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NACE CME Policy Statement

NACE is accredited by the Accreditation Council for Continuing Medical Education (ACCME) to provide continuing medical education for physicians.

NACE operates in accordance with the ACCME Accreditation Requirements and the Standards for Commercial Support. These requirements and standards are designed to ensure that continuing medical education (CME) activities are planned and designed independently of commercial interests to meet the needs of the target audience.  NACE abides by the following policies to ensure that all CME activities are balanced, independent, objective, and scientifically rigorous.

CME Activity Planning (ACCME SCS 1.1)
NACE ensures that in design of a CME activity the following decisions are made free of the control of a commercial interest: identification of CME needs, determination of educational objectives, selection and presentation of content, selection of all persons and organizations that will be in a position to control the content of the CME, selection of educational methods, and evaluation of the activity.  

Disclosure Policy (ACCME SCS 2.1, 2.2, 6.1, 6.2)
It is the policy of NACE to ensure fair balance, independence, objectivity and scientific rigor in all CME activities. All individuals in a position to influence content, are required to disclose all relevant financial relationships with commercial interests prior to participating in the activity planning process.  In addition, all faculty participating in CME activities sponsored by NACE are required to present evidence-based data and identify and reference off-label product use.  Individuals who refuse to disclose relevant financial relationships with commercial interests are not permitted to participate as a member of the planning committee or faculty and cannot have control of, or responsibility for, the development, management, presentation, or evaluation of the CME activity.  

NACE publishes disclosure statements by individuals in a position to control CME content in activity materials so that this information is available to learners prior to participating in the activity. NACE discloses the name of the individual, the name of the commercial interest, and the nature of the relationship the person has with each commercial interest. For individuals with no relationship to disclose, NACE publishes that no relationships exist.

Conflict Resolution Policy (ACCME SCS 2.3)
It is NACE policy that all individuals in a position to influence content must disclose all financial relationships with commercial interests, and that any potential conflicts of interest be resolved prior to the activity.

If it is determined through review of the disclosure form that an individual meets the criteria for having a relevant conflict of interest, the individual will be provided with the NACE Conflict of Interest Resolution Form. This form requires the individual to attest to compliance with ACCME requirements and standards when developing or presenting content and the individual must adhere to the following:

  • All recommendations involving clinical medicine should be based on “best available evidence” and represent a standard of practice within the profession of medicine.
  • Personal or professional preference for those products or services may not be expressed. While you may indicate that you use a particular product or service in your practice, you must not make patient care or practice recommendations based on your “clinical experience” only.
  • It is required that relevant financial relationships be disclosed to participants prior to the activity.  Participants will be asked to evaluate the objectivity of the presentation, and to identify any perceived commercial bias.
  • Speakers’ presentations should be submitted for peer review and content validation. If any content falls outside the requirements, you must revise or delete them. You must alsoadhere to these standards in your formal presentation, syllabus contributions and in any question and answer discussions.

 

If a conflicted faculty member or planner, is unable to abide by the above requirements and/or will not revise content as requested by the reviewers during the content validation process, the faculty member will be disqualified from participating in the CME activity.

Content Validation (ACCME SCS 5.1, 5.2)
CME consists of educational activities which serve to maintain, develop, or increase the knowledge, skills, and professional performance and relationships that a physician uses to provide services for patients, the public, or the profession. The content of CME is that body of knowledge and skills generally recognized and accepted by the profession as within the basic medical sciences, the discipline of clinical medicine, and the provision of health care to the public.  The content or format of a CME activity must promote improvements or quality in healthcare and not a specific proprietary business interest of a commercial interest.  

NACE reviews all content through a content validation process before content is distributed to learners.  This process involves review by content area experts and/or the members of the NACE activity planning committee.

The purpose of the content validation process is to ensure:

  • learning objectives are addressed
  • content has fair balance and is free of commercial bias
  • the scientific objectivity of studies mentioned in the materials or used as the basis for content is maintained
  • recommendations involving clinical medicine are based on evidence that is accepted within the profession of medicine as adequate justification for the indications and contraindications in the care of patients must conform to the generally accepted standards of experimental design, data collection and analysis

 

If there are concerns identified by the content validation process, feedback may be requested from the course director, and if necessary, a separate expert peer review may be conducted.

