Using ACCME’s Flowchart for Identifying and Resolving Personal Conflicts of Interest
ACCME requirements are designed to ensure that accredited continuing medical education (CME) provides a safe place for learning—independent of commercial interests and commercial influence. We prepared this tutorial and flowchart to help you navigate the identification of relevant financial relationships and the resolution of conflicts of interests in CME activities.
Use of these resources is optional. Please note that the tutorial and flowchart do not address all of the expectations of ACCME requirements for independence from commercial interests.
ACCME expects accredited organizations to ensure independence by:
- Identifying relevant financial relationships between commercial interests and those who plan, teach, and implement CME
- Resolving conflicts of interest that arise when those with relevant financial relationships with commercial interests have the opportunity to control CME content related to the products or services of those commercial interests
- Disclosing to learners the (identified) relevant financial relationships for those in control of CME content prior to the educational activity or disclosing that there were no relevant financial relationships.
These expectations are laid out in Standards 1, 2, and 6 of ACCME’s Standards for Commercial Support: Standards to Ensure the Independence of CME Activities.
Let’s Get Started
Is the content of the CME activity related to the products or business lines of an ACCME-defined commercial interest?
If your answer is “yes,” proceed to B.
If your answer is "no," there are no relevant financial relationships to identify. Before the CME activity, disclose to learners that there are no relevant financial relationships with ACCME-defined commercial interests for anyone who is in control of the content of the activity. The flowchart ends here—you’re done!
Helpful Tip: Make sure that you are using the correct definition of a commercial interest in your processes and forms. Otherwise, you may not get the information you need to ensure independence from commercial interests.
Beginning at B, use the flowchart for each person in control of the content of the CME activity. These may include planning committee members, staff, authors, content reviewers, and faculty.
Is the person an employee/owner of an ACCME-defined commercial interest?
If the answer is “no,” proceed to C.
If the answer is “yes,” proceed no further. Employees of ACCME-defined commercial interests are prohibited from having any role in the planning or implementation of CME activities related to the commercial interest’s business lines or products. (There are a few special-use cases where employees may have a specific, limited role. For more information, visit this Ask ACCME FAQ.
Helpful Tip: Have you checked for relevant financial relationships for all persons in control of content? Don’t forget staff, reviewers, and planning committee members in addition to authors and speakers/presenters.
Does the person have a relevant financial relationship with an ACCME-defined commercial interest?
The flowchart provides a four-question checklist to determine whether a relevant financial relationship exists—per ACCME expectations—therefore creating a conflict of interest. A relevant financial relationship exists only if you affirm all four statements.
- Relevant financial relationship between person in control of content (or their spouse/partner) and an ACCME-defined commercial interest
- To better understand how the ACCME defines relevant financial relationships, see this Ask ACCME FAQ. Remember that the financial relationships of the person’s spouse or partner count. (Please note that the ACCME’s definition of relevant financial relationships does not include faculty honoraria, even if the activity is commercially supported, since the financial relationship is between the faculty and the CME provider, not between the faculty and the commercial interest.)
- Any amount ($)
- A financial relationship of any value counts — there is no minimum threshold. For more explanation, see this Ask ACCME FAQ.
- In the past 12 months
- ACCME requirements are concerned with relevant financial relationships of the person in control of content (and/or or their spouse/partner) that existed within the 12 months prior to the CME activity.
- Products/business lines of the ACCME-defined commercial interest (with which they have the relationship) are related to the content of the CME activity
- Check this box if the content of the CME is related to the products and/or business lines of the ACCME-defined commercial interest with which the person in control of content has a financial relationship. It doesn’t matter what type of relevant financial relationship exists — what matters is whether the content of the CME is related to the products and/or business lines of the commercial interest.
The ACCME considers financial relationships to create conflicts of interest in CME when individuals have both a financial relationship with a commercial interest and the opportunity to affect the content of CME about the products or business lines of that commercial interest.
Helpful Tip: Consider using the ACCME Performance-in-Practice Structured Abstract to record relevant financial relationships.
If you affirm all four statements, proceed to D.
If you are not able to affirm all four statements, there is no relevant financial relationship for the person in control of CME content. Before the CME activity, disclose to learners that the person has no relevant financial relationships with ACCME-defined commercial interests. There is nothing more that you need to do.
You’ve determined that the person in control of content for the CME activity has a relevant financial relationship that creates a conflict of interest. The next step—before the CME activity takes place—is to take an active role to resolve the conflict of interest and disclose to learners the name of the individual, the name of the ACCME-defined commercial interest with which they have a relevant financial relationship, and the nature of the financial relationship.
There are a number of approaches you can use to resolve conflicts of interest. The flowchart includes several examples, but you can find more practice-based examples from accredited providers on the ACCME website page Examples of Compliance and Noncompliance for Criterion 7.
Helpful Tip: Be sure to use a process that is appropriate for the person’s role. Approaches to resolve conflicts for speakers may not be applicable to planners and vice-versa.
The flowchart is derived from ACCME’s requirements concerning the role of commercial interests (Standard 1), financial relationships for those in control of content (Standard 2.1), resolution of personal conflicts of interest (Standard 2.3), and disclosure of relevant financial relationships to learners (Standard 6.1). The ACCME website provides a number of resources that providers and other educational stakeholders may find helpful. These include the requirements, Ask ACCME frequently-asked-questions, and educational videos. ACCME also hosts educational workshops and meetings that address activity planning, including understanding and implementing the ACCME Standards for Commercial Support: Standards to Ensure the Independence of CME Activities.
If you have questions or would like more information, we’re happy to help. Please contact us at [email protected].