Key Steps for the Identification, Mitigation, and Disclosure of Relevant Financial Relationships

As an accredited provider there are several steps we go through to ensure the content is independent and unbiased as it relates to disclosing financial relationships.  We hope by putting up this information on our website it serves as an educational process for joint providers looking to become more informed on the disclosure process and purpose

Step 1:  Before any work is done to organize and design educational content disclosure forms should be collected from all planners, faculty and others who would be in a position to control content.  The forms needed on file are designed to provide information about all financial relationships with ineligible companies over the previous 24 months.

An ineligible company are those whose primary business is producing, marketing, selling, re-selling or distributing healthcare products used by or on patients.

Step 2: Review any disclosed relationships and exclude owners and employees of ineligible companies from participating as planners, faculty or other roles unless the educational activity meets of the exceptions listed below.  There are only 3 exceptions that allow for owners and/or employees of ineligible companies to participate as planners or faculty in accredited continuing education.

  1. When the content of the activity is not related to the business lines or products of their employer/company
  2. When the content of the accredited activity is limited to basic science research, such as pre-clinical research and drug discovery, or the methodologies of research, and they do not make care recommendations
  3. When they are participating as technicians to teach the safe and proper use of medical devices, and do not recommend whether or when a device is used

Step3: Determine which financial relationships are relevant to the content of the continuing education activity, mitigate those relevant financial relationships to prevent commercial bias, and disclose the presence or absence of all relevant financial relationships to learners prior to the activity

  1. Determine relevant financial relationships for everyone in control of educational content. Financial relationships are relevant if the following three conditions are met for the individual who will control content of the education
    1. A financial relationship in any amount exists between the person in control of content and an ineligible company
    2. The financial relationship existed during the last 24 months
    3. The content of the education is related to the products of an ineligible company with whom the person has a financial relationship
  2. Mitigate relevant financial relationships prior to individuals assuming their roles in the education
  3. Before the leaner engages in the education, disclose to learners the presence or absence of relevant financial relationship for all person in control of content

Contents provided by the ACCME, for more information, visit

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