VENTURA COUNTY MEDICAL CENTER
SANTA PAULA HOSPITAL
Associated with the UCLA School of Medicine
ADMINISTRATIVE POLICY
1.6
PROCEDURE:
PAGE
1 OF 2
VCMC COMMERCIAL SUPPORT POLICY
SUBJECT: PURPOSE OF DEPARTMENT
DEPARTMENT:
AFFECTS:
APPROVED BY:
OFFICE OF MEDICAL EDUCATION
EFFECTIVE DATE:
REVISION DATES:
12/5/2013
12/5/13
ALL DEPARTMENTS
Cheryl Lambing, M.D., FAAFP, CME Director
Medical Director, Professional Education, Ventura County Health Care Agency
REVIEW DATES:
Renee Higgins, M.D.
Chief Operations Officer, Ventura County Health Care Agency
Continuing Medical Education Committee Medical Staff, Staff and Members
PURPOSE AND BACKGROUND
The Ventura County Medical Center (VCMC) is accredited by the Institute for Medical Quality (IMQ)/California Medical
Association (CMA) to sponsor (designate credit) continuing medical education (CME) for physicians. The VCMC CME
Committee is responsible for ensuring compliance with the ACCME Standards for Commercial Support SM.
APPROPRIATE USE OF COMMERCIAL SUPPORT
Ventura County Health Care Agency (VCHCA)/Ventura County Medical Center (VCMC) CME Provider does not solicit,
accept nor utilize commercial support for CME activities. VCHCA/VCMC CME Provider does not accept commercial
interest advice or services for CME.
VCHCA/VCMC CME Provider does allow the Activity Medical Directors to invite speakers outside of the VCHCA
Medical Staff to address a specific CME requested topic. VCMC CME Committee maintains control of the topic,
objectives, Cultural and Linguistic Components and Disclosures/Conflicts of Interest. VCHCA CME Budget Allocation
funds, paid directly by VCHCA, provide speaker honoraria and speaker expenses in accordance with our
Honoraria/Reimbursement process documented in Administrative Policy 1.7.
Additionally, funds could be distributed by the Medical Staff should a particularly important topic or speaker be
identified or requested by the CME Committee. These funds are not Commercial Support, as they represent Medical
Staff Dues paid by all VCHCA/VCMC physicians every 2 years during reappointment and the funds would be provided
to serve our target audience—the VCHCA Medical Staff.
All Learner expenditures are VCHCA CME Budget Allocation funds only. There is no commercial interest providing
commercial support for any VCHCA/VCMC CME activity.
TERMS AND ACCOUNTABILITY FOR THE USE OF COMMERCIAL SUPPORT
The following policy exists at the request of IMQ as VCHCA/VCMC does not accept commercial support:
When VCHCA/VCMC accepts Commercial Support for CME this policy will be applied.
1. The terms, conditions and purposes of the commercial support must be documented in a written and signed
agreement between the commercial interest providing the commercial support and the CME Provider,
VCHCA/VCMC, prior to the CME activity. Commercial support must be unconditional – the commercial
interest will not influence or participate in the planning of or execution of the CME activity. The terms and
conditions must state that VCHCA/VCMC will make all decisions regarding the disposition and disbursement of
commercial support. The agreement will include Administrative Policy’s 1.6 and 1.7 to ensure knowledge of
and agreement to by all signing parties.
2. The agreement must include VCHCA/VCMC even if the commercial support is given to the educational partner
or joint sponsor of a CME activity.
3. The agreement must include detailed income and expenses.
4. Commercial support may not be used to pay for travel, lodging, honoraria or personal expenses for nonteachers or non-author participants (Learners) of a CME activity. Commercial support may be used by
VCHCA to directly pay for travel, lodging, honoraria or personal expenses for CME activity speakers or
individuals giving a presentation at a CME activity. Such expenses must follow our Honoraria/Reimbursement
process as documented in Administrative Policy 1.7.
5. Social events, meals or snacks may not take precedence over CME activities.
6. Commercial exhibits may not be present, may not influence or interfere with a CME activity or be a provision of
money provided for the activity.
7. Product promotion may not occur in the same place, space or time of the CME activity.
8. Slides/Handouts may not have messages for trade names or product groups.
Additionally, before VCHCA/VCMC may accept commercial support, the CME Committee will meet to discuss the
details of the potential educational grant to determine the specific need and whether to proceed to a Letter of
Agreement. The CME Committee will make a recommendation regarding any commercial support and it will be the
decision of the VCMC CME Director on whether to proceed to a Letter of Agreement.
DEFINITIONS
Activity Medical Director: The Ventura County Medical Center faculty member in charge of planning, implementing
and evaluating the CME activity and who is responsible for collaborating with VCMC CME Provider to ensure
compliance.
Commercial Interest: Any entity producing, marketing, re-selling, or distributing health care goods or services
consumed by, or used on, patients.
Commercial Support: Financial, or in-kind, contributions given by a commercial interest, which is used to pay all or
part of the costs of a CME activity.
Continuing Medical Education (CME): Continuing medical education consists of educational activities which serve to
maintain, develop, or increase the knowledge, skills, and professional performance and relationships that a physician
uses to provide services for patients, the public, or the profession. The content of CME is that body of knowledge and
skills generally recognized and accepted by the profession as within the basic medical sciences, the discipline of
clinical medicine, and the provision of health care to the public. (Source: ACCME)
Faculty: An individual speaking at or giving a presentation at a CME activity.
Joint Sponsor: A non-ACCME accredited organization that plans and presents a CME activity in partnership with an
ACCME-accredited organization.
Learner: An individual in attendance at a CME activity.