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Policy for Interactions with Companies

Adopted by Board of Directors June 6, 2013

Mission Statement

The mission of the American College of Osteopathic Internists (ACOI) is to advance the practice of osteopathic internal medicine. Through excellence in education, advocacy, research and the opportunity for service, the ACOI strives to enhance the professional and personal development of the family of osteopathic internists.

Objective

It is the goal of the ACOI to ensure balance, independence, objectivity, and scientific rigor in all of its activities. Central to the mission of the ACOI is the advancement of initiatives that enhance the quality and efficiency of care provided throughout the healthcare system.

Advancing Transparency and Independence

There are policies and procedures that have been developed by third-parties that are commonly recognized codes of conduct for physicians and organizations. To this end, the ACOI supports the applicable policies presented in the following documents:

  • AdvaMed Code of Ethics on Interactions with Healthcare Professionals
  • American Osteopathic Association (AOA) Accreditation Requirements for Category 1 CME Sponsors Policy
  • Accreditation Council for Continuing Medical Education (ACCME) Standards for Commercial Support: Standards to Ensure Independence in CME Activities
  • Council of Medical Specialty Societies (CMSS) Code for Interactions with Companies
  • Food and Drug Administration (FDA) Guidance for Industry: Industry-Supported Scientific and Educational Activities
  • PhRMA Code on Interactions with Healthcare Professionals
  • The Physician Payment Sunshine Act

Independence

All ACOI activities are to remain free of control from commercial interests. A commercial interest is any entity producing, marketing, re-selling, or distributing healthcare goods and services consumed by, or used on, patients. To this end, all decisions related to the development and implementation of CME activities remain under the control of the ACOI and its applicable committees. Recommendations for speakers, topics, learning objectives, presentation content and evaluation of activities, among other things, by corporate interests will not be accepted.

All individuals involved with the development and implementation of CME activities will disclose with specificity any conflicts annually. Failure to disclose a conflict will result in an individual’s removal from any planning, implementation or review of an educational program.

Conflict of Interest

A conflict of interest exists when an individual has an opportunity to affect programmatic content about products or services of a commercial interest with which he or she has a financial relationship.

Procedure

The process for ensuring compliance with this policy applies a multi-step approach including prevention, surveillance, and monitoring and evaluation. The steps for each area are described below.

Prevention

All individuals who are involved with the planning and implementation of ACOI activities must sign conflict of interest disclosure forms prior to planning or implementation an activity. All relevant financial relationships with any commercial interest must be disclosed. Individuals subject to this requirement include, but are not limited to, activity course directors and program chairs, planning committee members, faculty, speakers, presenters, authors and editors, expert reviewers, moderators, and panel members. The disclosure must be provided in writing on the standardized ACOI Disclosure form. An individual who does not disclose relevant financial relationships will be precluded from participation in the development and implementation of ACOI activities. Copies of disclosure forms are available upon request.

Relevant financial relationships will be disclosed to learners prior to a continuing medical education activity. Information provided in this manner includes the name of the individual, the name of the commercial interest, and the nature of the relationship the person has with each commercial interest. Information that an individual has no relevant financial relationship will be disclosed in advance.

All faculty involved with planning or instructing a CME activity who disclose a conflict of interest must resolve that conflict prior to the CME activity. Appropriate mechanisms for resolution will be identified by the Continuing Medical Education Committee.

Evaluation/Monitoring for Bias

As part of the ACOI’s efforts to ensure the independence of its educational activities, the CME Committee will review all presentations and materials for potential conflicts of interest and bias. ACOI activity participants may be surveyed about perceived commercial bias as part of the post-activity evaluation.

Transparency

ACOI activities will be clearly identified as CME and non-CME activities. In the event that commercial support is provided, such support will be clearly identified at the beginning of the sponsored event and in any publication, print or electronic, created specifically for the activity. In addition, support provided to the ACOI will be acknowledged in an official ACOI publication following the conclusion of the sponsored event or activity.

Use of Commercial Support

The ACOI will make all decisions regarding the disposition and disbursement of commercial support in accordance with a signed letter of agreement. The agreement shall be signed by the ACOI, the commercial supporter and any third-party provider involved with the activity.

Accepting Charitable Contributions

The College may accept charitable contributions from individuals or commercial interests. The use of the contributions must be aligned with the College’s Mission. Contributions that are intended to influence any activities of the ACOI, CME or non-CME, will be declined. In addition, the ACOI reserves the right to decline any contributions for any other reasons. All donors will be recognized in an official ACOI publication and otherwise as approved by the Board of Directors.

Use of ACOI Name and Logo

The American College of Osteopathic Internists’ name and logo are the sole property of the ACOI. Their use is strictly controlled by the ACOI. The ACOI does not engage in the marketing or sales of any pharmaceutical products, medical devices or other material items used in the treatment of patients.

Amendment

These policies may be amended at any time by the ACOI Board of Directors.