Policy for Identifying and Resolving Conflicts of Interest in CME
I.
Background:
It is important that continuing medical education (CME) content be based on needs assessments and not be
biased by commercial or marketing influences. This policy is designed to ensure that Mount Sinai School of Medicine
develops all CME programming without undue influence by any individuals or groups associated with these CME
activities.
Full disclosure of conflicting or potentially conflicting interests is required as part of the CME process,
reviewed by committee and this policy is to address the resolution of any real or perceived conflicts in order to promote
the integrity of CME activities at our institution.
Teachers/presenters/authors/individuals in control of CME content will be expected to offer CME that is
objective, balanced, scientifically rigorous, evidence-based and in compliance with the 2004 Updated ACCME
Standards for Commercial Support.
II.
Goals:
 to describe appropriate processes and procedures to identify all actual and/or potential conflicts of interest
 to identify mechanisms to resolve any real or perceived conflicts prior to the CME activity
 to implement the process to reach a resolution assuring that there is no conflict of interest in the educational
activity and to verify that the activity is in the best interest of the public
III.
Policy: Identification of Conflicts of Interest (COI):
1. The Page and William Black Post-Graduate School for Continuing Medical Education of Mount Sinai School of
Medicine requires that all individuals in control of CME content including the planning committee complete the
application form for CME approval which includes all the necessary ACCME elements and policies including
Disclosure Forms.
2. The Page and William Black Post-Graduate School for Continuing Medical Education of Mount Sinai School of
Medicine requires that all individuals participating in CME activities complete the Disclosure Form.
3. The primary responsibility to identify, address and attempt to resolve any COI belongs to the Activity Director.
The Office of Continuing Medical Education staff will be available to assist with this process.
4. Any disclosure forms of concern identified by the Activity Director will be reviewed by CME staff and the CME
review committee. The Director of CME and/or the Associate Dean for CME will be available discuss any conflict
with the course director.
5. The Activity Director will sign off on the educational activity as having reviewed all conflicts to be identified and
resolved.
6. All identified actual and potential COI, along with resolution mechanisms, will be disclosed to CME activity
participants.
IV.
Policy: Mechanisms for Resolving Conflicts of Interest:
The following are suggested mechanisms for resolving conflicts of interest (COI).
A. Attestation:
Persons who indicate the existence of potential or actual COI will be asked to agree in writing that said conflicts or
relationships will not bias or otherwise influence their involvement in the CME activity and will be evidence-based.
B. Evaluation:
Attendees will be asked about bias (or absence of bias) within the activity. Activity Directors and
teachers/authors will receive copies of the evaluation summaries and comments. These evaluations will be used for
quality improvement so that our office and the course directors can detect potential conflicts and resolve them prior to future programs.
C. Peer Evaluation:
An informed learner or peer who is not involved in the planning and/or teaching of the activity will observe the
CME activity. This evaluator will be asked to complete an evaluation to note any bias in the activity.
D. Independent content evaluation
E. Altering financial relationships:
An individual may change his/her relationships with commercial interests, however, when individuals divest
themselves of a relationship, it is immediately not relevant to conflicts of interest, but still must be disclosed to
learners for 12 months.
F. Altering control over content:
Change the focus of the CME content
Choose someone else to control that part of the content
Change the content of the person’s assignment
Limit the content to a report without recommendations
Limit the sources for recommendations
G. Elimination:
Activity Directors, activity planning committee members, and/or teachers/authors who are perceived as either
manifesting irresolvable COI or being biased may be eliminated from consideration as resources for the CME activity.