Administrator Support

Yes, there is a relevant financial relationship. We now have to mitigate this conflict somehow, and document that it has been mitigated. To do this, we will ask the appropriate institutional representative to complete a conflict of interest (COI) mitigation form.

If the individual who discloses a financial relationship is:	The appropriate person to conduct the mitigation process is:
An activity planner from outside the UAB community	A co-planner or other UAB faculty member familiar with the activity subject matter
An activity planner who is a faculty member at UAB	A co-planner or division director/department chair
A presenter or an activity planner who holds an upper-level administrative position within the department	to be determined in consultation with the UAB division of CME

The correct form to use will depend on whether the individual who discloses a financial relationship with a commercial entity is an activity planner or presenter (These forms are available in the documents library of our activity record system).

Activity Planner: Activity planning,either a single event or a regularly scheduled series, provides an individual with much more control over the content of an activity and therefore may require some extra steps to avoid the appearance of conflict. Along with identifying an appropriate reviewer as described above, options for mitigating such potential conflicts include:

•  No mitigation required - this is a potential conclusion, but must be accompanied by an explanation as to why that determination was made. For example, only basic science research may be involved, with no reference to specific drugs, drug families, therapies, or medical/diagnostic equipment. The activity may be purely didactic(e.g. as in a resident noon conference) and again, with no reference to any products or treatments.
• Divestment: The planner can divest themselves of the identified relationship.
• Withdrawal or recusal: The planner can withdraw entirely from involvement in the activity or can recuse her/himself from that portion of the activity that might give the appearance of a potential conflict. In such instances, the individual completing the form must provide an explicit statement that s/he will ensure that the individual is not involved in those portions of the program.
• Independent content validation: Planning process documentation and a sampling of content can be provided to the CME office for review.
• The planning committee may identify some other mechanism to resolve the potential conflict. Any such mechanism must be described in detail.

Conflict of Interest Mitigation form for planners

Activity Presenter: Presenters may come from inside or outside the institution, and a variety of organizations (but not organizations identified as ineligible entities except under a narrow set of circumstances). This can present additional challenges in reviewing potential conflicts of interest so please contact the office of CME when any questions arise. Typical options for mitigation include:

• "No mitigation required" - this is a potential conclusion, but must be accompanied by an explanation as to why that determination was made. For example, the presentation may include only basic science research, with no reference to specific drugs, drug families, therapies, or medical/diagnostic equipment. The presentation may be purely didactic, with no reference to any products or treatments. The presentation could also potentially be entirely outside of any topic area related to the presenter's area of expertise and/or financial relationship(s).
• Peer Evaluation: Someone with expertise in the topic area may review the content and determine that no potential commercial bias is present, or that certain changes to the presentation could exclude such potential bias.
• An independent review could validate that: content is valid and aligned with the interests of the public; b) all recommendations involving clinical medicine are based on best available evidence; c) all scientific research referred to, reported, or used in the CME activity in support, or as justification of patient care recommendations, conforms to the generally accepted standards of experimental design, data collection, and analysis.
• The planner(s) can alter control of the content by selecting a different presenter or changing the content itself.

Conflict of Interest Mitigation form for presenters

It's critically important to the mission of UAB CME that we ensure that all activities we certify are free of actual or perceived commercial bias. We need your help to ensure that this happens, so please reach out to us with any questions you might have related to conflict of interest.