Introduction
Commercial promotion is defined as marketing efforts by Accreditation Council for Continuing Medical Education (ACCME)-defined ineligible companies that promote products or services of commercial companies.
Examples of commercial promotion include commercial exhibits, advertisements, and satellite symposia (educational sessions that are held by an ineligible company that are promotional in nature). These are promotional activities and not continuing medical education.
If an educational activity includes commercial promotion as an adjunct to its educational program, learners must be able to participate in the education without interacting with the promotion. Details on how to manage the separation of Continuing Medical Education (CME) from commercial promotion are provided below. Additionally, arrangements for commercial exhibits or advertisements cannot influence planning or interfere with the presentation, nor can they be a condition of the provision of commercial support for CME activities (Standard 2).
Funds (such as exhibit fees) paid by ineligible companies to providers for these promotional activities are not considered to be commercial support. Therefore, exhibitors are not required to complete a letter of agreement.
If an ineligible company is providing commercial promotion in exchange for names or contact information of learners, individual learners must provide explicit consent before the sharing of their contact information with the company. Examples of this include providing ineligible companies with mailing lists of learners, hotel room door drops, etc. (Standard 2)
Commercial Promotion Guidelines
For Live CME Activities, including Live Virtual Formats and Face-to-Face Meetings (Standards 2 and 5)
- Educational materials that are part of a CME activity, such as slides, abstracts, and handouts, cannot contain any advertising, corporate logos, trade name, or a product- group message. This includes program materials that contain content related to the accredited educational activity, including the disclosure list, abstracts, and so on.
- However, program materials related to the non-CME elements of a CME activity (such as schedules, basic content descriptions) can include advertisements of an ineligible company. If advertisements are featured in program materials, the disclosure list is not permitted to be included and must be provided as an insert to the program instead.
- Product-promotion material or product-specific advertisement of any type is prohibited in or during CME activities
- Marketing, exhibits, and satellite symposia held by an ineligible company cannot occur in the educational space within 30 minutes before or after CME content.
- Commercial companies are prohibited from displaying and sharing information about their services and products in areas where the accredited learning activity occurs.
- All promotion or discussion of products and services must be done in the designated exhibit space. Exhibit placement/location must not interfere with the CME activities and must be physically separated from the places in which accredited educational content are held (for example, for face-to-face live meetings, separated by a wall, in a different room, or on a separate floor of the meeting venue, for virtual formats, on a different tab of the virtual meeting's website, away from CME content).
- Representatives of ineligible companies are not allowed to engage in sales or promotional activities while in the accredited educational program space.
- Representatives of ineligible companies must remove their company name badges while in the educational activity space.
- Branding and commercial marketing (including company names and corporate logos) are not allowed on items such as registration bags, pens, or lanyards.
- Social events that are funded by commercial promotion cannot compete with (in other words, occur at the same time) nor take precedence over CME content. Signs, table tents, podium signs, and centerpieces regarding commercially promoted social events are prohibited from being placed inside the education space.
- Any mention of exhibits (i.e. information about their location, hours, or scheduled exhibit breaks) cannot be listed the same space or time as educational content, and must be designated with a note stating, “Please note: Non-CME promotional events.”
- Moderators and program chairs are responsible for monitoring on-site activity, intervening as necessary in any possible violations, in order to ensure that the commercial promotion requirements are appropriately followed.
Satellite Symposia (at Live Activities) (Standards 2 and 5)
A satellite symposium is a scientific program (course, session, workshop, and so on) planned, executed, and sponsored by an ineligible company within (but separate from) a CME activity.
Satellite Symposia Guidelines
- The American College of Surgeons (ACS) does not provide CME Credit for satellite symposia.
- There must be a 30-minute separation before or after any CME content and the commencement of a satellite symposium, if conducted within the educational area. This 30-minute requirement does not apply if the satellite symposium takes place outside the educational space.
- The symposium cannot be scheduled concurrent to (held at the same time as) CME programming.
- Neither the College's name nor seal/logo may appear in the symposium materials.
- All promotional materials must be reviewed by CPDA prior to print.
- If listed in the program materials (or as part of the schedule) of the CME activity, mentions of the satellite symposium are limited to:
- "Industry Satellite Symposia—No CME Credit Provided." No other promotional text is permitted related to the company holding the symposium nor the symposium itself.
For Print CME Activities (Standards 2 and 5)
- Advertisements and commercial promotional materials are not permitted to be interleaved within the pages of the CME content.
- Advertisements and promotional materials may face the first or last pages of printed CME content as long as the promotional materials are not related to the CME content they face. Additionally, the CME content that the promotional materials face cannot be paid for by the commercial interest (either by commercial support or commercial promotion funds).
For Online CME Activities (Standards 2 and 5)
- Advertisements and promotional materials cannot be visible on the screen at the same time as the CME content.
- Promotional materials are not permitted between web pages of the CME content.
- Advertising of any type is prohibited within the educational content of CME activities, including, but not limited to, banner ads, subliminal ads, and pop-up window ads.
- CME activities cannot be placed on a website owned or controlled by an ineligible company.
- Links to an ineligible company's website are permitted only before or after the educational content of a CME activity, but cannot be embedded within the educational content. The learner must be made aware through clear language that they are leaving the educational web site if linking out to an ineligible company's website. Example: "Please note that by clicking on the link below, you will be leaving the CME activity and entering a commercial company's website."
- None of the elements of Internet-enduring CME (accreditation and credit information, learning objectives, disclosure list, scientific content, date of posting, and so on) can contain any advertising from ineligible companies.
- No "commercial breaks" are permitted in which advertising is included.
For Journal-Based CME (Standards 2 and 5)
- None of the elements of journal-based CME (accreditation and credit information, learning objectives, disclosure list, scientific content) can contain any advertising from ineligible companies.
- The learner must not encounter advertising within the pages of the article nor within the pages of the related questions or evaluation materials.
