CONTINUING MEDICAL EDUCATION
“commercial support” as financial or “in-kind contributions given by a
commercial interest that are used to pay all or part of the costs of a CME
activity.” 88 Examples include meals, speaker honoraria, travel expenses, or
a meeting space. 89 When a provider decides to solicit funds from drug and
device manufacturers, it must first inform the ACCME of its intent to do so
by listing potential commercial supporters on a sponsorship application. 90
When completing grant requests, the provider must also demand that any
payments be made directly to the provider, as opposed to any speakers or
vendors. 91 Once the provider approves a request, the manufacturer
generally responds with a Letter of Agreement (LOA), which the provider
submits to the ACCME prior to the date of the CME program. 92
The CME provider must make all decisions regarding the disposition and
disbursement of commercial support. The industry sponsor cannot require
the provider to accept advice or services concerning teachers (speakers),
authors, participants, or content as a condition of contributing funds. The
parties, including the CME provider, must include in a signed written
agreement the terms, conditions, and purposes for the commercial support. 93
The CME provider must be able to produce accurate documentation
showing the receipt and expenditure of the commercial support. 94
Further, the CME provider must be able to show that everyone who is in
a position to control the content of an education activity has disclosed all
relevant financial relationships with any commercial interest to the CME
provider. 95 CME providers must have a formal process to identify and
resolve any conflicts of interest. 96 These ACCME standards aimed at
resolving conflicts of interest target those in a position to control CME
content. For example, the ACCME requires CME providers to give a
88. Id. at 13.
89. See id. at 4.
90. See id. at 11.
91. Id. at 4.
92. See ACCME STANDARDS FOR COMMERCIAL SUPPORT, supra note 10, at 4, 13. A
LOA is a written agreement specifying the terms, conditions, and purposes of the
commercial support awarded by a commercial entity to a provider. Id. All commercial
support requires a LOA with the signatures of the director of the CME provider and the
supporting company. Id.
93. See id. at 4.
94. Id.
95. Id. at 13 (defining “relevant financial relationships” as financial relationships in any
amount occurring within the previous twelve months that create a conflict of interest). An
individual who refuses to disclose any relevant financial relationship is disqualified from
being a planning committee member, teacher, or author of CME and cannot have any control
over the presentation or evaluation of the CME program. Id. at 3.
96. Id.
