Financial Statement of Industry Humana Company - Excel

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					                                                    ACCF Mechanisms for Resolving Conflicts of Interest

The Accreditation Council for Continuing Medical Education (ACCME) requires all accredited providers of CME to have a mech
and resolving potential conflicts of interest (COI) prior to the educational offering. The ACCME considers financial relationships
interest “when individuals have both a financial relationship with a commercial interest and the opportunity to affect the content
services of that commercial interest.” A commercial interest is defined as any entity producing, marketing, re-selling, or distribu
services consumed by, or used on, patients.

The American Nurses Credentialing Center (ANCC) also requires providers of CE to have a mechanism in place for identifying
conflicts of interest (COI) prior to the educational offering. The ANCC considers a “conflict of interest” to exist when an individu
CE content in relation to a commercial interest with which he/she has a financial relationship.

The American College of Cardiology Foundation (ACCF) has approved the following as a list of potential resolution mechanism
Resolution mechanisms will vary depending on the nature of the financial relationship; ACCF staff will notify contributors of the
activity:

Please Note:
• Mechanisms #1-3 will automatically apply to participation in all ACCF credit bearing activities;
• Mechanisms # 10-12 will automatically apply to participation in committee activities involving continuing education
• College staff will advise contributors if any additional strategies are recommended


                                                      ACCF’S LIST OF OPTIONS FOR RESOLVING COI

1.Signed Attestation: By completing and signing the Attestation Section of the Disclosure Form, the contributor agrees that sa
will not bias or otherwise influence their involvement in the CME/CE activity, practice recommendations will be limited to those b
evidence (or absence of evidence), and recommendations will be consistent with generally accepted medical practice. They a
mandatory ACCME disclosure guidelines.


2. Audience Evaluation: Attendees will be advised of their right to expect non-biased presentations, and queried regarding th
bias (or the absence of bias) within the activity. Activity Directors and teachers/authors will receive copies of the evaluation sum

3. Speaker Disclosure Slide: Presenters will be required to show a disclosure slide to the audience at the beginning of their p
acc.org for a speaker slide template)

4. Follow-up Phone Call: CME/CE Committee identifies someone to follow-up with contributor by phone to discuss ways to a
disclosed relationships. CME/CE staff sends follow-up letter to document resolution.

5. Altering control over content: An individual’s control of CME/CE content can be altered to remove the opportunity to affec
products/services of a commercial interest. For example:

a. Select someone else to control that part of the content - If a proposed teacher/author has a conflict of interest related to the c
else who does not have a relationship to the commercial interests related to the content.


b. Change the content of the person’s assignment - The role of a person with a conflict of interest can be changed within the CM
is no longer teaching about issues relevant to the products/services of the commercial interest. For example, an individual with
regarding products for treatment of a disease state could address the pathophysiology or diagnosis of the disease rather than t
c. Limit the content to a report without recommendations - If an individual has been funded by a commercial company to perform
presentation may be limited to the data and results of the research. Someone else can be assigned to address broader implica

d. Limit the sources for recommendations to those based on best available evidence - Rather than having a person with a conf
personal recommendations or personally select the evidence to be presented, limit the role of the person to reporting recomme
structured reviews of the literature with the inclusion and exclusion criteria stated (evidence-based). For example, the individua
from the systematic reviews of a peer reviewed source, e.g. the Cochrane Collaboration (www.cochrane.org).

6. Peer Audit and Evaluation: an informed peer or member of the planning committee will be present, to evaluate the CME/C
be asked to complete a formal, detailed evaluation to measure any bias in the activity.


7. Peer Review of Content: The CME/CE Committee designates a committee representative or the Activity Director to review
to the presentation. The peer reviewer will be asked to complete a formal evaluation to measure whether any bias was in the p
resolution mechanism was provided to the contributor. Reviewer must also measure whether the resolution was adhered durin

8. Altering financial relationships: contributor’s relationship with commercial interest has changed or discontinued, and in do
introduce bias into the content. Although not relevant to COI, relationship must be disclosed to learners for 12 months.

9. Elimination: Contributors who are perceived as either manifesting conflicts of interest or being biased may be eliminated fro
resources (committee members, teachers, authors, etc.) in subsequent certified CME/CE activities.


ADDITIONAL RESOLUTION MECHANISM FOR CME/CE COMMITTEE MEMBERS ONLY

10. Signed Annual Statement: By completing and signing the Annual Statement, the committee member agrees to recuse him
and vote on the relevant submitted activity

11. Relationship with Industry Statement: This statement will be read at the beginning of each committee meeting. It remind
policy to have member recuse him/herself from discussion and vote on possible conflict of interest items.


