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Management of Accredited CME/CPD Activities and External Financial Support Procedure
Definitions
Accredited CPD Activity — An educational event that meets the administrative, educational and ethical standards of the Royal College of Physicians and Surgeons of Canada and College of Family Physicians of Canada. Accredited CPD activities include group learning, self-learning and assessment, in a live or electronic format.
College of Family Physicians of Canada (CFPC) — The professional organization responsible for establishing standards for the training, certification and lifelong education of family physicians and for advocating on behalf of the specialty of family medicine, family physicians and their patients.
Commercial Interest — For-profit entities that develop, produce, market, re-sells or distribute drugs, devices, products, or other healthcare goods, services or therapies that may be prescribed to patients or ordered by doctors in the diagnosis, treatment, monitoring, management or palliation of health conditions.
Commercial Support — Financial or in-kind contributions given by a commercial interest, which is used to pay all or part of the costs of an educational activity. “In-kind” includes the loan or donation of equipment, supplies, and/or services; and the provision of staff that are paid by a commercial interest.
Conflict of Interest (COI) — A set of conditions in which judgement or decisions concerning a primary interest (example a patients’ welfare, the validity of research and/or quality of medical education) is unduly influenced by a secondary interest (personal or organizational benefit including financial gain, academic or career advancement, or other benefits to family, friends, or colleagues).
Continuing Professional Development (CPD) — An array of educational activities that health professionals undertake to maintain, develop, and enhance the knowledge, skills, professional performance, and relationships they use to provide care for patients, the public, and the profession.1 Campbell, Silver, Sherbine, Cate, & Holmboe, 2010 2 Labrecqu et al, 2010 3 Sargeant et al, 2011
FoM Designated Teaching Site — A site not located within the Memorial University (Memorial) campus which has been designated by the Faculty of Medicine (FoM) as appropriate for providing Continuing Medical Education (CME) and Continuing Professional Development (CPD) activities.
Ghostwriting — Occurs when a paid professional writer, whether or not medically trained, writes something credited to someone else.
Royal College of Physicians and Surgeons of Canada (RCPSC) — The national professional association for specialists with the mission of improving the health and care of Canadians by leading in medical education, professional standards, physician competence and continuous enhancement of the health system.
Speaker Bureau — An arrangement in which speakers are under contract to a company, and thus are agents of the company, and the speaker does not have editorial control of the content.
Procedure
A.0 Planning CME/CPD Sponsored Activities
A.1. All accredited CME/CPD programing at the FoM must be planned and delivered in partnership with OPED to ensure strict compliance with accreditation requirements. Program planners are advised to contact OPED at least three (3) months in advance of the anticipated program delivery date to allow adequate time for development of a high-quality, accredited program.
A.2. A discipline/department may enter into a partnership arrangement with OPED in planning/delivering a CME/CPD program. However, if the program is to receive sponsorship from an external organization, then the discipline/department or faculty member must enter into a partnership arrangement with OPED for the development and delivery of accredited activities. The written agreement must outline the terms, conditions, and purposes by which the sponsorship is provided.
A.3. External organizations (to the FoM) planning to offer CME/CPD program(s) at the FoM or a FoM designated teaching site must enter into a partnership arrangement with OPED in planning/delivering a CME/CPD program. OPED holds the right to refuse activities that do not meet accreditation standards or are deemed inappropriate for a FoM audience.
B.0 Educational Material, Advertisement and Branding
B.1. All FoM faculty, staff, and learners are responsible for ensuring the scientific validity, objectivity and completeness of the content of any publication, presentation or slides presented in their name. Under no circumstances will any of the stated be listed as co-authors on professional presentations, such as CME/CPD presentations or research presentations, oral or written, that are ghostwritten by any party.
B.2. The objectives and content of all educational activities must be determined by the program planners and/or planning committee members.
B.2.1. The scientific planning committee must include representatives from the intended target audience.
B.3. OPED develops CME/CPD activities independent of any commercial interest. Commercial interests are not permitted to be involved in the following:
B.3.1. Identification of practice gaps and needs that become the foundation for the program;
B.3.2. Preparation of, or input into, the learning objectives of the program;
B.3.3. Selection and presentation of content;
B.3.4. Recommendation of persons to serve as speakers for a program or any other persons that will be in the position to control the content of the program;
B.3.5. Influence over the selection of the educational design for the program;
B.3.6. Selection of vendors or methods for the evaluation of the program;
B.3.7. Requests for “technical review” of the content of the CME/CPD program.
B.4. Descriptive terminology should be employed rather than brand names for pharmaceuticals (e.g., generic chemical names), medical technologies and devices. To avoid learner confusion, it is permissible to introduce a brand name in conjunction with its generic equivalent if this promotes learning.
B.5. To ensure FoM CME/CPD activities do not promote the interests of product manufacturers, the following safeguards are in place to monitor this separation:
B.5.1. Activities Linked to Analysis of Learner Gaps and Other Needs— CME/CPD activities are planned based on clear gaps in knowledge and/or performance, the expert opinions of recognized experts in the field, evidence-based guidelines or authorities’ description of best practices. Particular emphasis is placed on quality improvement and innovative learning methods.
