Purpose

1.0 Purpose: The purpose of this policy is to ensure that MEBN meets the needs of the public interest as it relates to the creation of educational activities that are fair balanced, free from individual influence, unbiased, and created from evidence-based, sound scientific information and practice.

Scope

2.0 Scope of Policy: this policy will apply to all accredited educational activities within MEBN, its subsidiaries or divisions.

2.1 Persons Affected: Any person involved with an MEBN-sponsored educational activity who is responsible for or has control over the content or reporting of activities funded or proposed for funding must disclose all direct personal financial relationships or legal ties that could directly or indirectly affect the activity.

This list includes, but is not limited to:
Medical writers
Managing editors
Faculty reviewers and authors
Editorial Advisors

Definitions

3.0 Financial Disclosure is defined as the mandatory disclosure of all relevant, direct personal financial relationships or legal ties that could directly or indirectly affect an educational activity.

3.1 Financial relationships are those relationships in which the individual benefits by receiving a salary, royalty, intellectual property rights, consulting fee, honoraria, ownership interest (e.g., stocks, stock options or other ownership interest, excluding diversified mutual funds), or other financial benefit. Financial benefits are usually associated with roles such as employment, management position, independent contractor (including contracted research), consulting, speaking and teaching, membership on advisory committees or review panels, board membership, and other activities for which remuneration is received or expected. ACCME considers relationships of the person involved in the CME activity to include financial relationships of a spouse or partner.

3.2 Relevant is defined as a financial relationship or legal ties occurring in the past 12 months that creates a conflict of interest

3.3 Conflict of Interest occurs when individuals have both a financial relationship with a commercial interest AND the opportunity to affect the content of CME about the products or services of that commercial interest.

3.4 Independent Review Committee (IRC): An internal committee within MEBN consisting of the Director of Accreditation, the Director of Managing Editors, and the Director of Editorial.

Implementation

4.0 Policy Implementation:
MEBN uses a planning committee of in-house Editorial Directors, Managing Editors and expert (non-staff) Editorial Advisors to develop the scope and sequence for the CME activity. Once potential faculty members and an Editorial Advisor are identified, they receive a letter from MEBN inviting them to participate, and a request to complete and return a Financial Disclosure Form. 

Faculty are advised in writing that their participation may be modified if the Managing Editor or IRC determines that a conflict of interest exists between the faculty member and commercial supporter. In addition, all individuals involved in the planning process are required to return completed Financial Disclosure Forms. Completed Financial Disclosure Forms are reviewed by the Managing Editor.

Conflict Resolutions and Remedies

5.0 Resolution of Conflict of Interest:
The Managing Editor will examine situations of apparent and/or real conflicts of interest in order to assess circumstances under which relevant financial relationships may inappropriately conflict and may affect the content of the educational activity. If the Managing Editor is unable to resolve the conflict of interest using one of the methods described below or identifies a need to excuse him or herself from this duty, the IRC will be convened for this purpose.

If a real conflict is found, one or all of the following mechanisms for resolution of conflict of interest may be employed to resolve the conflict:

5.0.0 Counsel the individual regarding the nature of the conflict and describe our remedies and options
5.0.1 Assign the individual an area of content that is unrelated to the area of conflict
5.0.2 Change the scope of their role as primary author/editor of content that relates to discussion of the products or services of the commercial sponsor

5.0.3 Change their role in the review process to minimize their ability to affect/ influence content
5.0.4. Exclude product/service content as part of the individual’s commitment
5.0.5 Add additional faculty who have no financial interests in this subject area
5.0.6 Excuse the individual from their obligation to participate in this activity

5.1.0 Peer review process. The content written or reviewed by the faculty member with a conflict of interest will be reviewed by another commercially-disinterested peer to assure fair-balance, absence of commercial bias and that it meets the needs of the public interest. The independent review will be conducted in a blinded fashion to insure an objective review.

Responsibility to the Public

6.0 Public Trust Assurances

Regardless of whether any conflicts of interest are identified, MEBN ensures that for all activities:
6.0.1 Faculty are given clear instruction to avoid commercial bias prior to beginning work on an activity.
6.0.2 Content is developed that is based on best available evidence and is free from personal opinion.
6.0.3 Participants will be asked to evaluate the educational activity for the presence of commercial bias.

Production will not begin on any activity without review and approval of the Director of Accreditation that ALL conflicts of interest have been resolved. Anyone refusing to disclose will be disqualified from the planning and implementation of the activity.

This policy is approved by the Chief Operating Officer of MEBN.

Revision Date: 7/1/05

This policy will be reviewed on an annual basis or as needed throughout the year.