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Full Disclosure and Commercial Support

Element 3.3:

The Provider must present CME activities in compliance with ACCME's policies for disclosure and commercial support.

1. The following elements are to be disclosed to the audience of all CME activities sponsored by EVMS:
   • All receipts of funds from proprietary entities
   • Investigational products or products not labeled for use
   • Existence of significant financial interest or relationship of faculty or provider with the manufacturer or commercial product
   • Relationships of faculty with commercial support of the activity
      
2. EVMS consistently maintains control of content:
   • Activities are free from commercial bias.
   • Educational materials, such as slides and syllabi, do not advance proprietary interests of supporting company.
   • There is mention of multiple companies' trade names, if applicable
   • Research reported of a proprietary company conforms to accepted practices of experimental design, data collection, and analysis.
      
3. EVMS consistently ensures that promotion and education are separate:
   • Exhibits do not interfere with CME activity presentations.
   • Exhibit placement is not a condition of support.
   • Exhibits are not displayed in the same room as the educational activity.
   • Proprietary company representatives do not engage in sales activities where the educational activity occurs.
      
4. EVMS consistently demonstrates appropriate management of funds from commercial supporters:
   • Funds received are in an educational grant payable to EVMS-CME.
   • Terms, conditions, and purposes of the educational grant are documented in a signed agreement between EVMS and the supporter.
   • Honoraria and expenses for faculty are reasonable.
   • No other funds are paid by the proprietary company to the director of the activity, faculty, or others involved with the supported activity.
      
5. Disclosure may be written on flyers, brochures, syllabi, or evaluation forms and distributed to all attendees.
    
6. Disclosure may be verbal when introducing the speaker, especially in the grand round situation. An example of disclosure:

   John Doe, M.D
   Professor, Department of Neurology
   The University of Texas Medical School at Houston
   Research Consultant, Peterson Pharmaceutical
   Madison, WI

7. The intent of this policy is not to prevent a speaker with a potential conflict of interest from making a presentation. It is intended that any conflict should be identified openly, so that participants may form their own judgments concerning the presentation with the full disclosure of the facts.
    
8. The Faculty Disclosure Form shall be completed by the faculty member/speaker and placed in the appropriate CME activity file prior to the presentation.
    
9. Evidence of disclosure having taken place is found on the evaluation summary (departmental grand round activities) or the syllabus of an individual conference. This information is filed with the CME activity materials in the Office of CME.
    
10. Disclosure forms for EVMS faculty who participate in grand rounds are kept on file in the Office of CME and expire after one year.

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