The Disclosure Compliance Process and Individual Requirements
Options for Disclosure
All relevant financial relationships must be disclosed to the learners before an activity begins. Individuals that report no relevant relationships must also disclose and that disclosure is shared with the learners prior to the activity taking place.
There are several different ways to disclose the financial relationships for anyone that has a role in the CME activity to the learners.
- Include the disclosure information in promotional material distributed to attendees
- Verbally announce the disclosure(s) to the learners before the presenters begin. This type of disclosure would have to be documented for the file.
- Provide a handout or an attachment to the brochure/program that has a summary of the disclosures the planners, presenters, etc. have made ().
- Second slide of the presentation being delivered to the learners. This way the learners will be aware of any disclosure information the presenter has and can determine for themselves if the presentation creates any conflicts of interest with the presenter’s financial relationships.
So how might we disclose this information to participants?
We're always looking for ways to make it easier for you and us to keep track of all this, so please feel free to send along any ideas that you have.
Right now, here are some options that are currently in use:
- Place the information in the promotional content distributed to potential participants
- Place the information on or next to the sign-in sheet used to record attendance*
- Place the information on the second slide of visual presentation(s) used to deliver content
- Disclose the information to participants in a document or spreadsheet distributed to all participants*
* This option only applies to regularly scheduled series (grand rounds) that involves presenters from inside its division/department only.
Evidence of how the disclosure was made to the learners must be documented and uploaded into the file. Examples and templates are provided in the next section.
The Division of CME is required to submit an annual report to the ACCME. From those reports, random files are chosen for review during reaccreditation (every 4-6 years). For the file to be complete, all disclosures and evidence of disclosure to the learners must be in the file. In our most recent reaccreditation, some of that documentation was missing from the files and we were found to be non-compliant for disclosure of the planners of the activities to the learners.