Compliance corner: Identification and mitigation game

June 10, 2022
Area(s) of Interest: Continuing Medical Education (CME) 

The Accreditation Council for Continuing Medical Education (ACCME) Standards for Integrity and Independence in Accredited CE Standard 3: Identify, Mitigate, and Disclose Relevant Financial Relationships is an area of great importance, but also an area in which many accredited continuing medical education (CME) providers are found non-compliant at time of accreditation. The goal of accredited continuing education is to protect learners from commercial bias and marketing. The California Medical Association (CMA) has created this fun and informational game to help understand these standards.

Identification and mitigation of relevant financial relationships is the responsibility of you, the accredited CME provider, to determine which financial relationships may be allowed to control content related to the business lines or products of an ineligible company, and to take steps to prevent insertion of bias toward commercial products or services.

With all accredited CME, start with collecting financial relationships from prospective planners, faculty, and others in control of content for your activity, and exclude owners or employees of ineligible companies. In our game, we have collected financial relationships already.

You will begin by reviewing the information to determine whether each person’s financial relationships with ineligible companies are relevant to the content of the education case.

Next, choose a mitigation strategy, appropriate to the person’s role, for each person who has a relevant financial relationship. The strategy must be implemented before the person assumes their role.

An ineligible company is any entity whose primary business is producing, marketing, selling, re-selling, or distributing health care products used by or on patients.

Play the mitigation matching game! To access, click here to open the instructions and game. Once complete, check your answers with the Answer Key (don’t peek!).

As a reminder, you must disclose the presence, as well as the absence, of relevant financial relationships to learners before they engage with the accredited education.

Helpful resources include the Standards for Integrity and Independence in Accredited CE and much more in the ACCME Standards Resources and Toolkit.

As always, reach out to CMA CME at cme@cmadocs.org with any questions you may have about the Standards for Integrity and Independence, core criteria or accreditation policies. We are here to help.


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