The revised UMMS policy (effective September 2019) allows commercial support and associated exhibits for continuing medical education (CME). Commercial support is financial or in-kind gifts/contributions from an ACCME-defined commercial interest (referred to as "industry" in the policy) used to pay all or part of the costs of an accredited CME activity. A Written Agreement describing the terms of the financial support must be received and approved by the Office of CME and Lifelong Learning (OCME&LL) at least two working days before the planned educational activity (see “what you can expect from us”). All commercial support must be provided with the full knowledge and approval of OCME&LL.
Guidance for Commercial Support
OCME&LL has developed guidance to help Educational Planners and others navigate the commercial support process. The department has the primary role in ensuring all commercial support is compliant with medical school policy and the standards for commercial support from the Accreditation Council for CME (ACCME).
There are two types of Written Agreements; one generated by the Medical School (the Medical School Written Agreement for Commercial Support for Continuing Medical Education), and others generated by Commercial Interests (eg. a drug company or medical device manufacturer) called Third-party Written Agreements. The Medical School Written Agreement is compliant with all medical school policies and ACCME standards. Third-party agreements may contain terms and requirements that are inconsistent with medical school policy and ACCME standards.
Responsibilities of the Department
- Ensure that a CME activity is financially viable and any budget is independent of the promise of commercial support.
- Apply for funding 8-10 months in advance of the CME activity.
- Administer the review, revision, and approval process for all Written Agreements.
- The Medical School’s Written Agreement template should be used whenever possible and must be signed by the commercial interest. Standard Medical School Written Agreements are typically reviewed and approved by OCME&LL within two business days and do not require additional review by the Office of Regulatory Affairs (ORA) and Office of General Counsel (OGC).
- Any Third Party Written Agreements must be reviewed and approved by both the Office of Regulatory Affairs and the Office of General Counsel before final approval is sought from OCME&LL. The approval process can take anywhere between two to five months to complete, depending on the series of reviews and amendments required to ensure consistency with medical school policy and ACCME standards.
- Make all arrangements to receive funds. Checks should be payable to the University of Michigan (Tax ID: 386006309) and specify the name of the CME activity. Funds should not be deposited into departmental accounts until the Written Agreement has been received and approved by OCME&LL. A final activity budget describing how funds were spent is required during the Activity Close Out submitted within 30 days after the activity ends.
- Acknowledge and share with participants all commercial support before the activity begins. The nature of support (i.e., educational gifts, grants, loan of equipment) and the name of the company must be included (commercial logos must not be used). This information is conveniently generated by MiCME on the standard Activity Information announcement.
OCME&LL reserves the right to refuse or withdraw CME credit designation if a signed and approved Written Agreement is not provided before the start of the educational activity.