What Constitutes Commercial Support?
Companies that are ineligible to be accredited in the ACCME System (ineligible companies) are those whose primary business is producing, marketing, selling, re-selling, or distributing healthcare products used by or on patients. Commercial support is defined as financial or in-kind support from ineligible companies that are used to pay all or part of the costs of an educational activity. “In-kind” refers to the loan or donation of equipment and/or supplies from an ineligible company.
Commercial Funding for Specific CE Activities Is Permitted if the Activities Have Been Pre-Approved by the Strategic Advisory Committee (SAC)
This includes activities either on campus or at off-site venues and all functions that propose to use the Stanford name. Donations from companies which do not meet the definition of an eligible companies, individuals, foundations, and/or charitable organizations that are not ineligible companies may be used for support of a specific CE activity and do not need preapproval by the SAC.
Commercial Support Guidelines
Support from industry for CE may be accepted by Stanford CME or by an external educational partner approved by Stanford CME will only be accepted for activities in areas that have been designated by Stanford for curricular development. These areas will be identified and proposed to the Stanford CME on a regular basis. The Stanford CME conducts a two-level review and approval process to ascertain that the activities have been independently developed without influence from ineligible companies, focus on identified practice gaps, and are congruent with Stanford Medicine’s identified needs and mission. Commercial support can be accepted only in these pre-determined areas of curricular enhancement. Acceptance of commercial support must not influence curriculum in any way. Stanford and any Stanford CME identified educational partners must lead the identification of needs, determination of educational objectives, selection and presentation of content, selection of all persons and organizations that control the content, selection of educational methods, and evaluation. Commercial support may not be accepted for Regularly Scheduled Series (RSS).
Commercial Support Funding for Food and Beverages is Prohibited
All food and beverages served at CE activities must be paid for through tuition, funds supplied by a School of Medicine or hospital department, or other eligible companies.
Commercial Support Funds May Be Contributed to the Stanford Center for Continuing Medical Education
All commercial support for CE activities must be directed to the Stanford CME or to an approved educational partner with which Stanford CME is developing an activity. Commercial funds eligible for use in support of CE activities can be given either to the Stanford CME in support of a specific activity (except for RSS) or in support of the overall activity.
Applying for Commercial Support
On a regular basis, Course Directors can submit to the Stanford CME requests for permission to seek commercial support. These requests will be assessed by Stanford CME to verify the Request’s independence and fit within the missions of Stanford Medicine’s entities. If approved, the activity will be designated appropriate for curricular development and commercial support may be sought for it.
Stanford CME will submit the Request to a non-conflicted clinician reviewer. The review will check to ensure that no commercial bias exists. If commercial bias is present, the Request will be modified by the Course Director as needed to remove the bias.
If an ineligible company agrees to provide funding for an activity, both the ineligible company and Stanford are required to sign a Letter of Agreement (LOA) for Commercial Support that specifies the ineligible company providing the commercial support and terms and conditions of that support that comply with the ACCME Standards for Integrity and Independence in Accredited Continuing Education. This instrument must be approved and signed by a responsible company official (who is authorized to make such commitments) and by the Associate Dean for Postgraduate Medical Education or the Director of Stanford CME. Stanford has developed a standard form for this purpose.
Management of Commercially Derived Funds
All commercial support for CE certified by Stanford must be given with the full knowledge and approval of and be managed by either the Stanford Center for CME or its approved education partner.
Educational Partners
Stanford supports collaborative development of CE activities with other organizations. It will work closely with non-ACCME/JA accredited entities to develop and offer jointly provided activities (as defined by the ACCME/JA), on a case-by-case basis. In these cases, commercial exhibits and advertisements are prohibited, regardless of which institution certifies the activity.
Co-providership with organizations that are ACCME/JA accredited CE providers will also be considered. Proposals should be discussed with the Associate Dean for Postgraduate Medical Education and/or the Director of CME. Either institution may be the accrediting provider and control the process for commercial support as long as the CE activity is found to be free of commercial bias as determined by an independent (defined as an individual not associated with the activity) non-conflicted physician reviewer or the School of Medicine’s Conflict of Interest Review Program.
Potential collaborations must be based on a willingness to fully comply with Stanford policies.
Commercial Funds Contributed for Purposes Other Than CME May Not Be Used to Support CE
To ensure compliance with ACCME and Stanford Industry Interaction Policy requirements, commercial funds contributed for initial uses other than CE (such as unrestricted commercial donations to departments or other Stanford Medicine entities) may not be used to support Stanford CME activities.
No Additional Funds May Be Provided to Those in Positions to Influence Educational Content
Stanford School of Medicine policy prohibits commercial supporters from providing funds for CE other than through an agreement with the Stanford CME office. An ineligible company may not provide additional CE support funds to those in a position to control content of CE activities.
Disclosing Commercial Support to Learners
Stanford must disclose to the learners the name(s) of the ineligible company(ies) that gave the commercial support, and the nature of the support if it was in-kind, prior to the learners engaging in the education. Disclosure must not include the ineligible companies’ corporate or product logos, trade names, or product group messages.
“In-kind” Support – A Special Consideration
“In-kind” support refers to the loan and/or donation of equipment or supplies from an ineligible company. In-kind support may be donated for use in a specific activity upon prior approval by the Associate Dean of Postgraduate Medical Education or Executive Director of Stanford CME via an executed Letter of Agreement for in-kind commercial support. No marketing activity may be associated with the use of in-kind support. When multiple products are available, conscientious effort must be made to attract support from multiple vendors of similar and substitutive equipment and supplies. Stanford has developed a standard LOA for this purpose.
Utilization of Excess Commercial Funds
Funds contributed by companies in support of a Stanford CME activity will be expended on the designated CE activity. Once the contractual agreements from the company are met, if any funds remain available, these monies can be used amplify the reach of the designated Stanford CME activity i.e., the development of enduring materials from the recorded live session. Any excess funds will be returned to the funder.