Conflict of Interest Identification and Management
It is vital that Continuing Medical Education is free from commercial bias. All individuals involved in planning or presenting educational content must undergo conflict of interest identification and management. Financial conflicts with commercial interests must be identified, managed, and shared with participants.
What is a Conflict of Interest?
A Conflict of Interest arises when an individual has a relevant financial relationship with a commercial interest (a pharmaceutical company or medical device manufacturer) whose products or services are used on (or consumed by) patients and will be discussed at a CME activity.
Identify and Manage Conflicts of Interest in 3 Easy Steps:
Step 1. Identify Individuals with Financial Relationships Relevant to the Educational Activity
Part A: Perform an Annual Review of All Existing Financial Relationships.
Each year, educational planners, co-planners, content presenters and conflict of Interest managers must review their existing personal financial relationships (and those of their spouse or partner) and record them in MiCME.
For University of Michigan Medical School faculty, the annual reporting period is July 1 through June 30.
For all others, the annual reporting period begins with the date financial relationships are entered or updated in MiCME.
Part B: Identify Conflicts for each activity.
The list of existing financial relationships must be reviewed for relevance to the content of the educational activity using the Conflict of Interest Identification Tool. If a relevant financial relationship is found, this is a TRUE CONFLICT OF INTEREST that must be managed before an individual can plan or present the educational content.
Step 2. Manage All Identified Conflicts of Interest
A TRUE CONFLICT OF INTEREST must be managed before an individual can plan or present at a CME activity. The identified conflicts must be reviewed by a Conflict of Interest Manager (the Educational Planner by default). If the Educational Planner also has financial relationships relevant to the educational activity they can’t serve in this role and a different individual (familiar with the subject matter but without financial conflicts) must be given the role.
The Conflict of Interest Manager works with the Educational Planners and Content Presenters to ensure that all identified conflicts are managed and that the educational activity is free from bias. They review the relationship and assess its potential effect on the educational content to make one of the following determinations:
- The Conflict is INACTIVE - financial relationship ended more 12 months ago.
- The Conflict is NOT RELEVANT - “Activity plans and/or educational content were reviewed and found not to be relevant to the identified financial relationship(s).”
- The Conflict IS RELEVANT but can be managed - “Activity plans and/or content were reviewed and found to be relevant to the identified financial relationship(s). Conflicted educational planners will remove themselves from all planning decisions related to conflicted content, and non-conflicted planners will make all final planning decisions. Content presenters will discuss products/services in generic terms only, with no discussion or recommendation of specific products.”
- The Conflict IS RELEVANT and cannot be managed - Activity plans and/or proposed content were reviewed, are relevant to the financial relationship(s), and the conflict is unable to be resolved. The individual can have no role in the activity (educational planning or presentation of content).
Step 3. Share the Activity Information with Participants
Educational Planners must share information about conflict of interest management with all participants before an educational event even if there are “no financial relationships relevant to the content of the educational activity.” MiCME generates an Activity Information document that summarizes the presence or absence of conflicts of interest for all individuals in control of educational content (i.e., planners, co-planners, presenters), as well as the steps taken to manage the identified conflicts of interest. This information can be easily shared with participants.
Conflict of Interest Identification and Management - Frequently Asked Questions
Q. Are there any Financial Relationships that do not create a conflict of interest?
A. Yes, the accrediting body for CME has decided that the following do not cause a conflict of interest, financial relationships:
- With non-profit organizations or government entities.
- With companies that don't produce health care goods or services, including companies whose sole business is basic science or research, artificial intelligence, electronic health records, or health information/technology.
- Where payment is not received directly by an individual (eg. distributed to the institution or department.
Q. Who cannot plan or present educational content at a CME activity?
- Individuals who do not complete the Conflict of Interest Management process.
- Individuals who are employees or owners of a commercial interest, except in some very rare instances. Note: Consultants are not considered employees.
Q. I’m a faculty at Michigan Medicine, I already disclose my existing financial relationships through the M-Inform portal, why can't you use that data?
We already do! MiCME is linked to the M-Inform database for all faculty at Michigan Medicine. All information regarding existing financial relationships in the system is automatically copied over to MiCME. We want to eliminate any duplication of effort and help you review and check the relevance of any financial relationship to the educational content.
Q. When do Conflicts need to be Managed during the process?
The timing depends upon the individual’s role:
- For Planners and Co-Planners, all relevant financial relationships must be identified and managed before the CME application is submitted.
- For Content Presenters, all relevant financial relationships must be identified and managed before the start of the CME activity.
Q. How can the Conflict of Interest Identification and Management Process be monitored to ensure it remains on track and the activity can go ahead as planned?
The Conflict of Interest Management Summary is used to monitor which financial forms have been completed and if conflicts have been managed. Once all financial information has been submitted, the information must be shared with participants.
Q. How does the Educational Planner assess the participants’ overall perception of commercial bias for the activity?
Participants may complete an evaluation after each activity, providing feedback on whether the content was biased. These evaluations must be reviewed by the Educational Planner to confirm the activity was free of commercial bias. If biased content was detected the Educational Planners should contact the Office of CME and Lifelong Learning so that appropriate action can be taken for future activities.