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									                                            ENTITY                                       NUMBER
                                            University of Manitoba
                                            Faculty of Medicine
                                            Office of Continuing Medical Education
                                            MANUAL                                       EFFECTIVE DATE
                                            Policy and Procedure                         April 1,2006

                                            SUBJECT                                      REVISED
                                            Commercial Support Policy                    May 17, 2008
                                                                                         Jan 5, 2010 (reformat)

PURPOSE

It is the policy of the University of Manitoba’s Faculty of Medicine that clinical decision-making, education,
and research activities be free from influence or perceived influence created by improper relationships with, or
gifts provided by, Industry. Because provision of financial support can exert a subtle but measurable impact on
recipients’ behavior, the University of Manitoba’s Faculty of Medicine has adopted a policy to govern the
interactions with Industry (Interactions between the University of Manitoba’s Faculty of Medicine and
the Pharmaceutical, Biotech, Medical Device, and Hospital and Research Equipment and Supplies
Industries).

University CME/CPD providers often receive financial and other support from commercial sponsors. Such
support can contribute significantly to the quality of CME/CPD activities but must avoid potential bias or the
perception of it. The purpose of this document is to describe the guiding principles that the Office of
Continuing Medical Education will meet in planning, designing, implementing, and evaluating CME/CPD
activities for which commercial support was received.

POLICY

1.0 Selection of subjects/clinical areas.

To ensure clinical and scientific integrity, the planning committee cannot receive guidance, either nuanced or
direct, on the content of the activity or on who should deliver that content from commercial interests. The
identification of needs, determination of educational objectives, selection and presentation of content,
educational methods and evaluation is solely the responsibility of the course director/planning committee and
the Office of Continuing Medical Education.

If a commercial sponsor recommends a resource person or speaker, he or she must be acceptable to the course
coordinator and his/her planning committee. The invitation to participate must emanate from the course
coordinator and not from the commercial sponsor. All members of planning committees must abide by the
principles set out in this document and participate without introducing commercial bias.

All Office Continuing Medical Education activities must be based on an unbiased needs assessment of the
educational needs of physicians and the needs of the patient population. Needs assessment is not necessarily
synonymous with asking physicians what they wish to learn about. Needs may be perceived or unperceived.
Unperceived needs may be determined by consultation with public health, regulatory or regional health
authorities. Needs assessments should not be conducted in such a manner that the outcome is pre-determined
or biased towards a particular topic.
2.0 Content and format without commercial bias

Topics may not be product or promotion oriented and presentations must give a balanced view of all relevant
therapeutic options available. For example, generic names should be used where possible. When trade names
are employed, it is preferable to use the trade names of several companies rather than that of a single
commercial sponsor. Any unapproved therapy mentioned in a CME/CPD activity should be explicitly
identified as such in the presentation.

An effort should be made to present competing views regarding various therapeutic options. Cases presented
must not be constructed in such a way that the sponsor’s product is the best choice in all instances.

2.1 Assistance from commercial sponsors

a) Assistance with preparation of educational materials
The content of slides and reference materials must remain the ultimate responsibility of the faculty selected to
provide the CME/CPD activity. A commercial sponsor may be asked to help with the preparation of
conference related educational materials, but these materials must not, by either content or format, advance the
specific proprietary interests of the commercial sponsor. The distribution of promotional materials with the
course registration package or during educational sessions will not be permitted unless they are judged
unbiased by the Office of Continuing Medical Education or the course coordinator and his/her planning
committee and clearly include only those things related to instruction.

b) Assistance with educational planning
The acceptance by the course coordinator and his/her planning committee of advice or services from the
commercial sponsor concerning speakers, invitees or other educational matters including content, must not be
among the conditions of providing support by a commercial sponsor. The final decision on the involvement of
any participant must be made independently by the course coordinator and his/her committee.

Commercial sponsors must not be on the planning committee of an event where the Office of Continuing
Medical Education is the primary sponsor. CME/CPD sessions developed by commercial sponsors will not be
offered as CME sessions at the University of Manitoba. While many of these talks offer high quality
CME/CPD, it is not appropriate for a commercially developed talk to be presented as a university-sponsored
CME/CPD session.


2.2 Disclosures Relevant to Potential Commercial Bias. [See Conflict of interest policy for program
planners, speakers and authors of continuing medical education (CME) activities]

Course directors or their designates are responsible for conveying to the participants any potential conflicts
declared by the speakers or planning committee members and any funding received in support of them.
Speakers and planning committee members must fully disclose and address any competing interests with
respect to information being presented at a CME/CPD event in accordance with the Office of Continuing
Medical Education’s Conflict of interest policy for program planners, speakers and authors of continuing
medical education (CME) activities.

2.3 Evaluation of bias [See Conflict of interest policy for program planners, speakers and authors of
continuing medical education (CME) activities]

The evaluation of a CME/CPD activity must allow participants to indicate if any commercial bias was
perceived. Following any CME/CPD activity, an evaluation form to assess speakers and the overall program
must include a question concerning the possibility of commercial bias such as; “Did you perceive commercial
bias in any aspect of the program?”

2.4 Commercial Exhibits [See Policy on Commercial Exhibits]

When commercial exhibits are part of the overall CME/CPD activity, arrangements for these exhibits must not
influence planning or interfere with the presentation of CME/CPD activities. Exhibit placement should not be
a condition of support for a CME activity.

No commercial promotional materials shall be displayed or distributed in the same room immediately before,
during, or after a CME/CPD activity.

A separate contract will be used for exhibit arrangements. That contract will contain the terms, conditions,
and prohibitions regarding exhibits associated with the education activity.

The Office of Continuing Medical Education charges an additional exhibit fee for grant supporters who wish
to exhibit. The fee for exhibiting cannot be included in the educational grant check and must be a separate
transaction.

