Employees or Owners of Ineligible Companies
UUCME policy matches ACCME standards that any employee or owner of an ineligible company must be excluded from controlling the content of a CME activity. This includes planners, speakers, moderators or in any other role.
For UUCME, this issue tends to come up with University faculty who have been involved with a biotech company that they may have founded or own equity in as they invented or discovered something, even if that something is licensed and company registered through the University. Review the definition of an ACCME-defined ineligible company, employees and owners here and specifically includes “Bio-medical startups that have begun a governmental regulatory approval process”.
In rare circumstances, speakers may be able to contribute if they meet one these three specific situations:
- When the content of the activity is not related to the business lines or products of their employer/company.
- When the content of the accredited activity is limited to basic science research, such as pre-clinical research and drug discovery, or the methodologies of research, and they do not make care recommendations.
- When they are participating as technicians to teach the safe and proper use of medical devices, and do not recommend whether or when a device is used.
Planners who are employees or owners of an ineligible company will not be allowed as the planning role does not allow for any of the above three specific situations.
If an apparent employee or owner of an ineligible company is desired as a speaker of a CME activity, UUCME staff will work with directors/coordinators to ascertain details of the ineligible company and the content. If UUCME determines the person is an employee or owner of an ineligible company, the activity director will be educated on the policy and issues surrounding this topic. The director as the content expert and UUCME will determine if the three special cases above apply and what next steps will be taken.
However, you should know about this restriction and try to plan activities without the involvement of employees or owners of ineligible companies. These relationships cannot be mitigated. You may be asked to replace the employee or owner in your activity or you may not be able to provide CME credit for the affected portion of your activity. If credit is not offered, this becomes a non-accredited and promotional section and must take place completed separated from the education, including not occurring within the educational space within 30 minutes before or after the education and be labeled and communicated clearly as not accredited.
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