The Disclosure Compliance Process and Individual Requirements

The Disclosure Documentation Process

We must be able to demonstrate to the ACCME that we follow the disclosure requirements for any individual activity or regularly scheduled series. As a course administrator, we must rely on you to help us validate that the programs you manage follow these requirements, and that requirements are met through appropriate documentation.

  • Disclosure information is collected for anyone in the position to control the content of the activity (planning committee, speakers, moderators, etc.) before the activity begins
  • Any potential commercial conflicts of interest are identified and resolved
  • Disclosure (required) and Commercial Resolution Form (if needed) are uploaded into the file before the presentation
  • Disclosure of any commercial relationship (or lack thereof) are disclosed to the learners prior to the activity session in one of the CME approved formats
  • Evidence of disclosure to the learners for each activity session is uploaded into the file

We need your help in determining appropriate mechanisms for collecting evidence of disclosure without putting undue burden on you.

The next section provides some mechanisms for documenting disclosure. Please think about ways in which you can document the activities that you oversee; we're here to listen.

A last word on disclosure requirements:

According to the ACCME, the disclosure should occur within the past 24 months of the event (Click here for the policy wording).  If a person is acquiring or terminating a new relevant financial relationship within the 24 month period, it should be disclosed within 30 days of the event. As of 1/1/2021, planners and speakers need not disclose financial relationships of spouses or significant others.