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
    • Presenters
    • 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:

  1. Course director identifies a financial relationship with a commercial entity on her/his disclosure form
  2. 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
  3. 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:
      1. No resolution is required
      2. The content does not need to be changed in any way
      3. 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.