2.5 Participation by Industry Representatives at Supported CME/CPD Activities

Representatives from commercial supporters may attend an educational activity as an observer only, and may
not speak during question and answer periods or engage in sales activities in the room where the activity takes
place. Office of Continuing Medical Education reserves the right to limit the number of representatives
attending an activity.



3.0 Appropriate Use of Commercial Support.

3.1 Expenditures and Expenses for Individuals Providing CME/CPD [See CME Honoraria Policy]

Faculty and visiting speaker payments must be consistent with that which would be made in the absence of
commercial sponsorship.

Honoraria for faculty or authors are paid directly by the University of Manitoba or an educational partner
when specifically designated in the commercial support letter of agreement. Honoraria amounts are calculated
in accordance with the Office of Continuing Medical Education CME Honoraria Policy.

In addition, commercial supporters of an activity will not enter into any other compensation arrangement with
instructors, planners or managers relative to that CME/CPD activity.

Faculty or planning committee members may only accept reimbursement for travel, lodging, and meal
expenses directly by the University of Manitoba or an educational partner when specifically designated in the
commercial support letter of agreement.

3.1 Expenditures for Learners

Commercial support funds may not in any way be used to defray any part of the cost of attending a CME
activity including but not limited to travel or lodging costs or other personal expenses of physicians, their
spouses, or family members attending an activity sponsored by the University of Manitoba Office of
Continuing Medical Education.

Scholarships or Special Funds may be accepted to permit medical students, residents or fellows in accredited
programs to attend CME/CPD activities as long as these funds are approved by their program director or
designate.

3.2 Registration Fees

A registration fee must be charged for all CME/CPD activities that would normally have a registration fee
associated with them.

A commercial sponsor must not cover the entire cost of a CME/CPD activity. Commercial support may help
reduce the cost of registration but a registration fee should be paid by the participants in order to avoid a
perceived or real influence on learning. Payments to defray the costs of a conference should not be accepted
directly from any company by physicians attending the activity.

Exceptions to this general principle might include rounds, established professional meetings, faculty
development activities and research oriented continuing education activities since these activities would
normally be carried out without charge to participants. Any exceptions to these principles are at the sole
discretion of the Associate Dean CME or designate.

3.3 Knowledge of Funds

All commercial support associated with a CME/CPD activity must be given with the full knowledge and
approval of the Office of Continuing Medical Education. No additional funds or in-kind support will be
provided to the planning committee members, teachers, or authors beyond those defined in the budget.

3.4 Use of Funds

The Office of Continuing Medical Education makes all decisions regarding the acceptance and disposition of
commercial support funds in-kind support received for CME/CPD activities.

No prerequisite conditions, except for the designation of topic areas under which the educational grant is
given, will be allowed with regard to the receipt of commercial support funds.

All commercial support expenditures are documented in the form of a written letter of agreement between the
Office of Continuing Medical Education and the commercial supporter. The terms, conditions, amount of
grant, name of the supporter and the University of Manitoba’s Office of Continuing Medical Education must
be included in the written agreement.

The Office of Continuing Medical Education will not retroactively accept a grant from a commercial interest.

3.5 Social Events

Since all funds from commercial interests must be in the form of unrestricted educational grants; subsidies
specifically designated for hospitality will not be accepted. Commercially supported social events (including
meals) at CME/CPD activities must not compete with nor take precedence over educational events. The
approved educational activity must clearly have greater importance and time duration than any associated
social activities. In general, travel and accommodation arrangements, social events, and venues for CME/CPD
events receiving commercial sponsorship should be in keeping with arrangements that would normally be
made without commercial sponsorship.


5.0 Acknowledgment of Commercial Support. [See CME Brochure Policy]

Acknowledgment will be made of any outside organization providing commercial support, including in-kind
grants for an educational activity. Acknowledgements should simply mention the name(s) of the commercial
sponsor(s) and must not mention or suggest any endorsement of the commercial sponsor or its product(s).
Advertising commercial products by name or indication is not permitted. Commercial sponsors may not be
listed in the schedule of activities or close to the list of faculty members. In addition, the following guidelines
apply:

a) Course brochures: Unrestricted educational grants and commercial sponsors may be acknowledged in
course brochures. Commercial sponsors must not be listed on the front of brochures.

b) Posters, flyers, and one-page brochures: Commercial sponsors may be acknowledged at the bottom of the
document in an unobtrusive manner.

c) Websites and other electronic formats: in a one-page or one-screen format, commercial sponsors may be
acknowledged at the bottom of the page or screen in an unobtrusive manner. In a multi-page or multi-screen
format, commercial sponsors must not be acknowledged on the main (home) page. Links to commercial
sponsors may not be established.

d) In printed CME/CPD handouts or syllabi, advertisements, and promotional materials may not be interleafed
within the pages of the CME/CPD content. They may be inserted at the end of the syllabus, not facing any
content, and clearly marked as advertising/promotion.


6.0 Satellite symposia

“Satellite” symposia are separate meetings often associated with conferences and other CME/CPD activities.
These symposia are frequently produced by commercial interests and are not in compliance with these
commercial support guidelines. Registrants may perceive such “satellite” programs as integral to the approved
event and be unaware of commercial bias. Thus, conference organizers must take care to ensure that:

a) registrants at the approved program are aware that such satellite symposia are not approved by the Office
   of Continuing Medical Education;

b) such activities are promoted (marketed or “branded”) in a way which clearly identifies the satellite activity
   as distinct from the approved event; and

c) the satellite symposia are separated temporally and if possible, spatially from the approved event.




APPROVALS:
CME Advisory Committee: May 17, 2008

								
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