St. John Hospital CME Conflict of Interest (COI) Policy and Procedure

The St. John Hospital Office of Continuing Medical Education requires that all CME certified activities be developed free from the control of a commercial interest and be balanced, objective, and scientifically rigorous.

Definition of Conflict of Interest (COI)

A conflict of interest exists when individuals in a position to control the content of a CME activity have a relevant personal financial relationship with a commercial interest that benefits the individual and may ultimately bias the content being presented. The following factors serve as part of the foundation for potential COI:

A financial relationship (in any amount) with a commercial interest occurring within the past 12 months and

The opportunity to affect the content of CME about the products or services of that commercial interest.

When the individual’s interests are aligned with those of a commercial interest the interests of the provider are in ‘conflict’ with the interests of the public. The interests of the people controlling CME must always be aligned with what is in the best interests of the public

St. John Hospital CME

St. John Hospital and Medical Center, an organization accredited by the Michigan State Medical Society (MSMS), is responsible for creating a mechanism to identify, manage and resolve all conflicts of interests for all individuals involved in the planning and implementation of an MSMS certified activity.

St. John Hospital incorporates the following strategies as part of the overall planning process of CME activities:

Identify financial relationship that may constitute a potential conflict of interest for all individuals involved in the planning and implementation of the proposed CME activity (planning committee members, faculty presenters, authors, etc.).

Disqualify any individual who fails to provide disclosure from participation in the planning and/or implementation of the proposed CME activity.

Implement educational planning and design strategies that work to ensure that content is balanced, scientifically rigorous, and evidenced-based and reflects the current standards of care and/or future directions of medicine and healthcare.

Monitor and manage CME activities in accordance with the current standards, regulations and guidelines outlined by the constituencies involved in the delivery of continuing medical education, research and patient care.

Document the processes for needs assessment, gap analysis, content validation, and educational design that provide for fair and balanced discussion of the desired topics.

Monitor the execution of CME activities to validate the presence/absence of commercial bias and the consistent application of the standards of quality education for physicians and other healthcare professionals.

Situations where Conflict of Interest cannot be effectively resolved

While St. John Hospital CME strives to be flexible, accessible and helpful in the development and implementation of CME certified activities, there are some situations where adequate resolution of COI may not be feasible. In these situations, CME certification will not be provided. Examples of these situations include:

Requests for CME certification of the content after the majority of the planning for the CME activity has occurred with faculty and/or content selections already determined;

Short planning timeframes that don’t permit adequate planning and implementation of required MSMS and St. John CME policies and procedures;

Inappropriate processes in educational planning and/or financial management that are not consistent with MSMS and/or St. John CME policies and processes.

Resolution of Conflict(s) of Interest Form

St. John Hospital and Medical Center

To be completed for each individual involved with the planning and/or implementation of the activity’s content who has disclosed financial relationship(s) with commercial interest(s). Note: this form must be completed prior to the event.

Meeting Title:
Presentation Title:
Activity Date:
Speaker or Planner:

I have reviewed the speaker’s identified financial relationships and handled his/her perceived conflicts of interest by the following means (check all that apply and provide further explanation as needed).

No Resolution Required: Speaker topic and presentation are not pertinent to the speaker’s disclosed financial relationship(s) with commercial interest(s).

Peer Evaluation: The Course Director or knowledgeable clinician reviewed the content (slides) prior to the start of the presentation. Review did not require changes to the content. The following changes were made to the content:

Independent Content Validation: a) content is valid and aligned with the interests of the public; b) all recommendations involving clinical medicine are based on best available evidence; c) all scientific research referred to, reported, or used in the CME activity in support or as justification of patient care recommendations conforms to the generally accepted standards of experimental design, data collection, and analysis.

Altered control over content:

Chose someone else to control that part of the content	Changed the focus of the CME activity

Changed the content of the person’s assignment	Limited sources for recommendations

Limited content to a report without recommendations

Elimination: Activity Medical Directors, planning committee members and/or teachers/authors who were perceived as either manifesting conflicts of interest or being biased will be eliminated from consideration as resources in subsequent certified CME activities.

Comments:

Signature of Course Director or Executive CME Director	Date

Approved 9/12/2012

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.