In-CE

Compliance Cases in Focus

When Disclosure Doesn’t Need a Form

Context

A speaker, constrained by international travel, couldn’t complete an accredited provider’s online disclosure form before the submission deadline.

Compliance Issue

The speaker offered to share her financial relationships with ineligible companies verbally by phone. The coordinator’s concern: Would this meet ACCME Standards for Integrity and Independence in Accredited CE?

Analysis

Under ACCME Standard 3.1, providers must collect financial relationship information from anyone in control of content. Importantly, the Standards don’t specify how that information must be collected. Electronic, written, or verbal – all are acceptable if:

  • The individual understands the definition and what qualifies as an ineligible company.
  • The disclosure is comprehensive and covers financial relationships within the past 24 months.
  • The provider documents the information collected in a verifiable way.

Strategy

The provider accepted the verbal disclosure after ensuring compliance safeguards. The coordinator reviewed the definition of ineligible companies with the speaker, confirmed all relevant relationships were disclosed, and documented the disclosure provided. This created a verifiable record, aligned with Standard 3.1.

Practical Tips

  • Documentation is key, particularly if disclosure is verbal. Keep a record.
  • Confirm the individual understands what qualifies as an ineligible company.
  • A provider’s disclosure collection method is flexible. Adapt processes when needed, as long as compliance requirements are met.
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