According to the ACCME Standards for Integrity and Independence Standard 3: Identify, Mitigate, and Disclose Relevant Financial Relationships, the reason we must mitigate relevant financial relationships is to protect the integrity, independence, and credibility of CME activities and to ensure that educational content is free from influence by companies whose primary business is producing, marketing, selling, re-selling, or distributing healthcare products used on patients (these are called “ineligible companies”). By identifying and mitigating relevant financial relationships, planners create a safe, trusted learning environment where clinicians can engage in education that supports improved patient care without concern about hidden promotional agendas.
Steps to Mitigate a Relevant Financial Relationship
Based on the ACCME Standards for Integrity and Independence Standard 3: Identify, Mitigate, and Disclose Relevant Financial Relationships here are the structured steps a CME Planner need to follow:
1. Collect Disclosures from All Content-Control Individuals
Gather information from everyone in a position to control educational content—this includes planners, committee members, speakers, authors, reviewers, editors, instructional designers, and staff. Disclosures should cover all financial relationships with ineligible companies over the past 24 months, regardless of the amount or perceived relevance ACCMECollege of MedicineFoundation for Care Management.
2. Exclude Owners or Employees of Ineligible Companies (with Limited Exceptions)
Identify anyone who is an owner or employee of an ineligible company. Generally, they must be excluded from roles that influence content—unless one of three specific exceptions applies:
- Their role relates to content unrelated to the employer’s products;
- The activity is limited to basic science research, with no care recommendations;
- They function as technicians teaching safe device use, with no recommendations.
3. Determine Which Relationships Are Relevant
Review disclosures to identify which financial ties are relevant to the content. A financial relationship is considered relevant if:
- It exists with an ineligible company.
- It occurred within the past 24 months, and
- The educational content overlaps with the company’s business lines or products
4. Mitigate Relevant Relationships—Before Content Development Begins
Once a relationship is identified as relevant, take proactive steps—before the individual takes on their role in the activity—to mitigate potential bias. Mitigation steps should be tailored to the individual’s role in the CME:
For Planners, Committee Members, Reviewers:
- Recuse them from any aspects of planning/content related to their relationship;
- Alternatively, have their planning decisions reviewed by someone without such financial ties (peer review)
For Faculty, Speakers, Authors:
- Ask them to end or divest the financial relationship.
- Reassign them away from content tied to the conflict.
- Subject their content to peer review by someone without a relevant relationship.
- Require an attestation that their clinical recommendations are evidence-based and free of commercial bias
5. Document Mitigation and Review Process
Keep a detailed record of how each conflict was mitigated: what steps were taken, who reviewed or approved those steps, and when. Documentation should be accessible in the event of an audit.
CME Committee Migration Process:
- Peer review of all content by independent party
- Recusal from planning/content decisions related to relationship
- Reassignment to unrelated topic/content
- Divestment or termination of relationship
- Written attestation of evidence-based, unbiased content
6. Disclose to Learners—Before the Learning Activity Begins
Share with learners, ahead of time, the presence or absence of any relevant financial relationships. Disclosures must include:
- The individual’s name;
- The ineligible company involved.
- The nature of the relationship.
- A statement affirming that the relationship has been mitigated (if applicable).
- Also note individuals without relevant relationships to affirm transparency
If you have any questions regarding the mitigation process, please contact the CME Administrator.