NFID Policies for Managing Commercial Support and Conflicts of Interest
The policies of the National Foundation for Infectious Diseases (NFID) are based on the ACCME Standards for Commercial Support. These policies are designed to ensure independence in continuing education (CE) activities. All individuals in a position to control the content of NFID educational activities are provided a copy of relevant policies.
Standard 1: Independence
1.1 NFID maintains a strict separation of its CE program from all commercial interests. A commercial interest is defined as any entity producing, marketing, re-selling, or distributing healthcare goods or services consumed by, or used on, patients. NFID activity planners are solely responsible for needs assessment, educational objectives, content and its control, educational methods, and activity evaluation. Commercial support for NFID CE activities is in the form of unrestricted educational grants.
Employees of commercial interests will not be involved in the planning of educational activities and will have no control over the content. Employees of commercial interests will not be invited as speakers in plenary sessions or symposia offering CE. Employees of commercial interests may submit abstracts to be considered for presentation at NFID-sponsored sessions offering CE and must meet the specific circumstances identified by ACCME. For all submitted abstracts, activity planners will review and validate the research process as well as the results and conclusions. The selection of content for presentation will be based on its relevance and importance to activity attendees.
1.2 A commercial interest cannot take the role of non-accredited partner in a joint provider relationship.
Standard 2: Resolution of Personal Conflicts of Interest
2.1 All individuals in a position to control content are required to disclose any relevant financial relationships with ACCME-defined commercial interests, including CPE Committee members, activity planners, presenters, authors, content reviewers, NFID staff, and staff of collaborating partners and/or joint sponsors. Submitted disclosure forms are maintained on file for all NFID educational activities.
2.2 Anyone refusing to disclose relevant financial relationships is disqualified from any involvement in NFID CE activities.
2.3 NFID is committed to identifying and resolving all conflicts of interest prior to the educational activity being delivered to participants. As an added step (as part of the post-activity evaluation), participants and presenters are asked about whether disclosure procedures were followed and whether each presentation was evidence-based and free of commercial bias. In advance of the activity, conflicts of interest may be resolved by one of the following mechanisms:
2.3.1 Alter control over content–Individual and/or NFID staff can elect to alter the educational design, format, content, or individual responsibilities to maintain the scientific rigor, integrity, and balance of the CE activity. These options include:
- Select an alternative presenter/author for that portion of the content.
- Alter the focus of the activity to broaden the discussion and focus on issues rather than products or services.
- Alter the individual’s responsibilities in planning and implementation to areas not related to commercial interest’s products or services.
- Limit the content to a report on the “current state of the art” without recommendations.
- Limit the source of recommendations to evidence-based sources that provide systematic and clearly defined parameters.
2.3.2 Peer review of content–Independent review and validation of content to verify the scientific basis and integrity of the content. Recommendations will be based on evidence currently accepted within the profession of medicine as acceptable justification for indications and contraindications for the care of patients. Scientific research referenced, utilized, and/or included in CE activities will conform to generally accepted standards of experimental design, data collection, and analysis.
Standard 3: Appropriate Use of Commercial Support
3.1 NFID makes all decisions regarding the disposition and disbursement of commercial support.
3.2 NFID maintains written documentation of letters of agreement, specifying that all support is in the form of unrestricted educational grants. The supporter agrees not to be involved in any aspect of the planning or implementation of the activity.
3.3 All commercial support is provided with the full knowledge and approval of NFID. Commercial support is disclosed in promotional material and at the time of the educational activity.
3.4 Letters of agreement outline the terms, conditions, and purposes of the commercial support.
3.5 The name of the commercial supporter is clearly stated in each letter of agreement.
3.6 All letters of agreement are signed by both the commercial supporter and NFID.
3.7 Written policies and procedures for honoraria and reimbursement of out-of-pocket expenses for planners, presenters, and authors are maintained.
3.8 All honoraria and reimbursement of expenses are disbursed directly by NFID, or, as appropriate, the joint provider or designated education partner.
