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CME Credits

Conflicts of Interest Disclosures and Continuing Medical Education

Physicians and other healthcare professionals are familiar with conflicts of interest (COI) and the ethical implications of practicing under the influence of financially-motivated relationships. It’s an important part of the job and a legal requirement to consider how these might interfere with your responsibilities as a medical provider. Practitioners must be free of influence to serve their patient’s best interests.

The consequences of failing to do what’s in the best interest of patients by not properly identifying, disclosing and mitigating COI can have serious consequences for you, your employer and your patients. In the most extreme cases, these can include practitioners losing their job or medical licenses.

Defining Conflicts of Interest

COI can be defined simply as any opposition between the private interests and the formal responsibilities of a person in a position of trust, power or authority. Common sources of conflicts of interest inside and outside the medical profession are family, financial and social factors. Common scenarios can be further classified as self-dealing, insider trading, gift issuance or acceptance, and nepotism.

For COI to occur, it’s not necessary for overt influence to occur. It is enough for the situation to appear as though there is a chance of biased professional judgment. It is the physician’s responsibility to actively identify and avoid the appearance of conflict.

The ACCME, CME Providers and Conflicts of Interest

With the stakes so high and a considerable degree of vigilance required to avoid conflicts of interest, physicians can rely on their professional organizations and, in the case of continuing medical education, Accredited Council for Continuing Medical Education (ACCME) approved providers for guidance.

Accredited continuing medical education providers must adhere to ACCME standards to earn and maintain provider accreditation. The third of five standards set by the ACCME in partnership with the major professional medical associations is to: Identify, Mitigate, and Disclose Relevant Financial Relationships.

The ACCME also states:

“…individuals in control of educational content and ineligible companies and managing these to ensure they do not introduce commercial bias into the education. Financial relationships of any dollar amount are defined as relevant if the educational content is related to the business lines or products of the ineligible company.”

Many practitioners have relationships with ineligible companies and don’t even realize it. According to the ACCME, ineligible companies include those producing, selling, re-selling, marketing or distributing health products.

This standard is designed to ensure that educational content forwards the goal of improving patient welfare by enhancing care. Those engaging in CME activities have a right to know and receive instruction from individuals and content that isn’t compromised by biased information.

Learners also have a right to know steps were taken to mitigate conflicts of interest. CME providers should make information available regarding their accreditation and any conflicts of interest in their employees or those who provide or deliver content for them, including conference presenters.

Examples of Ineligible Companies

Physicians or health professionals with relationships with ineligible companies must identify, mitigate and disclose those associations prior to accepting a role as a CME presenter or author of CME content. Just as in other areas of medicine, disclosure should include all forms of financial benefit, even those not yet realized.

Here are some examples of companies that can be deemed ineligible:

  • Advertising or marketing firms working on behalf of ineligible companies
  • Pharmaceutical companies and distributors
  • Companies that create, market and/or sell medical or dietary supplements
  • Diagnostic laboratories or those that sell them equipment
  • Medical device manufacturers or their distributors
  • Research firms or startups studying drugs or procedures with which you are associated
  • Charities set up for research or education that receive funding from commercial healthcare entities

Find the ACCME’s list of ineligible companies here.

Disclosing Conflicts of Interest

Those involved with making CME content available to audiences should clearly disclose the presence (and absence) of relevant financial relationships. To this end, CME Seminars discloses COI (and lack thereof) on the details page of every conference.

Accredited CME providers will work with presenters and those who created CME activity curriculums to issue a disclosure containing:

  • The names of individuals they have/had financial relationships with
  • The names of companies they have/had financial relationships with
  • A brief statement describing the nature of the relationship
  • A brief statement indicating the ways these relationships have been mitigated (if necessary)

Here is an example of a CME conflict of interest disclosure form for a professional medical organization containing the above components.