Commercial Support (ACCME SCS 3.1, 3.2, 3.3, 3.4, 3.5, 3.6, 3.9, 3.12, 3.13, 6.3, 6.4, 6.5)
NACE recognizes the following organizations as commercial interests:
any entity producing, marketing, re-selling, or distributing health care goods or services consumed by, or used on, patients.
 
When financial or in-kind support is provided to NACE by a commercial interest in the form of an educational grant:

  • All commercial support associated with a CME activity must be given with the full knowledge and approval of NACE. NACE requires a letter of agreement between NACE, the commercial interest supporter, and if applicable the educational partner, outlining the terms, conditions, and purposes of the support. The agreement must be fully executed prior to the start of the CME activity.
  • No additional funds or in-kind support will be provided directly to the planning committee members, teachers, or authors beyond those defined in the agreement.
  • NACE is responsible for all decisions regarding identification of CME needs, determination of educational objectives, selection and presentation of content, selection of all persons and organizations that will be in a position to control the content of the CME, selection of educational methods, and evaluation of the activity.
  • NACE will not accept guidance or recommendations from the supporter regarding the content of the activity or the faculty involved in developing and delivering the content.
  • NACE makes all decisions regarding the disposition and disbursement of the commercial support funds and in-kind support received for CME activities. NACE may not use commercial support to pay for travel, lodging, honoraria, or personal expenses for non-teacher or non-author participants of a CME activity. All commercial support expenditures are documented and, upon request, provided to the commercial supporter.
  • Disclosure of commercial support for a CME activity is acknowledged and published in activity materials available to learners prior to participating in the activity. Corporate logos, trade names or product-group messages of a commercial interest are never used to disclose commercial support.

 

Separation of Education and Promotion (ACCME SCS 3.11, 4.1, 4.2, 4.3, 4.4, 4.5)
Social Events

  • Social Events or meals at CME activities cannot compete with or take precedence over the educational events.
  • Company-sponsored promotional meals or events are prohibited within the same space of an educational activity.

Live Activity Exhibits and Promotional Activities

  • Arrangements for commercial exhibits must not influence planning or interfere with the presentation of CME activities.
  • Exhibit placement should not be a condition of support for a CME activity.
  • No commercial promotional materials shall be displayed or distributed in the same room immediately before, during, or after a live CME activity.
  • All promotional exhibit or advertising participants of a CME activity will be provided with NACE’s Exhibitor Agreement that does not allow sales or promotional activities outside of their assigned exhibition space or while in the space or place of the CME activity
  • Representatives of Commercial Interests are not permitted to engage in sales or promotional activities while in the space or place of the CME activity.

Activity Materials

  • Educational materials that are part of a NACE CME activity content, such as slides, abstracts and handouts, cannot contain any advertising, corporate logo, trade name or a product-group message of an ACCME-defined commercial interest.  
  • Print or electronic information distributed about the non-CME elements of a CME activity that are not directly related to the transfer of education to the learner, such as schedules and content descriptions, may include product-promotion material or product-specific advertisement.  

Distribution of CME Activities to Learners

  • NACE does not allow commercial interests to serve as the agent providing a CME activity to learners, e.g., distribution of self-study CME activities or arranging for electronic access to CME activities.

Enduring and Electronic Activities
NACE prohibits product-promotion material or product-specific advertisement of any type in or during NACE CME activities.

