In-CE

Compliance Cases in Focus

Incomplete Disclosure: The Pitfall of Self-Determined Relevance

Context

Accredited Provider ABC collects financial relationship information from planners, faculty, and others in control of educational content over the prior 24 months. Their disclosure mechanism includes the ACCME Standard’s definitions of ineligible companies and relevant financial relationships, along with instructions to fully complete the disclosure process.

Compliance Issue

During their most recent audit, Accredited Provider ABC was found non-compliant. Despite including detailed definitions and instructions, they failed to meet the Standard’s requirements. The provider was confused by the finding, believing their disclosure process was thorough.

Analysis

According to ACCME Standard 3.1, individuals in control of educational content must disclose all financial relationships (of any amount) with ineligible companies, regardless of their perceived relevance to the educational content. Allowing individuals to self-assess relevance leads to incomplete disclosures, violating the standard.

Strategy

According to ACCME Standard 3.1, individuals in control of educational content must disclose all financial relationships (of any amount) with ineligible companies, regardless of their perceived relevance to the educational content. Allowing individuals to self-assess relevance leads to incomplete disclosures, violating the standard.

Practical Tips

  • Require disclosure of all financial relationships, regardless of perceived relevance.
  • Make it clear that relevance is determined by the provider, not the individual disclosing.
  • Regularly review and update your disclosure mechanism to align with current standards