person in control of the content will attest on the activity application/planning and disclosure/attestation forms that they are not in a joint provider relationship with an ACCME-defined ineligible company.

Policy

CPD will follow the ACCME policies for Managing Commercial Promotion, which are outlined in the ACCME Standards for Integrity and Independence and recapped below.

 Procedures

This standard applies only when there is marketing by ineligible companies or non-accredited education associated with the accredited continuing education.

CPD is responsible for ensuring that education is separate from marketing by ineligible companies—including advertising, sales, exhibits, and promotion—and from non-accredited education offered in conjunction with accredited continuing education.

1. Arrangements to allow ineligible companies to market or exhibit in association with accredited education must not:

• • Influence any decisions related to the planning, delivery, and evaluation of the education.
  • Interfere with the presentation of the education.
  • Be a condition of the provision of financial or in-kind support from ineligible companies for the education.

2. The accredited provider must ensure that learners can easily distinguish between accredited education and other activities.

• • Live continuing education activities: Marketing, exhibits, and non-accredited education developed by or with influence from an ineligible company or with planners or faculty with unmitigated financial relationships must not occur in the educational space within 30 minutes before or after an accredited education activity. Activities that are part of the event but are not accredited for continuing education must be clearly labeled and communicated as such.
  • Print, online, or digital continuing education activities: Learners must not be presented with marketing while engaged in the accredited education activity. Learners must be able to engage with the accredited education without having to click through, watch, listen to, or be presented with product promotion or product-specific advertisement.
  • Educational materials that are part of accredited education (such as slides, abstracts, handouts, evaluation mechanisms, or disclosure information) must not contain any marketing produced by or for an ineligible company, including corporate or product logos, trade names, or product group messages.
  • Information distributed about accredited education that does not include educational content, such as schedules and logistical information, may include marketing by or for an ineligible company.

3. Ineligible companies may not provide access to, or distribute, accredited education to learners.

Policy

CPD will adhere to the ACCME Standards for Integrity and Independence concerning appropriate handling of commercial support.

Procedures

• CPD would makes all decisions regarding the disposition and disbursement of commercial support.
• CPD would not be required by an ineligible company to accept advice or services concerning teachers, authors, or participants or other education matters, including content, from an ineligible company as conditions of contributing funds or services.
• All commercial support associated with a CPD educational activity is given with the full knowledge and approval of CPD.
• CPD would make sure the terms, conditions, and purposes of the commercial support are documented in a written agreement between the ineligible company that includes CPD and its educational partner(s). The agreement includes CPD, even if the support is given directly to the provider’s educational partner or a joint provider.
• The written agreement would specify the ineligible company that is the source of commercial support.
• Both the ineligible company and CPD would sign the written agreement, which is between the ineligible company and CPD.

Commercial Support for a CME activity is financial, and/or in-kind, contributions given by an ineligible company, which is used to pay all or part of the costs of a CPD activity.

A Commercial Interest is any entity producing, marketing, re-selling, or distributing health care goods or services consumed by, or used on, patients. The ACCME does not consider providers of clinical service directly to patients to be commercial interests.

Policy

All persons involved in the development of a CPD educational activity must disclose all relevant financial relationships.

Procedures

• CPD shows that everyone who is in a position to control the content of an educational activity has disclosed all relevant financial relationships with any ineligible companies. The ACCME defines “‘relevant’ financial relationships” as financial relationships in any amount occurring within the past 24 months that create a conflict of interest.
• An individual who refuses to disclose relevant financial relationships will be disqualified from the planning committee, presenter, teacher, or an author of a CPD educational activity, and cannot have control of, or responsibility for, the development, management, presentation or evaluation of the educational activity.
• CPD discloses to the learner prior to the educational activity any relevant financial relationship(s) and includes the name of the individual, the name of the ineligible company and the nature of the relationship the person has with each ineligible company.
• For an individual with no relevant financial relationship(s), CPD discloses to the learner that the individual has no relevant financial relationship(s).
• The source of all support from ineligible companies is disclosed to learners. When commercial support is “in-kind‟ the nature of the support is disclosed to learners.
• Disclosure will not include the use of a corporate logo, trade name or a product-group message of an ACCME-defined ineligible company.
• CPD discloses the above information to learners prior to the beginning of the educational activity.
• CPD has implemented the ACCME flowchart to identify and resolve all conflicts of interest prior to the educational activity being delivered to learners.

