Compliance Corner: Standard 3.1 Ineligible Company - Definition

September 25, 2023
Area(s) of Interest: Continuing Medical Education (CME) 

One of the most common non-compliance findings is for Standard 3: Identify, Mitigate, and Disclose Relevant Financial Relationships, specifically in Standard 3.1, Collect Information. However, it can also be the easiest to avoid.

A common noncompliance is not having updated your collection mechanism to reflect the new standards, which became effective January 1, 2022.

To meet Standard 3.1, your collection mechanism needs to include the following items:

  • Request for ALL financial relationships. Note that the word “relevant” should be removed from the collection mechanism. It is your organization’s responsibility to determine what is relevant, and not the individual you are collecting information from.
  • Gather financial relationships from your individual in control of content for the past 24 months. (References to 12 months should be removed from the collection mechanism.)
  • Include the correct definition of an ineligible company. This definition must be verbatim. (Remove all references to Commercial Interest and confirm the definition below is being used.)
    • Ineligible companies are those whose primary business is producing, marketing, selling, re-selling, or distributing healthcare products used by or on patients.
  • Only collect financial relationship information from the individual in control of content, no longer their spouse/partner. (Remove any references to spouse/partner from your collection mechanism.)

Take a moment to review your current collection mechanism and confirm that it has all the components listed above. The California Medical Association strongly encourages you to use the Accreditation Council of Continuing Medical Education template, as it includes current accurate information and does not include additional details that may be noncompliant. This template is available in Word format so you can easily brand it to for own organization.

Reach out to cme@cmadocs.org with any questions.


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