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6: Disclosures Relevant to Potential Commercial Bias


QUESTIONS RELATED TO SCS 6.1
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1) If we have taken appropriate steps to resolve conflicts of interest what is there left to disclose? (SCS 6.1)
Informed learners are the final safeguards in assuring that a CME activity is independent from commercial influence. Regarding personal conflicts of interest, CME providers are to have in place mechanisms to identify and resolve conflicts of interest. While these mechanisms should greatly reduce the potential for conflicts of interest to affect CME content, a potential for influence remains. Disclosing to learners the relevant financial relationships that were present and resolved assists learners in assessing the potential for bias in information that is presented. ACCME believes this disclosure contributes to the transparency and accountability of the system.

2) What does ACCME mean by ‘nature of relationship? (SCS 6.1)
The ‘nature of the relationship’ means the role they play or service they provide in exchange for some form of compensation (e.g., employment, management position, independent contractor including contracted research, consulting, speaking and teaching, membership on advisory committees or review panels and board membership).ACCME has not set a minimum dollar amount for relationships to be significant. Inherent in any amount is the incentive to maintain or increase the value of the relationship therefore the dollar value of the relationship does not need to be disclosed.

QUESTIONS RELATED TO SCS 6.2
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1) What does SCS 6.2 add to the system?
This allows the learners to distinguish between missing disclosure information and the circumstances where there is nothing to disclose.

QUESTIONS RELATED TO SCS 6.3
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1) Is disclosure of commercial support different than disclosure of financial relationships? (SCS 6.3)
Yes. Commercial support is given to the accredited Provider and the accredited Provider must disclose its existence to the learner. The presence of commercial support is critical information. The disclosure of commercial support is not an opportunity for product advertising but rather it must be restricted to the name of the corporate entity that provided the financial or specified in-kind support.

QUESTIONS RELATED TO SCS 6.3, 6.4, 6.5
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1) Can a commercial supporter's logo be used to acknowledge support? (SCS 6.3, 6.4, 6.5)
While the logo can appear, the provider cannot acknowledge support only by showing the commercial supporter's logo. The acknowledgement needs to specifically tell the learner that the commercial supporter gave support for the activity. The acknowledgment of commercial support cannot contain any product promotion.


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