Commercial Support Policy and Independence of both Continuing Medical Education and Non-Accredited Offerings (Adopted February 2019)
Conflict of Interest Disclosure Form
Overview and Purpose
The International Atherosclerosis Society (IAS) has a tradition a mission of global leadership in delivering medical policy statements and supporting education activities consistent with its mission and free from commercial bias and influence in both the design and delivery of continuing medical education (CME) accredited and non-accredited education activities. We value the independence of education based on the trust of the clinicians served and organizations represented in our membership. Through adherence to this policy we ensure that the development and design programs reflect integrity and build confidences in our ability to design and deliver quality programs and activities which seek to meet the needs of clinicians and ultimately have positive impact in the care of patients.
This policy along with the organizational bylaws, require that all leaders, faculty, planners, and partnering education institutions adhere to standards for the declaration of conflicts of interest whether in a CME offering or non-accredited offering. This methodology ensures clear declaration of conflicts of interest and resolution of all matters pertaining to education and ensures the integrity of education offerings. Methods of resolution to ensure the activities of the organization reflect integrity and that the educational offerings of the Society remain free of commercial influences that jade the objectivity of the organization. This policy also requires the full disclosure of all commercial interest and support to all interested parties and participants whether the contribution be financial or in-kind.
ACCME Commercial Support Standard
Further, the IAS has adopted that it adheres to Criterion 7 related to independence or the current exiting “Standards of Commercial Support” identified by the Accreditation Council for Continuing Medical Education (ACCME) in both the design and delivery of all types of continuing medical education activities and programs.
Other Accreditation Standards
Other accreditations, such as EBAC , the Royal College of Physicians or other local accreditations, are sometime appropriate for the activity being offered, and are sometimes the preferred or widely accepted standard in various parts of the world. However, the IAS will respect such accreditations but shall adhere to the most stringent standard or default to the ACCME standard for practicality in establishing this policy.
Independence in Accredited CME Activities
As discussed, the IAS will remain independent and that all decisions involved in the planning of a CME activity are made free of control or inducement by a commercial entity. The IAS will control the process based on its own independent assessment of needs based gap analysis, definition of educational objectives, the identification of faculty and content, the method presentation and the evaluation methods to measure attainment of knowledge, change in practice, or activity satisfaction. Independence also means that the IAS cannot accept inducements or other conditions such as naming of faculty, payment of participants or participant expenses, as a condition of financial contribution to the activity.
Commercial Interests in Non-Accredited Education Activities
The IAS recognizes that the medical profession is in an environment in which the education of clinicians exists in an environment where commercial entities also seek to educate and advise clinicians. This is particularly important in underserved areas and populations where this type of commercially supported activity is often the only source of medical education content. In our mission, we recognize that there is value and merit in reaching underserved populations and to such ends the activities of commercial supporters often align and coexist. Such activities, when considered, must not conflict with the standards supported by this policy. The ACCME standards require that a commercial interest cannot take the role of nonaccredited partner in a joint sponsorship relationship that has been established to design and present a CME activity.
As such, IAS participation non-accredited activities must also remain independent and never under the auspices of the commercial interest. All parties must agree that there shall be no commercial promotion, commercial placement, or advertising, in the presentation of the education activity and there shall be no control, influence, or direction of messaging required by any commercial supporter, in the delivery of scientific content by those selected to present or any IAS allied member institutions or IAS faculty or reviewer assigned. All disclosures of support and all conflicts of interest must be declared. If such relationship is found to be corrupted , in violation of the spirit of these policies, or without remedy, the IAS will remove its name or any endorsement, participation, or approval of such activity immediately.
Maintaining Boundaries with Commercial Supporters
As a non-profit 501C 3 entity, the IAS is often dependent on funding for its activities and offerings. As such there is a need to be able to understand the objectives of potential funders to evaluate the potential of success and achievement of organizational goals in the delivery of any IAS activity. It is also the desire of the IAS not to entangle potential commercial supporters into discussion which would prohibit their ability to meet their own compliance and commercial standards for education.
As such the IAS shall maintain a boundary for establishing dialogue with commercial entities that only allows for clear discussion, but which is free from tying support to activities based on commercial interests. In such the IAS will only seek to understand the commercial supporters perspective in potential grant support of proposals and activities based on emerging science, clinicians gaps in knowledge, application of guidelines, lack of guidelines, or the need to better define practice patterns in the pursuit of patient care advances. The IAS will also seek to understand the best methods of application for any such possible support.
Board, Leadership and Staff
The organizational Bylaws adopted May 21, 2013 in Section XXII require conflicts of interest be declared and resolved in all matters of society activities. This policy shall require that all Board, Leadership and Staff declare in writing their full conflict of interest pertaining to any activity of the IAS and any commercial supporter as soon as known or as soon as invited into the planning of any activity of the IAS. Therefore anyone or any entity in a position to control the content of an education activity must disclosed to the all relevant financial relationships with any commercial entity for the past twelve months at the beginning or any IAS activity or if such relationship is established during the planning or development phase. In accordance with ACCME standards, any individual who refuses to disclose conflict of interests and relevant financial relationships must be disqualified from being a planning committee member, a teacher or an author of CME and cannot have control of or responsibility for the development, management, presentation or evaluation of a CME activity.
Disclosure of Conflicts and Commercial Support
Transparency with the public must be maintained. The IAS is required to disclose all conflicts of interest and the existence of commercial and non-commercial supporters in the brochure, website, slides, or other materials prior to the delivery of content to any participant.
The IAS will also disclose its grants and support in accordance with federal tax laws and the US Internal Revenue Service (IRS) 990 non-profit tax return of the association made in each tax year. Such return is available at www.irs.gov in the non-profit area and is public for inspection.