The ACCME defines relevant financial relationships as financial relationships in any amount, which occurred in the twenty four-month period preceding the time that the individual was asked to assume a role controlling content of the CME activity, and which relate to the content of the educational activity, causing a conflict of interest.

The ACCME considers financial relationships to create conflicts of interest in CME when individuals have both a financial relationship with an ineligible company and the opportunity to affect the content of CME about the products or services of that ineligible company.  The potential for maintaining or increasing the value of the financial relationship with the ineligible company creates an incentive to influence the content of the CME—an incentive to insert commercial bias.

The ACCME defines financial relationships as those relationships individuals benefit by receiving a salary, royalty, intellectual property rights, consulting fee, honoraria, ownership interest (e.g., stocks, stock options or other ownership interest, excluding diversified mutual funds), or other financial benefit.  Financial benefits are usually associated with roles such as independent contractor (including contracted research), consulting, promotional speaking and teaching, membership on advisory committees or review panels, board membership, and other activities for which remuneration is received or expected.

Policy

CPD will identify and mitigate all conflicts of interest.

Procedures

• CPD coordinator reviews disclosures of everyone in a position to control the content of an educational activity and identifies conflicts of interest prior to the educational activity.
• CPD uses the ACCME Flowchart for the Identification and Mitigation of Personal Conflicts of Interest. See Below

Conflicts of interest occur when an individual has a relevant financial relationship with an ineligible company and has the opportunity to affect the content of a CPD educational activity regarding the products or services of that ineligible company.

 An ineligible company is any entity producing, marketing, re-selling, or distributing health care goods or services consumed by, or used on, patients.

ACCME Conflict of Interest Flow Chart

Policy

The content, format and related materials of a CPD educational activity will encourage improvements in healthcare and will not promote the business interest of an ineligible company.

Procedures

• Presentations provide a balanced view of therapeutic options.
• Presenters use generic names to show impartiality.
• CPD educational content and materials use trade names (where available) from several companies and not just trade names from a single company.
• CPD activities promote improvements or quality in healthcare and not promote any specific proprietary business interest of a commercial entity.
• Presentations give a balanced view of therapeutic options in the planning and/or delivery of this CME activity.
• No direct payment from an ACCME-defined ineligible company is given to the director of this educational activity, any planning committee member, teacher or author, joint provider, or any others involved in this CPD educational activity.
• All who are in control of the educational content attest on the disclosure form they are not employed by an ACCME-defined ineligible company.
• All who are in control of the educational content attest on the disclosure they are not a non-accredited partner (in a joint provider relationship) of an ACCME-defined ineligible company.

Policy

CPD will document content validation and verification on its Application/Planning and Disclosure/Attestation Forms.

• All the recommendations involving clinical medicine in a CME activity must be based on evidence that is accepted within the profession of medicine as adequate justification for their indications and contraindications in the care of patients.
• All scientific research referred to, reported, or used in CME in support or justification of a patient care recommendation must conform to the generally accepted standards of experimental design, data collection and analysis.
• Providers are not eligible for ACCME accreditation or re-accreditation if they present activities that promote recommendations, treatment, or manners of practicing medicine that are not within the definition of CME, or known to have risks or dangers that outweigh the benefits or known to be ineffective in the treatment of patients. An organization whose program of CME is devoted to advocacy of unscientific modalities of diagnosis or therapy is not eligible to apply for ACCME accreditation.
• All person in control of the content will attest on the activity application/planning and disclosure/attestation forms that they will adhere to the content validation and verification