*CME Providers may now use hyperlinks to link to disclosure information
*Also, starting May 1: All commercial logos must be removed from educational materials and disclosures in accordance with last year's decision
The Accreditation Council for Continuing Medical Education (ACCME) now allows for accredited CME providers to use tabs and hyperlinks to transmit disclosure information to learners at educational activities. ACCME notes that this revised policy does not affect the actual disclosure requirements under the Standards for Commercial Support, just the method for disclosure. Furthermore, one year after ACCME modified its logo policy, no educational material or disclosures should contain a commercial logo or slogan. Materials may still state the name, mission, and areas of clinical involvement of commercial interests.
Updated: 5/5/2015: We previously indicated that starting May 2015, there is "no longer an exception" to the new logo policy for materials that existed at the time of ACCME's April 2014 policy. ACCME has indicated that there was never a specific exception for these materials, only an extended timeframe for accredited providers to come into compliance with the new rules. CME providers were told that they did not need to discard their current materials and reprint them without a logo, but that they were expected to make the changes by May 2015 into all current and future CME materials. ACCME states: "After May 2015, the ACCME will begin to find providers in noncompliance if logos of ACCME-defined commercial interests are included with disclosure of commercial support."
ACCME requires all commercial support to be disclosed in a specific manner, in accordance with their Standards for Commercial Support (SCS):
ACCME SCS: Disclosure Relevant to Potential Commercial Bias
- Standard 6.1: An individual must disclose to learners any relevant financial relationship(s), to include the following information: The name of the individual; The name of the commercial interest(s); The nature of the relationship the person has with each commercial interest.
- Standard 6.2: For an individual with no relevant financial relationship(s) the learners must be informed that no relevant financial relationship(s) exist.
- Standard 6.3: The source of all support from commercial interests must be disclosed to learners. When commercial support is "in-kind‟ the nature of the support must be disclosed to learners.
- Standard 6.4: 'Disclosure' must never include the use of a corporate logo, trade name or a product-group message of an ACCME-defined commercial interest.
- Standard 6.5: A provider must disclose the above information to learners prior to the beginning of the educational activity.
"In a continuing effort to simplify compliance expectations and make them consistent across activity types, the ACCME has decided to allow accredited CME providers to use tabs, links, or other electronic mechanisms to transmit disclosure information to learners for CME activitiesm" states ACCME. Previously, CME providers were restricted from using methods such as electronic tabs or links and had to "use a method that ensured learners passed through electronic disclosure information before engaging in an activity."
"Now, CME providers can make electronic disclosure information available via an electronic tab or link, just as they have always been able to make disclosure available via a tabbed section in a printed syllabus."
"Regardless of the method, the ACCME expects—as it always has—that disclosure information will be delivered prior to the beginning of the CME activity and will be clearly marked, accessible, and useful for learners," ACCME advises.
As noted in Standard 6.4, last year, ACCME elected to disallow the use of company logos on educational materials and disclosure information. ACCME CEO and President, Dr. Murray Kopelow, discussed the modifications in a webinar, noting that a CME provider's "acknowledgment of commercial support as required by Standards 6.3 and 6.4 may state the name, mission, and areas of clinical involvement of an ACCME-defined commercial interest but may not include corporate logos and slogans."
He stated that this change is effective immediately but does not apply to currently printed existing materials. CME providers "do not need to throw them out and reprint them, but you do need to make all of these changes and incorporate this new policy by May 2015 into your printed materials and your Internet presentations of continuing medical education."
Kopelow also clarified:
I want to emphasize that this change only applies to mixing educational materials and logos and only applies to mixing disclosure of commercial support and logos; it applies to nothing else. It is not relevant to when a speaker mentions a brand name in your educational materials or if you're using a device to teach accredited continuing medical education and that device has a logo or brand on it. You don't have to remove that logo from the device.