ACCREDITATION
CRITERIA
CONFLICT OF INTEREST
CONTENT INTEGRITY
Part I
Conflict of Interest (COI)
COI (Cont.)
ANCC defines COI as existing when:
An individual who has the ability to control content of
an education activity has a relationship with a
commercial interest organization, the products, and
services of which are related to the content of the
educational activity
COI (Cont.)
ANCC defines COI as existing when:
ANCC considers relationships to be relevant if they
existed within the past 12 months. Relationships of
an individual’s spouse or significant other are also
considered relevant.
In other words, COI exists ONLY if there is a real or
potential financial gain
A Commercial Interest Organization (CIO)
is NOT eligible for accreditation
ANCC definition of a Commercial Interest
Organization(CIO)
AN ORGANIZATION THAT:
◦ Produces markets, sells or distributes health care goods or services consumed
by or used on patients.
◦ Is owned or operated, in whole or in part, by an organization that produces,
markets, sells or distributes health care goods or services consumed by or
used on patients.
◦ Advocates for use of the products or services of a commercial interest
organization.
Exempt Organizations that do not have
COI
◦ Government entity
◦ Non-profit 501c organizations
◦ Providers of clinical services directly to patients; including but not
limited to, hospitals, health care agencies, and independent health
care practitioners.
Exempt Organizations that do not have
COI
◦ Entity who the sole purpose is to improve or support the delivery
of health care to patients; including but not limited to, providers or
developers of electronic health information systems, database
systems, and quality improvement systems.
Exempt Organization that do not have COI
(Cont.)
◦ Non-health care related entity whose primary mission is not
producing, marketing, selling, or distributing health care goods or
services consumed by or used on patients.
◦ Liability insurance providers
◦ Health insurance providers
◦ Group medical practices
(2014 ANCC Content Integrity Standards)
Exempt Organization that do not have COI
(Cont.)
◦ Acute care hospitals (for profit and non-for-profit)
◦ Nursing homes (for profit and not-for-profit)
◦ Blood banks
◦ Diagnostic laboratories
◦ Employment with a college
(2014 ANCC Content Integrity Standards)
Related Organizations Which Have a COI
◦ Parent organization – organization that owns one or more
subsidiary organizations.
◦ Parent organization that is a commercial interest organization.
◦ Subsidiary organization – organization owned by parent company
which is a commercial organization.
Related Organizations Which Have a COI
(Cont)
◦ Sister organization – two organizations sharing a common parent
organization (an organization may be eligible if it establishes and
maintains adequate firewalls to shield said from sister organization
that is a commercial interest organization).
(2014 ANCC Content Integrity Standards)
DISCLOSURE OF CONFLICT OF INTEREST
(COI)
It is critical that providers implement the following steps when planning
educational activities:
•Identify all individuals in a position to control content of the educational activity.
•Collect and document any relationships that individuals in a position to control
content have with any COI.
•For individuals who have relationships with COI, evaluate whether the products
and/or services of the COI are relevant to the content of the educational activity.
•If relevant, the relationship must be resolved and disclosed to learners.
DISCLOSURE OF CONFLICT OF INTEREST
(COI) (Cont.)
It is the responsibility of ALL involved with an educational activity to disclose if
he/she is in a position to control or influence content of the educational activity.
Any relationship declared with commercial interest organizations must be
identified and evaluated for conflict of interest. If a potential or actual conflict is
identified, they mus.t have a documented resolution mechanism. Disclosure
must be placed on the Biographical/Conflict of Interest form.
DISCLOSURE OF CONFLICT OF INTEREST
(COI) (Cont.)
It is the responsibility of the Nurse Planner to identify the presence or absence
of actual or potential conflicts of interest and to resolve this issue during the
planning and implementation phases of an educational activity.
If the nurse has an actual or potential conflict of interest he or she must recuse
self from the role as nurse planner for the educational activity.
DISCLOSURES
All Relevant Relationships Must be Disclosed to Learners:
◦ During the time the relationship is in effect.
◦ For 12 months after the relationship ends.
◦ Prior to the start of the educational activity.
COI EXAMPLES
Salary
Royalties
Intellectual property rights
Consulting fees
Ownership interest
Grants
Contracts
Any other financial benefit received directly/indirectly from commercial
interest organization
STEPS TO RESOLVING COI
Identify – individual with relationship with commercial
organization (Includes spouse/significant other). It is the
responsibility of the Nurse Planner to identify the presence or
absence of actual or potential conflicts of interest and to
resolve this issue during the planning and implementation
phases of an educational activity.
STEPS TO RESOLVING COI (Cont)
Determine if there is a commercial interest relationship with
planners, speakers, authors, content reviewers, and/or the
spouse/partner. COI may include salary, royalties, intellectual
property rights, consulting fees, ownership interest, grants,
contracts or any other financial benefit directly or indirectly
from a commercial interest.
STEPS TO RESOLVING COI (Cont)
Evaluate
•No relationship
•Relationship not relevant
•Relevant relationship with resolution - Any individual who is in a
position to control or influence the educational activity content must
be evaluated from any association with commercial interest
organization to determine if they may participate in the activity.
STEPS TO RESOLVING COI (Cont)
•Revising role of individual with COI so that the relationship is
no longer relevant to activity
•Not awarding continuing education contact hours for a
portion or all of educational activity
STEPS TO RESOLVING COI (Cont)
•Undertake a review of activity by content reviewer to evaluate
for potential bias, balance in presentation, evidence-based
content or other indicator of integrity, and absence of bias,
AND monitoring activity to evaluate for commercial bias.
•Remove individual with COI from participating in all parts of
the educational activity.
Part II Content Integrity
Content Integrity
The content of a continuing nursing education activity or its
related materials must promote improvements or quality in
health care by giving a balanced view of therapeutic
options.
Activity Content
Content must be planned to prevent bias by:
◦ Providing evidence of COI being identified, resolved and disclosed for all
individuals in position on control content.
◦ Being evidence-based or chosen on best-available evidence
◦ Being planned independently from influence of commercial interest
organizations.
◦ Being free from promotion or bias.
Activity Content (Cont.)
◦ Should be congruent with purpose and objectives.
◦ Based on needs assessment and gap analysis.
◦ Provide information beyond restating objectives.
◦ Evidence-based or based on best-available sources (usually within last 6
years).
For Additional Clarification
Refer to ASNA’s Continuing Education Page (“resources”)
http://alabamanurses.org/?page_id=12334
Or
Contact:
Ginger Collum, Nurse Peer Review Leader, ASNA
collumva@gmail.com
Charlene Roberson, Director of Leadership Services, ASNA
charlenerasna@alabamanurses.org