CRITERIA FOR DISCLOSURE OF FINANCIAL RELATIONSHIPS WITH INELIGIBLE COMPANIES IN CONTINUING EDUCATION (CME/CE)
1. Instructors, planners, content reviewers, or others who may control educational content of a CME/CE activity are required to disclose all financial relationships that you have had in the past 24 months with ineligible companies** (i.e., any entity whose primary business is producing, marketing, selling, re-selling, or distributing healthcare products used by or on patients). There is no minimum financial threshold; we ask that you disclose all financial relationships, regardless of the amount, with ineligible companies. You should disclose all financial relationships regardless of the potential relevance of each relationship to the education.
- Advertising, marketing, or communication firms whose clients are ineligible companies
- Bio-medical startups that have begun a governmental regulatory approval process
- Compounding pharmacies that manufacture proprietary compounds
- Device manufacturers or distributors
- Reagent manufacturers or sellers
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- Diagnostic labs that sell proprietary products
- Growers, distributors, manufacturers, or sellers of medical foods and dietary supplements
- Manufacturers of health-related wearable products
- Pharmacy benefit managers
- Pharmaceutical companies or distributors
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2. You are to disclose all financial relationships that fit the above definition in any amount that has been received over the past 24 months.
3. Financial relationships with governmental agencies (e.g., the NIH) and organizations that do not fit the above definition do not have to be disclosed.
4. Honoraria or consulting funds received from a CE provider do not have to be disclosed, even though those funds may have been provided to that CME/CE provider through an educational grant from a commercial interest.
5. If you are a principal investigator for an ineligible company, you must report that research relationship below under "Contracted Research" even if those funds came to your institution and are managed by said institution.
6. In accordance with ACCME, ANCC, and ACPE requirements, failure to provide disclosure information in a timely manner will result in the disqualification of the potential planner, course director, moderator, faculty, presenter, author, or reviewer from this activity.