COMMERCIAL SUPPORT
For your convenience, AXIS compiled a list of common questions regarding continuing education, joint providership, etc; answers are provided below. Click on the topic above that seems most related to your question and search for your particular question in that section of this page.
- What is the definition of an ineligible company?
- What is commercial support and/or sponsorship?
- If an ineligible company provides an unrestricted educational grant for our activity, does that organization get recognized as a joint provider?
- What is a conflict of interest?
- Does AXIS require a signed financial disclosure form as the means to document financial relationships with ineligible companies and demonstrate compliance with the Standards for Integrity and Independence in Accredited Continuing Education?
- Is it acceptable for a teacher/faculty/presenter of a certified educational activity to use slides, images, or videos created by an ineligible company?
- We were talking with a company that makes a medical device and they said that if we developed continuing education training for their staff, they would give us a grant to work on this. Is this compliant?
- Are exhibits at a conference considered commercial support?
- Is paying for food and/or beverages considered to be commercial support?
A commercial interest is any entity producing, marketing, re-selling, or distributing healthcare goods or services consumed by, or used on, patients. An ineligible company is defined by the ACCME, ACPE, and ANCC as any entity whose primary business is producing, marketing, selling, re-selling, or distributing healthcare products used by or on patients. For specific examples of ineligible companies visit accme.org/standards..
Ineligible companies are prohibited from engaging in joint providership with accredited providers.
Commercial support is defined as a financial or in-kind contribution given by an ineligible company.
Sponsorship is defined as a financial or in-kind contribution given by an organization that is not an ineligible company.
Organizations that provide commercial support or sponsorship may not be a provider or joint provider of any certified educational activity and may not participate in planning, implementation, or evaluation of any certified educational activity.
The receipt of commercial support or sponsorship for a certified activity must be documented on a commercial support or sponsorship agreement, known as a letter of agreement. Learners who are interested in participating in a certified educational activity must be informed of any and all commercial support or sponsorship received for the development of that activity prior to the start of the activity.
No. An organization that provides unrestricted educational grant funding to plan, implement, and evaluate a certified educational activity is not considered a joint provider. In fact, by definition an ineligible company cannot be a joint provider for an activity.
A conflict of interest is defined as a financial affiliation or relationship with an ineligible company that could bias a person's ability to objectively participate in the planning, implementation, or evaluation of a certified educational activity.
The potential for bias exists when an individual is able to control or influence the content of an educational activity and has a conflict of interest with an ineligible company.
Yes. A financial disclosure form is used to document information regarding the relevant financial relationships of all people in control of the content of an educational activity. These persons include all planning committee members, teachers/faculty/presenters/speakers, and authors of a certified educational activity.
The AXIS financial disclosure form instructs the person in a position to control the content of a certified educational activity to document financial relationships:
- in any amount
- that exist within the 24 months prior to the educational activity
- that are with a defined ineligible company
- that relate to the content of the educational activity.
The accreditation bodies require accredited providers to obtain information about the financial relationships of all people in the position to control content. Obtaining this information and evaluating it are key components to ensuring independence in the planning, implementation, and evaluation of certified educational activities.
All planning committee members, teachers/faculty/presenters/speakers, and authors of a certified educational activity must disclose all financial relations with any commercial interest.
A financial disclosure form must be completed and signed, even if a person has no financial relationships with any commercial interests to report.
No. All aspects of the presentation must be developed and controlled by the accredited provider (eg, AXIS) and the joint provider. Therefore using slides, images, or videos from an ineligible company is not allowed.
No. Continuing education activities must be planned, implemented, and evaluated independently from all ineligible companies. This includes the suggestions of topics and faculty members, as well as the tying of financial support to the production of certain activities.
No. Exhibits at a conference are considered “trade shows” and not part of an educational activity that takes place at the related conference. Vendors who exhibit at the trade show are paying for the booth space/tables, etc, to promote their products or services and have nothing to do with the planning, implementation, or evaluation of the certified educational activities that take place at the same conference.
Many conference organizers have specific forms and accounting systems for the funds allocated for exhibit space. Monies received from vendors for exhibit space can be used by the conference organization as they see fit and are not required to be reported in post-activity documentation or annual reports. Vendors who exihibit at a conference are not required to sign a joint providership agreement related to the certified educational activities that take place at the same conference because they are not joint providers of those activities; in fact, they play no role in the planning, implementation, and evaluation of those activities.
Conference organizers must ensure that exhibits/vendors are physically located in another room separate from where the educational activity is presented.
If the food and/or beverages are paid for by an ineligible company, then the funds used for that purpose are considered commercial support.