12. Disclosure to Peers and Activity Audience: Committee disclosure information will be shared with peers and any relevant
nterest

ers of CME to have a mechanism in place for identifying
 ders financial relationships to create actual conflicts of
rtunity to affect the content of CME about the products or
 eting, re-selling, or distributing health care goods or



nism in place for identifying and resolving potential
st” to exist when an individual has an opportunity to affect



ntial resolution mechanisms for resolving COI.
ill notify contributors of the mechanism selected for their




ng continuing education



 COI

 e contributor agrees that said conflicts or relationships
ons will be limited to those based on the best available
d medical practice. They also agree to all other




s, and queried regarding their impressions concerning
copies of the evaluation summaries and comments.

e at the beginning of their presentation (please see



phone to discuss ways to avoid perception of bias due to



ove the opportunity to affect content related to the



ct of interest related to the content, choose someone



n be changed within the CME/CE activity so that he/she
example, an individual with a conflict of interest
of the disease rather than the therapeutics.
mercial company to perform research, the individual’s
to address broader implications and recommendations.

having a person with a conflict of interest present
 rson to reporting recommendations based on formal
  For example, the individual could present summaries
rane.org).

ent, to evaluate the CME/CE activity. This evaluator will




e Activity Director to review the content of the slides prior
ether any bias was in the presentation and, if so, what
solution was adhered during the presentation.

 or discontinued, and in doing so, no duty remains to
ners for 12 months.

iased may be eliminated from consideration as




ember agrees to recuse him/herself from the discussion



mmittee meeting. It reminds members of the College
ems.


with peers and any relevant activity audiences.
                                                                                                                            SAMPLE
                                                                        ACCF Conflict of Interest (COI) Resolution Chart - FOR CME/CE ACTIVITIES
                                                                        Activity Name:

                                                                             Activity
                                                                              Date:
        Instructions:
1. Activity Director/Editor COI resolution must be conducted by the activity CME/CE approval committee, as part of the approval process.
2. Activity Director/Editor then conducts COI resolution for his/her presenters.
3. Staff CME/CE activity manager must fill in the requested info below for each presenter.
3. Automatic activity level resolutions are checked; share this chart with your director/editor and ask if any further resolution is needed to ensure content validation for any presenters.
4. IMPORTANT: Disqualify anyone who fails to disclose. Disquality employees/owners of a commercial interest from presenting on a relevant topic. Speaker bureau relationships may require a higher level
   COI resolution to ensure content validation.
5. Definitions for a "conflict of interest", a "commercial interest", and for each "resolution mechanism" are attached.
6. Followup with presenters as needed to inform them of the COI mechanisms that will be in effect for their presentation.

Director/Editor who resolved presenter COI:                                                                   Dr. XXXX XXX, Director/Editor                                KEY: Relationship Category
                                                                                                                                                                           1. Consulting Fees, Honoraria                                 7. Officer, director or any other fiduciary role
Committee Chair who resolved Activity Director/Editor COI:                                                   enter name                                                    2. Speaker's Bureau*                                          8. Ownership/partnership/principal*
                                                                                                                                                                           3. Equity interest/stock options                              9. Research grants
                                                                                                                                                                           4. Equity interests                                           10. Fellowship support
Director/Editor COI Review Date:                           enter date of COI resolution                                                                                    5. Royalty income                                             11. Salary*
                                                                                                                                                                           6. Non-royalty payments                                       12. Intellectual property rights
                                                                                                                                                                                                                                         13. Other financial benefit
                                                                                                                                                                           *see "Important" Reminder Note in Instructions

Electronic Signature of Activity Director/Editor conducting COI review: {Signature Here}
     I certify that I have reviewed the following disclosure information for each presenter/faculty and I approve the indicated COI resolution mechanisms

     Further follow up required based on conflicts identified below:

     ______________________________________________________________________

Your selection above constitutes an electronic signature and indicates complete review and approval of all presenter/faculty disclosures provided for the above listed program




                                                                                                                                                                          Activity Level -- Conflict of Interest Resolution Mechanisms
                                                                                                                                                                            Check all that apply; see next page for definitions of each mechanism
                                                                 Disclosure Information                         Does
                                        Relationship                                                          Conflict of
       Activity Presenter
                                         Category          List Name of Commercial Interest                    Interest
              Name                                                                                                                                                                                             (7) Peer                                         (11) Read
                                       (see key above)                                                          (COI)
                                                                                                                                                                                                              Review of                                          Relation-
                                                                                                                exist?
                                                                                                                                                                                           (5)                 Content                                             ship       (12)
                                                                                                                                                            (3)                         Altering                 (List       (8) