The Disclosure Compliance Process and Individual Requirements
So who is "in a position to control content"?
This can vary between activities. In general, such individuals may include:
- Course planners/directors/committee members
- Faculty authors
- Content reviewers
- Content editors
"Content reviewers" can include department chairs or division directors if, for example, these individuals are called upon to complete a conflict of interest resolution for a course director of a regularly scheduled series. Here's the scenario:
- Course director identifies a financial relationship with a commercial entity on her/his disclosure form
- The course director is the sole planner of the activity OR Co-director(s) for the activity also discloses a financial relationship with a commercial interest
- The department chair or division director is then asked to complete a conflict of interest (COI) resolution form in which she/he may identify that:
- No resolution is required
- The content does not need to be changed in any way
- Specific content changes are made to resolve the identified conflict
In this instance, we must provide disclosures for the presenter, the course director(s), and the department chair/division director to participants prior to the event.