American College Of Surgeons - Inspiring Quality: Highest Standards, Better Outcomes

Disclosure Information

Best Practices

Retrieve a signed ACS Disclosure Form from all standing committees, even if you are unsure whether you will hold a CME activity. In the event that you decide to offer CME Credit, having a Disclosure Form on file from all individuals who may contribute to CME content ensures full compliance with ACCME and ACS requirements.

Consider using an electronic tool (such as Survey Monkey, Google Forms, etc.) to collect and review disclosure information.

For educational activities that include presentation slides, remind speakers/presenters to include their disclosure information (or lack of) as a slide, prior to the start of the content. This may include phrasing such as "Disclosures: I have no disclosures/conflicts of interest" or "Disclosures: I received a research grant from (commercial company). This possible COI was reviewed and deemed irrelevant to the content of this presentation.

Frequently Asked Questions

Please note that all forms and templates described are available after logging into the CME Platform.

What does it mean to “disclose”?

Related to CME, all individuals who are involved in the development and presentation of content are required to disclose (or report) all financial relationships they (or their spouse/partner) hold with an ACCME-defined "ineligible company", within the last 24 months. An "ineligible company" is defined as "companies whose primary business is producing, marketing, selling, re-selling, or distributing healthcare products used by or on patients." Owners and employees of ineligible companies are not permitted to participate as planners or faculty of CME activities, as their financial relationships are considered unresolvable.

Why is disclosing important?

Collecting information related to financial relationships held by individuals involved in the development and presentation of CME content helps to ensure that it is unbiased, without undue influence from commercial companies. In addition to collecting the information, being aware of a financial relationship allows the opportunity to resolve the potential conflict of interest, to prevent possible bias in the educational activity. The ACS’ accrediting body, the Accreditation Council for Continuing Medical Education (ACCME), also requires this measure, for several reasons, explained further here and here. Learners must also be informed of the disclosure information from all individuals involved in the CME activity, in order to ensure transparency, report perceived bias, and form their own judgments related to the CME content.

Who should disclose?

Any individual involved in the development (i.e. planning committee members, editorial board) and/or presentation of content (i.e. speakers, moderators, chairs, authors, etc.) must disclose prior to their involvement in the educational activity.

How does one disclose?

The ACS utilities a Disclosure Form to standardize the collection of information related to financial relationships from individuals. The ACS Disclosure Form template can be found after logging in to the CME Platform (click either on the name of your educational activity, and scroll to the “Planning Disclosure” template, or enter the CME Activity Form, CME Application, or Pre-Activity Information requirements). The person responsible for the CME activity (the contact) must collect disclosure forms from all individuals prior to their involvement in the activity. Individuals must complete a Disclosure Form on at least an annual basis, with the opportunity to update their Form prior to each new CME activity. If any financial relationship with an ineligible company develops between the time the Disclosure Form is completed and the educational activity, the individual must notify the contact in writing and disclose the new or additional information.

When should one disclose?

Individuals must complete and return the Disclosure Form to the contact before contributing to the CME activity. This means that planners must disclose prior to the start of the planning process. Those in other roles must disclose prior to their presentation of the content (i.e. speakers must disclose prior to participating in the activity). The contact must then review all Disclosure Forms to ensure that all individuals appropriately disclosed their financial relationships (or lack of). Any noted financial relationships and subsequent conflict of interest must be resolved.

What happens if someone discloses a financial relationship? Are they disqualified from participating in the educational activity?

Individuals may still contribute to a CME activity as long as their financial relationship is resolved, to avoid a potential conflict of interest. Resolving a conflict of interest involves identifying a method to ensure that an individual’s disclosed financial relationship does not influence educational content. The method of resolution must be in line with the individual’s role in the educational activity. For example, a planning committee member would be required to recuse themselves from (not participate in) any discussion that may be relevant to their financial relationship, since the content of the educational activity is being developed. An author may include validation of evidence-based content. A moderator may be urged to offer no recommendations, and instead limit content to scientific or research data. These resolution strategies are designed to mitigate potential conflicts of interest and eliminate bias in the educational content of a CME activity. If a conflict of interest cannot be resolved, then another individual must be selected to present the content.

Who is responsible for resolving the potential conflict of interest?

A Designated Official (MD/DO) identified by the contact (such as the Program Chair, a moderator, etc.) must review the financial relationship with the individual and determine a resolution strategy based on what is deemed appropriate. This process must be documented on page two of the ACS Disclosure Form. Common methods of resolution are listed on the Form. Whenever possible, the moderator or Program Chair is responsible for monitoring the content during a CME activity, and intervening if an individual appears to be hold a bias.

How should learners be made aware of disclosure information for the CME Activity?

Upon approval of your educational activity, the ACS provides a standard template for the Disclosure List that must be displayed to learners prior to the educational activity. In addition to providing definitions related to disclosures, the Disclosure List template displays a comprehensive list of all individuals involved in the CME activity by role, in addition to all financial relationships (or a lack therefore). This list must be included in the program materials (program book, slide presentation, landing page of a website). In cases where the Disclosure List cannot be included in the program materials (due to a print deadline for a live meeting, for instance), the list must be provided as an insert to the program materials. The purpose is to provide full disclosure and transparency in the individuals who contributed to the CME activity. For educational activities that include presentation slides, speakers/presenters are required to include a slide displaying their disclosures (or lack of) prior to the start of the content.

How should disclosure information be submitted to the CPDA Section?

Disclosure Forms from those involved in the planning and development of a CME activity are due to CPDA with the CME Application (at least 90 days prior to the activity), via the CME Platform. Once all disclosure information for individuals presenting content has been collected and reviewed by the contact for the CME activity, the Disclosure Summary must be submitted to the Continuous Professional Development Accreditation (CPDA) Section via the CME Platform at least 5 days before the educational activity. Please note: the Disclosure Summary provides a template to summarize disclosure and resolution information, rather than requiring the submission of individual Disclosure Forms from those presenting content.

What happens if someone refuses or fails to complete the disclosure process?

Individuals who refuse or neglect to disclose must be disqualified from participating in the planning or presentation of the CME activity. An alternative individual should be identified to participate instead, who is required to disclose before involvement in the educational activity.

What is the difference between the various forms and templates related to disclosures?

The ACS Disclosure Form should be used to collect disclosure information from all individuals (regardless of role) involved in the planning and presentation of the CME activity. When all individuals have disclosed, the Disclosure Summary which summarizes the responses from all individuals involved in the CME activity must be submitted to the CPDA Section for review and approval. The Disclosure List provides a template for how all disclosure information must be displayed to learners. The Disclosure List must be featured in the program materials, prior to the start of CME content (or as an insert, due to print deadlines or space limitations of a program book for a live meeting). All forms and templates are available after logging into the CME Platform and must be submitted for review by CPDA at each corresponding step, through the Platform.

Please contact the CPDA Section by emailing CPDA@facs.org with questions.