UCSF Policy to Identify and Mitigate Financial Relationships

In accordance with the Standards for the Integrity and Independence of Accredited Continuing Education ("Standards"), it is the policy of the UCSF Office of CME (OCME) to ensure balance, independence, objectivity, and scientific rigor in all of its continuing education activities. OCME requires that all personnel involved in planning, production, and teaching of CE activities to disclose all financial relationships with ineligible companies and mitigate them prior to the CE activity.  The 2020 Standards call for accredited providers to produce accredited CE that is independent and free of the control of defined ineligible companies. Each CE activity is planned, presented, and evaluated in accordance with these national standards.

To ensure independence, OCME requires that, for each accredited activity:

1. Each individual in a position to influence or control CE content must disclose all financial relationships held within the previous twenty-four (24) months with any defined ineligible companies.  (IDENTIFY)

2. Any individual involved with planning or teaching in a CE activity who discloses a relationship with an ineligible company that creates a conflict of interest with the content of the activity must have that conflict of interest mitigated prior to assuming his or her role in the activity.  (MITIGATE)

3. The relevant financial relationships with ineligible companies of planners and speakers (or lack thereof) must be disclosed to learners prior to the learners’ participation in the continuing education activity. Information provided in this manner includes the name of the individual, the name of the ineligible company, and the nature of the relationship(s) the person has with each company. A statement that financial relationships have been mitigated must follow the disclosure statement.  (DISCLOSE)

Ineligible Company: As defined by the Standards, an ineligible company is one that is ineligible to be accredited in a national accreditation system (ACCME, ACPE, ANCC, etc.), whose primary business is producing, marketing, selling, re-selling, or distributing healthcare products used by or on patients. We do not consider providers of clinical service directly to patients to be ineligible companies except when the provider of clinical service is owned, or controlled by, a defined ineligible company.

Relevant Financial Relationship with an ineligible company: A financial relationship of an individual is considered relevant if it is with an entity that produces, markets, resells or distributes health care goods or services that is directly related to the content of a continuing education activity.

The following UC and UCSF policies are relevant to the Standards for Integrity and Independence in Accredited Continuing Education:

1. UCSF Continuing Education Faculty Financial Relationships Policy Updated version coming soon
2. UCSF Industry Relations Policy
3. University of California Health Care Vendor Relations Policy
4. UCSF CME Policy on Speakers' Bureaus
5. UCSF CME Commercial Support Policy Updated version coming soon
6. UCSF CME Exhibitor & Promotion Policy Updated version coming soon

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