  • The juxtaposition of editorial and advertising material on the same products or subjects is not prohibited. Live (staffed exhibits, presentations) or enduring (printed or electronic advertisements) promotional activities must be kept separate from CME.
  • For print, advertisements and promotional materials will not be interleafed within the pages of the CME content. Advertisements and promotional materials may face the first or last pages of printed CME content as long as these materials are not related to the CME content they face and are not paid for by the commercial supporters of the CME activity.
  • For computer based CME activities, advertisements and promotional materials will not be visible on the screen at the same time as the CME content and not interleafed between computer ‘windows’ or screens of the CME content. Also, ACCME-accredited providers may not place their CME activities on a Web site owned or controlled by a commercial interest. With clear notification that the learner is leaving the educational Web site, links from the Web site of an ACCME accredited provider to pharmaceutical and device manufacturers’ product Web sites are permitted before or after the educational content of a CME activity, but shall not be embedded in the educational content of a CME activity. Advertising of any type is prohibited within the educational content of CME activities on the Internet including, but not limited to, banner ads, subliminal ads, and pop-up window ads.
  • For audio and video recording, advertisements and promotional materials will not be included within the CME. There will be no ‘commercial breaks.’
  • For journal-based CME, none of the elements of journal-based CME can contain any advertising or product group messages of commercial interests. The learner must not encounter advertising within the pages of the article or within the pages of the related questions or evaluation materials.

Faculty Honoraria and Expense Reimbursement (ACCME SCS 3.7, 3.8, 3.10)
Honoraria Payments
The Accreditation Council for Continuing Medical Education (ACCME) Standards for Commercial Support (SCS 3.7, 3.8) make it clear that CME providers should be the ones to decide on the honoraria faculty are paid for their services. Honoraria paid to faculty is determined by a variety of factors:

  1. Industry averages regarding honoraria
  2. Amount of work required by faculty
  3. Amount of time required to develop the activity
  4. Amount of travel time required
  5. Specialty and national prominence of the faculty members

 

Any honoraria paid to a faculty member is clearly communicated prior to their agreement to participate in a CME activity. Payment of honoraria is made within 30 days of the program and after all faculty expenses have been submitted for reimbursement provided we have a W-9 Form on file.

Faculty may only accept honoraria, reimbursement or payment for their role at the CME activity from NACE or the joint provider. Faculty may not accept payment for their role in the CME activity directly from the commercial supporter.

Reimbursement for Out-of-Pocket Expenses
NACE requires the use of the NACE Faculty Expense Form to be reimbursed for all out-of-pocket expenses associated with participation as a faculty member, host/moderator, or planning committee member of a CME activity (i.e., mileage reimbursement, parking, meals, taxis). Receipts must be attached.

For faculty participating in a CME activity as both a speaker and learner, only expenses related to the speaker role will be reimbursed. Modest meal expenses will be reimbursed. The following expenses are not covered by NACE and will not be reimbursed:

  1. Limousine service
  2. Car service may need to be pre-approved by NACE (other than services such as Uber or a car service used for short distances such as travel to local airports, etc.)
  3. First class or business class air travel
  4. In-room movies
  5. Mini-bar charges
  6. Bar charges

 

Joint Providers (ACCME SCS 1.2)
NACE engages in joint providership with non-commercial interest partners.  A joint providership agreement is required between the joint provider and NACE.  The joint provider is required to maintain compliance with NACE CME policies. NACE does not allow commercial interests to serve as the non-accredited partner in a joint provider relationship.

Attendance Records
NACE verifies and documents participation of each learner participating in a NACE CME activity.

  • Learners are required to register for each CME activity prior to the beginning of the activity.  For live activities, learners can register online, by phone, or in-person on-site at the activity.  For online activities, learners must register online where the activity is hosted.
  • Learners are required to check-in upon arrival at each live CME activity, providing verification of attendance. 
  • Learners are required to attest to participation in the sessions that they attended at the live CME activity and claim only the number of hours of credit for the sessions they attended. For enduring CME activities, learners are required to check a button that they personally completed the course.
  • Upon completion of each activity, learners receive certificates verifying their participation in the CME activity.

NACE maintains records of participation in electronic and paper files for a minimum of 6 years.

Course Cancellations/Refunds
Should you need to cancel your registration for a NACE CME activity, please contact NACE by phone or email as soon as possible. No refunds permitted for paid courses.

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