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4: Appropriate Management of Associated Commercial Promotion


QUESTIONS RELATED TO SCS 4.1
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1) Are advertising and exhibit opportunities always to be offered to commercial supporters? (SCS 4.1)
No. Payment and arrangements for advertising and exhibits are separate, business transactions. They are payment for the sale of promotional space.

2) Is the provider responsible for the content of advertising and exhibits? (SCS 4.1)
No. The Provider is not accountable to the ACCME for the content of advertising and exhibits. The information transferred in an advertisement or exhibit is not part of the Provider’s program of continuing medical education activities.

QUESTIONS RELATED TO SCS 4.2
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1) Does SCS 4.2 represent a change for enduring materials?
This is a more detailed description of the requirements that must be followed if there is advertising in enduring materials. There can be advertising before and after the CME content of an enduring material but those advertisements cannot be related to the content of the CME and cannot have been paid for by the commercial supporter.

2) Where can providers put advertisements in printed enduring materials and printed journal-based CME and still be in compliance with SCS4.2?
  • In journal-based CME there cannot be an advertisement within the pages of the article on which the activity is based. There can be advertisements between articles.
  • In a print enduring material there can be advertisement at the end and the beginning of the CME content but nowhere else in the enduring material.


3) What does ACCME mean by ‘space or place?’ (SCS 4.2)
Twenty years ago, most CME occurred in a lecture hall. Now, learning activities occur in many different environments including electronic media, and ACCME intends that all of these places and spaces of CME activity need to be protected from encroachment by advertising, sales or promotional activity.

QUESTIONS RELATED TO SCS 4.3
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1) What can and what cannot have advertising? (SCS 4.3)
ACCME insists on the separation of education from all promotional activities, materials and messages. Many providers create a print or text based document that goes along with an activity and provides information that is supplementary to the education content – like reproductions of slides, graphics or other handouts. These documents, in print or electronic, are an integral part of the education and as such cannot have any advertising, trade name or a product-group message associated with them.

2) Our program book has abstracts in it but we give no CME credit for the abstracts – there is no problem having advertising in the program book – correct? (SCS 4.3)
The Updated SCS do not represent a change from what has been ACCME policy for many years. It depends on what the Program Book, with abstracts, is used for in relation to the CME activity. If the abstracts are referenced during the activity or serve as a component of the content, then there can be no advertising in the Program Book. If the abstracts are not referenced as part of the CME content, and appear in the Program Book with all other logistical information about the activity, then there can be advertising.

QUESTIONS RELATED TO SCS 4.4
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1) Does SCS 4.4 refer to what we call a ‘program book?
Yes. It contains logistical and organizational information and not education materials. It contains maps and floor plans but not slides and not abstracts.

QUESTIONS RELATED TO SCS 4.5
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1) Does this mean that ACCME is prohibiting commercial supporters and other commercial interests from distributing CME enduring materials to physicians? (SCS 4.5)
No. The regulation of commercial interests’ promotional activities is not within the scope of ACCME’s responsibility. SCS4.5 is about the providers’ role in separating promotion from education. ACCME is asking accredited providers to use their own distribution channels for CME activities. For example, having a CME enduring material created so as to be used in promotional visits to physicians’ offices is not in keeping with the concept of separating CME from promotion.

2) Can the Provider use a commercial supporter to distribute promotional materials for CME activities, e.g., “save the date cards, brochures?” (SCS 4.5)
Yes.

3) What if a commercial entity is interested in buying a CME product and approaches the CME provider – is it acceptable to sell the product to it? (SCS 4.5)
Yes. A Provider would not be out of compliance with the Standards for Commercial Support.

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