AMERICAN COLLEGE OF GASTROENTEROLOGY
POLICIES AND PROCEDURES
IDENTIFYING AND RESOLVING CONFLICTS OF INTEREST

It is the policy of the American College of Gastroenterology to ensure objectivity, balance, independence, transparency, and scientific rigor in all its sponsored educational activities.  The Accreditation Council for Continuing Medical Education (ACCME) requires CME providers to demonstrate that everyone who is in a position to control the content of an education activity has disclosed all relevant financial relationships with any commercial interest to the provider. 

The ACCME requires that providers establish mechanisms to identify and resolve conflicts of interest (COI) assuring there is no conflict of interest in the activity and to verify that the activity is in the best interest of the public.  Providers must be engaged in a system that goes beyond simple disclosure, with necessary interventions to resolve any real or perceived conflicts of interest implemented before the activity.

Conflict of Interest is defined by ACCME as occurring when an individual has an opportunity to affect CME content about products or services of a commercial interest with which he/she has a financial relationship.

Procedures for Identifying Conflicts of Interest:

1. All planners, speakers and authors in a position to control the content of a CME activity must complete a disclosure declaration in advance of the deadline.  Individuals who refuse to disclose are disqualified from any role in planning, management, presentation, or evaluation.
   
   
2. Primary responsibility for identifying, addressing and attempting to resolve any COI rests with the Course Director(s), however the Chair of the Educational Affairs Committee reserves the right to appoint members of the Educational Affairs Committee or members of the College with specific topic expertise to assist with the review process as the need arises.
   
   
3. Conflicts of interest are identified through an analysis of the information disclosed and an understanding of the planned content of the CME.
   
   
4. Any disclosure forms of concern identified will additionally be reviewed by the Chair of the Educational Affairs Committee for determination of appropriate action.
   
   
5. The Course Director or other appointed reviewer will provide certification as to having reviewed all conflict of interest disclosures and determining a mechanism for their resolution.
   
   
6. Instances where the Course Director(s) have a conflict of their own, the disclosure will be reviewed by the Chair of the Educational Affairs Committee.
   
   
7. ACG shall convey any information disclosed by the faculty member to the CME program audience by: (1) including a description in the printed program; (2) by display of the information on a slide shown in the meeting room at the time of presentation; and (3) by the statement being read aloud by the moderator preceding the faculty member/participant’s presentation.
   
   

Procedures for Resolving Conflicts of Interest:

• Attestation (Presenters will be asked to agree in writing that their disclosed relationships will not bias or influence their involvement and that their presentations will be evidence-based.)
  
  
• Content Validation through peer review of handout materials and/or slides (The presentation can not favor the commercial interest, and must include alternatives to drugs/devices manufactured by the commercial interest where possible.)
  
  
• Evaluation (Attendees will be asked to review the activity for the absence of bias, and this information will be made known to the planners.  Additionally, the Educational Affairs Committee may assign evaluators to monitor presentations.)
  
  
• Disqualification (Planners, teachers or authors whose conflicts are irresolvable or who are perceived to be biased may be eliminated from the program or prohibited from participating in future ACG-sponsored activities.)
  
  

Suggested mechanisms for resolving COI:

• Limit content to a report without recommendations (i.e., limit it to data and results of research, and assign someone else to address broader implications and recommendations);
• Limit to independent sources for recommendations (citing all independent references);
• Change the focus of the CME content;
• Select someone else to control that part of the content;
• Revise the content of the person’s assignment;
• Limit personal opinions to question and answer sessions;
• Altering the financial relationship (A presenter may change his or her relationships with commercial interests, however, when individuals divest themselves of a relationship, it is immediately not relevant to conflicts of interest but must still be disclosed to the learner for 12 months.)

ACG Board of Trustees Disclosure Declaration
Oversight of all educational programming content is conducted by the ACG Board of Trustees through a review and approval process.     View the ACG Board of Trustees disclosure information by clicking on the links below.

2006-2007 ACG Board of Trustees
2007-2008 ACG Board of Trustees
2008-2009 ACG Board of Trustees
2009-2010 ACG Board of Trustees

ACG Staff
ACG staff are required to disclose conflicts of interest.  This information is made available to the ACG Executive Director for the determination of whether any identified conflicts of interest require an individual’s recusal or excusal from certain ACG roles or decision making, or other consideration to ensure staff acts in the best interest of the ACG.