As an organization accredited by the Accreditation Council for Continuing Medical Education (ACCME), the American College of Surgeons (ACS) has developed the following commercial support guidelines (commercial promotion guidelines are provided in a separate document). Please review the following guidelines, which ensure that educational activities are held without commercial influence and in full compliance with ACCME Standards for Integrity and Independence in Accredited Continuing Education.
Commercial support, previously referred to as "educational grants," is categorized as financial or in-kind (equipment, supplies, services, and so on) contributions provided by an ACCME-defined ineligible company
Ineligible company: Defined by the ACCME as "any entity producing, marketing, reselling, or distributing health care goods or services consumed by, or used on, patients (in other words, pharmaceutical or device company)
Commercial supporter: An ineligible company that provides financial or in-kind support for a Continuing Medical Education (CME) activity
The two types of commercial support are:
Financial support: A monetary donation used to pay for all or part of the costs of a CME activity
In-kind support: Non-monetary contributions provided by an ineligible company in support of a CME activity in one of the following categories:
Commercial supporters will not direct content nor influence the planning or implementation of educational activities
Commercial supporters are not permitted to be involved in the following:
For Directly-Sponsored activities, the ACS CME staff representative or Chapter representative is responsible for soliciting and applying for commercial support toward their educational activity.
For the Joint Providership Program (JPP), the partnering organization representative is responsible for soliciting and applying for commercial support toward their educational activity.
The CPDA team must review all mailings/materials used to solicit commercial support from ineligible companies prior to distribution in order to ensure compliance with ACS and ACCME requirements.
The Letter of Agreement template discussed in this section can be found after logging into the CME Platform, and initiating a new entry (click on the title of the educational activity under the "My Activities" tab, and click on the icon next to "Letter of Agreement" on the list to download the template).
If a company agrees to provide commercial support for a CME activity, a Letter of Agreement (LOA) is required. The ACS LOA template must be used, which includes the following components:
For Directly-Sponsored activities, the commercial supporter representative must sign off prior to the ACS representative's signature.
For Joint Providership Program activities, the commercial supporter representative must sign off prior to the partnering organization representative. The CPDA section representative will sign the LOA only after both signatures have been provided.
If a company cannot utilize the ACS' LOA template, the following components must be incorporated, and the LOA must be reviewed by the CPDA team for compliance with ACS and ACCME policies:
All LOAs must be signed by all parties and submitted to the CPDA at least five days before the educational activity.
Commercial supporters receive only an acknowledgement for their contribution toward a CME activity. Acknowledgements of any kind CANNOT include company logos, nor product-group messages.
Acknowledging commercial supporters must be done prior to content being disseminated, at the beginning of the CME activity. Examples may include, but are not limited to:
Sample text for acknowledgements for Directly-Sponsored activities: "The American College of Surgeons (Chapter Name, if Chapter) acknowledges (company name) for their commercial support of this educational activity."
If you receive in-kind commercial support (i.e. equipment loan, disposable materials, facilities/space rental, etc) for an educational activity, the acknowledgments must specifically indicate this type of support. Sample text for in-kind support: "The American College of Surgeons (Chapter Name, if Chapter) acknowledges (company name) for their in-kind support of this educational activity". In-kind support acknowledgments must be kept separate from the acknowledgement about general commercial support.
Sample text for acknowledgements for Joint Providership Program activities: "The (partnering organization name) acknowledges (company name) for their commercial support of this educational activity."
Sample text for in-kind support: "The (partnering organization name) acknowledges (company name) for in-kind support of this educational activity." In-kind support acknowledgments must be kept separate from the acknowledgement about general commercial support.
Acknowledgments of commercial support must be global and apply to the entire educational activity, rather than linked to specific sessions or portions of an activity. For example, the acknowledgement “The ACS would like to acknowledge (company name)’s support of the Paper Competition.” is not permitted.
Reconciliation of commercial support is required for all CME activities as part of the Final Report due to the ACS CPDA team following a CME activity. For monetary commercial support, the commercial company name, financial amount of support (dollar value), and details of how the funds were utilized toward the CME activity must be summarized for each commercial support contribution.
Honorarium is defined as "a payment, fee, or other compensation received as a gratuity, award, or honor."
Planning/editorial committee members, speakers, authors, moderators, or any individual in a position to affect or control the content of a CME activity are not permitted to receive payment directly from an ACCME-defined ineligible company for honoraria, travel, or out-of-pocket expenses. Individuals are required to attest to these terms as part of the disclosure process.
If a ineligible company is providing monetary support for a CME activity, these funds cannot be used to pay for learners' registration, travel, lodging, or out of pocket expenses related to their participation in a CME activity.
This policy applies only to honoraria that are funded by ACCME-defined ineligible companies (either through commercial support or commercial promotion). If honoraria are being provided by non- commercial entities, the individuals responsible for the CME activity must ensure adherence to the ACS division policy for ACS activities, and to the partnering organization's policy for JPP activities.