B.5.2. Content Validation Practices—Planning committee members, presenters, moderators, facilitators and authors must disclose to participants any financial affiliations with manufacturers of products mentioned at the event or with manufacturers of competing products. OPED has developed a standard form for this purpose to be used in the planning stages for all activities. Content planners and course faculty are required to attest that commercial bias is not present and that the educational material is scientifically accurate, based on evidence acceptable to the profession, and that treatments discussed are appropriate. If specific products or services are mentioned, there should be a balanced presentation of the prevailing body of scientific information on the product or service and of reasonable, alternative treatment options. If unapproved uses of a product or service are discussed, presenters must inform the audience of this fact.
B.5.3. Retrospective Learner Feedback—Evaluation mechanisms must be in place which assess the degree to which an accredited CPD activity:
B.5.3.1. Met the stated learning objectives;
B.5.3.2. achieved appropriate balance; and,
B.5.3.3. was perceived to be bias.
B.5.3.3.1. If a bias is perceived, this information must be provided to the planners, faculty and others so that an improvement plan can be determined and outcomes of the improvements monitored.
B.6. Commercial marketing and product messaging is forbidden within accredited CME/CPD programs. All FoM medical education syllabi, brochures, course websites, lecture slides, etc. must be entirely free of commercial marketing or product messaging such as logos, slogans etc. If the presentation or program is accredited then accreditation guidelines permit use and acknowledgement of commercial support in a limited manner and these guidelines must be followed.
B.7. Promotion of FoM CME/CPD by commercial interests is forbidden. FoM CME/CPD activities may not be marketed by commercial interests (e.g., on their websites or by their representatives), unless these programs were co-developed or co-sponsored, because this could be misunderstood to imply a relationship that does not exist.
B.8. The MUN Logo and the FoM Logo are branding/service marks of Memorial. Memorial owns these logos and, when used for the purposes of CME/CPD activities, either or both of these logos may be used by a discipline/department in the FoM only with the permission of OPED.
C.0 Commercial Support and Conflict of Interest Disclosure
C.1. All commercial support or sponsorship designated for accredited CME/CPD will be directed to, and managed by OPED. An individual faculty, staff, and student of the FoM cannot receive direct payment from a commercial entity for taking part in a FoM CME/CPD program.
C.2. OPED will acknowledge the receipt of any educational grants from commercial interests and makes this information known to learners prior to the offering of a CME/CPD activity. This information is provided through the publication of a general statement in the activity syllabi or in handouts or in online activities by acknowledging all in-kind and monetary support received for all activities.
C.3. OPED must ensure the disclosure of any real or apparent conflict of interest of speakers, planning committee members, and other individuals who play a role in influencing the content or subject matter by way of presentation or planning. The existence of commercial or financial interests of speakers related to the subject matter of their presentation(s) should not be construed as implying bias or decreasing the value of their presentation(s). However, disclosure should help participants form their own judgements. The disclosure of any identified conflicts of interests will be identified as per requirements outlined within the guidelines referenced in this policy.
D.0 Endorsement of and/or Participation in CME/CPD Activities
D.1. Faculty are expected to make speaking engagements and participation in FoM sponsored/endorsed CME/CPD activities a priority over outside speaking engagements with industry/private sector events.
D.2. Members of the FoM are discouraged from attending CME/CPD accredited activities that fail to follow the Innovative Medicines Canada Code of Ethical Practices.
D.3. The content of industry/private sector sponsored journal clubs must follow the general guidelines of accredited CME/CPD activities in that the content is to be determined by the learners under supervision of faculty. There must be no overt or covert advertising or marketing taking place during this activity. Further, faculty, staff, and students are prohibited from accepting payment for simply attending a CME/CPD event or accepting gifts at such activities. With the exception of presenting research results from industry-sponsored projects, faculty are discouraged from joining ‘speakers’ bureaus’.
D.4. Faculty members have special knowledge and competencies and may wish to share these with others especially when they can enhance the reputation of MUN. Consulting contracts with industry related to medical education or medical products (such as pharmaceuticals and devices) should be identified in a timely manner to their Vice-Dean/Associate Dean/Assistant Dean/Dean, Chair or Department Head. Clinical faculty should consult the CMA Guidelines for Physicians on Interactions with Industry concerning the nature of their interactions. Such contracts must provide details on specific tasks and deliverables, and the payment must be commensurate with the tasks assigned. The content of any materials produced or presented must not imply that Memorial, FoM approves of, or endorses, a specific product, service or treatment. Arrangements that pay faculty without clearly defined associated duties are considered gifts and are prohibited. A Memorial, FoM approved disclaimer must be used in the materials produced. Consult Memorials Conflict of Interest policy for clarification.
D.5. Faculty are not authorized to commit the name of the University in any outside professional activity unless agreed, in writing, by the Vice President (Academic). Faculty are permitted to state the nature and place of his or her employment, rank and title, in connection with outside professional activities, provided that he or she shall not purport to represent the University or speak for it, or to have its approval unless that approval has been given in writing.
D.6. Memorial financial and travel policies and guidelines will be followed for all CME/CPD activities offered by OPED.