Guidelines for Soliciting/Accepting Commercial Support for

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Commercial Support Agreements:

Where financial or in-kind support from a commercial interest is involved, a Letter of Agreement must be completed, signed by all parties and returned to the Office of CME prior to any acknowledgement. If the Office of CME has not received the signed LOA prior to the date of the educational activity, the company cannot be acknowledged in the program materials and the educational grant cannot be accepted. The agreement must be signed by a representative from the commercial interest and the Provider. The Provider is Northwestern University with the contact information of the Feinberg School of Medicine Office of Continuing Medical Education. The university’s Office of General

Council has designated Dr. John X. Thomas, Senior Associate Dean for Medical Education, as the appropriate signature for commercial company’s LOA; members of the OCME are the designees for the medical school’s LOA.

The sponsoring department, affiliate or co/joint sponsor are NOT the appropriate signature for LOAs.

All commercial support must be given with full knowledge and approval from the OCME. The course director must make all decisions regarding the disposition and disbursement of commercial support. The Director of CME, members of the CME Review Committee and the Senior Associate Dean for Medical Education must approve the disbursement of commercial company funds during the application process. If there are any changes in the status of the support, the course director must inform the Director of CME. Funds provided by commercial supporters may not be used for travel, lodging, honoraria or personal expenses for participants of the activity.

For educational activities NOT coordinated by the Office of CME, the OCME will provide a grant request letter indicating that the funds be distributed to the affiliate or co/joint sponsor. If the company must pay the Provider

(FSM), the OCME will process the educational grant and issue the funds to the sponsoring department, affiliate or co/joint sponsor. Please refer to the fee structure for the fees associated with distributing educational grants. The grant processing fees should be built into the activity’s budget estimate as CME administrative fees.

Grant Submission and Reconciliation:

The department, affiliate, medical education company, medical education company, co/joint sponsor coordinating the activity is responsible for processing the online grant submissions, reconciliations and retaining the activity’s financial records for a period of 3 years.

Educational grant requests must be communicated to the Provider (Northwestern University Feinberg School of

Medicine) prior to the grant submission. A copy of all grant requests must be submitted to the Office of CME prior to their submission to the commercial company.

Grant submissions must reflect the anticipated income and expenditures for an upcoming activity. It is appropriate to include a department administrative fee to cover the cost that the hosting department incurs for their faculty and administrative staff’s time to develop and execute the learning activity. The letters of agreement must indicate how the funds are to be used (e.g., speaker’s honoraria, printing costs, etc.). The hosting department is responsible for reconciling the educational grant as stated in the letter of agreement. If the letter of agreement states that the excess funds should be returned if the activity is cancelled or the activity does not require the entire amount of grants given, the excess amount must be returned. For example, if the letter of agreement identifies the funds will be used for printing, and the printing cost are less than originally predicted, those excess funds must be returned. In the event that multiple companies have issued educational grants, the excess funds will be returned only to those companies that have the requirement included in their agreement.

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