Policy - Relationships with Commercial Supporters
GRMERC is ultimately responsible for the content, quality and scientific integrity of all CME activities that it sponsors, directly or jointly. Identification of educational needs, determination of learning objectives, selection of faculty, educational methods and materials, and evaluation of an educational activity is GRMERC's responsibility as an accredited sponsor according to ACCME guidelines.

The GRMERC President/CEO and the CME Committee (CMEC) are ultimately responsible for funding arrangements for all of its direct and joint sponsored educational activities. Financial and other support from commercial supporters will be accepted by GRMERC where such support can contribute significantly to the quality of an educational activity. Commercial support for an educational activity should be in the form of an educational grant payable to GRMERC with the terms, conditions and purpose of such grant documented in a signed agreement between GRMERC and the commercial supporter. Payment of faculty honoraria and expenses will be the responsibility of GRMERC in accordance with its policies. Upon request, GRMERC will prepare an accounting of the income and expenses for each CME activity involving commercial support and will furnish a copy of the report to the commercial supporter and other relevant parties. Likewise, commercial supporters should report to the accredited provider information concerning their expenditures in support of an educational activity.

All information to be disseminated to the medical community about the CME activity must be authorized by GRMERC. Commercial support of an educational activity will be acknowledged in printed announcements and brochures. These printed materials will not reference specific products or services.

Presentations must give an objective and balanced perspective, and must be free of commercial bias for or against any product. Commercially supported social events and/or exhibits at an educational activity must not compete with, or take precedence over, the educational activity. Social events must be modest in nature and must have the advance approval of the CMEC. Exhibit placement will not be considered a condition of support, nor will exhibits be displayed in the same room immediately before, during, or immediately after the educational activity. Representatives of commercial supporters may attend an educational activity, but may not engage in sales activities while in the room where an educational activity occurs.

The accredited provider may not use funds originating from a commercial supported to pay travel, lodging, registration fees, honoraria, or personal expenses for non-faculty attendees. Subsidies for hospitality should not be provided outside of modest meals or social event that re held as part of an educational activity. Scholarships or other funding to permit medical students, residents, or fellows to attend selected educational activities may be provided, as long as the selection of students, residents or fellows who will receive the funds are made either by the academic or training institution, or by the accredited provider with the full concurrence of the academic or training institution.

Policy - Speaker Disclosure/Conflict of Interest
Potential or actual conflict of interest may be considered to exist when an individual having responsibilities related to a GRMERC CME activity is affiliated with or has a financial relationship with a commercial company or competitive commercial company that has a direct interest in the subject matter being presented.

Conflicting relationships with a commercial company would include, but not be limited to, receiving research funds from that company, serving as a paid consultant to that company, being paid by the company to make the presentation, or hold stock in the company. Full disclosure of the conflicting relationship must be made by the individual to GRMERC as a sponsoring organization for the CME activity.

Disclosure Relevent To Potential Commercial Bias
ACCME allows for information about faculty/provider relationships being disclosed to participants verbally or in writing (slide, handout, etc.) before the presentation begins.

The source of all commercial support from commercial interests must be disclosed to learners, including "in-kind" support. Disclosure should not include the use of a trade name or a product-group message. Disclosure should include the following:

• Faculty member's name;
• Name of the commercial supporter or entity with whom the member has the relationship or affiliation; and
• Type(s) of relationships.
• In the event an individual has no relevant financial relationship(s), the learner must be informed that no relevant financial relationship(s) exist.

Timing of Disclosure
Verbal disclosure of the above information must be made prior to the beginning of the educational activity.

Documentation of Disclosure
The physician responsible for the activity who was in attendance at the time of the verbal disclosure must attest in writing to the following:

• Verbal disclosure did occur; and
• Itemization of the disclosed information; or
• No relevant financial relationship(s) existed to disclose; or
• Faculty member refused to disclose.

GRMERC has revised the Activity Attendance Form for you to easily document this information.

Policy - Conflict of Interest
SC element 2.3- Provider must have implemented a mechanism to identify and resolve all conflicts of interest prior to the education activity.

Who does what? Is the person a lecturer, speaker, consultant, board member, etc, with a financial relationship with a commercial interest and has the opportunity to affect the content of CME about the products or services of that commercial interest.

Content validation: Does the material relate to the commercial interest? Are the handouts or slides prepared by or do they acknowledge a commercial interest?

It the policy of GRMERC to identify and manage conflicts of interest prior to the possibility that anyone in a position of control the content of the educational activity does so. An attempt will be made to review all slides, handouts and educational material prior to the presentation. Information disclosed will be analyzed. If potential conflict of interest is identified the speaker and or director will be asked to eliminate the conflict of interest. If compliance is demonstrated, the speaker will not be allowed to present in the immediate future.

Policy - Speaker Honoraria and Expense Reimbursement
Honoraria and expenses related to a Grand Rapids Medical Education & Research Center (GRMERC) Continuing Medical Education (CME) activity should be reasonable and customary as concluded by a member or members of the GRMERC CME Committee. Extenuating circumstances will be taken under advisement. Program Coordinators and Activity Planners will be notified of unusual or abnormal fees/expenses prior to, or after such programs.