3.9 No other payments are made to anyone involved in the educational activity.
3.10 Presenters are not provided any additional funds outside of honoraria and/or reimbursable expenses, as outlined in NFID policies and procedures.
3.11 Social events or meals at CE activities may not compete with the educational activity.
3.12 Commercial support is used only for expenses and honoraria of presenters, authors, NFID staff, or volunteers. Funds are not provided to any other individuals participating in a CE activity.
3.13 Documentation of the receipt and expenditure of commercial support is maintained by NFID.
Standard 4: Appropriate Management of Associated Commercial Promotion
4.1 Commercial exhibits or advertisements do not influence the planning or interfere with the presentation of CE activities. Exhibit space is never exchanged for commercial support.
4.2 Promotional material or advertisement is never allowed during CE activities. NFID does not allow advertising in any printed CE materials. During live activities, advertisements and promotional materials are not displayed in the educational space. Exhibits are physically separated from the educational activity.
4.3 All educational materials (including slides, abstracts, and handouts) are reviewed in advance to ensure that they do not contain any advertising, corporate logos, trade names, or product-group messages of an ACCME-defined commercial interest.
4.4 NFID does not advertise or promote commercial products in any of its materials.
4.5 NFID maintains a strict separation of the CE program from any commercial supporters. Commercial interests are never used to distribute CE activities to participants.
Standard 5: Content and Format without Commercial Bias
5.1 The content of all CE activities promotes improvements or quality in healthcare and not a specific proprietary business interest of a commercial interest. Content validity is ensured in two ways:
5.1.1 Presenters/authors are required to provide a copy of their content to NFID in advance of the activity for the purpose of peer review. Presenters/authors are notified in writing of NFID requirements, and must attest that they will comply with the following requirements:
- Balance and scientific accuracy in the presentation, with content free of influence by industry or financial contributors.
- Provide evidence validating any clinical content (e.g., literature references) that is accepted within the profession of medicine as adequate justification and ensuring that all scientific research referred to, reported, or used in presentations regarding patient care recommendation conforms to the generally accepted standards of experimental design, data collection, and analysis.
5.1.2 NFID medical director, NFID staff, and activity planners work closely with all presenters/authors to ensure understanding and adherence to these requirements. An NFID representative attends each live educational activity in order to monitor compliance.
5.2 All presentations provide a balanced view of therapeutic options. Presenters/authors attest that they will comply with the following requirements:
- Clinical recommendations presented in this activity are based on evidence that is accepted within the profession of medicine that adequately justifies the indications and contraindications in the care of patients.
- All scientific research referred to, reported, or used in support of justification of a patient care recommendation will conform to the generally accepted standards of experimental design, data collection, and analysis.
- If discussing specific healthcare products or services, use generic names to the extent possible. If trade names need to be used, use trade names from several companies when available.
Standard 6: Disclosures Relevant to Potential Commercial Bias
6.1 For all NFID educational activities, all relevant financial relationship(s) of any individual involved in the planning or implementation of the activity are disclosed to participants prior to participation in the educational activity. These disclosures are published in written form in the activity materials or signage and, for presentations, are presented as a slide before the activity content. At conferences/courses, presenters are also asked to provide their disclosure information verbally before their presentation. Information provided includes the name of the individual, the name of the commercial interest, and the nature of the relationship.
6.2 For individuals with no relevant financial relationship(s), this information is provided to participants in advance of the activity in the activity materials, on presentation slides, and verbally at conferences/courses.
6.3 The source and nature of commercial support is provided to participants in activity materials or signage. Acknowledgement of commercial support does not include any corporate logos, trade names, or product-group messages of an ACCME-defined commercial interest.
6.4 Disclosures do not include the use of a corporate logo, trade name, or product-group message of an ACCME-defined commercial interest.
6.5 All of the disclosure information is provided to participants prior to the beginning of the activity.
Approved January 2019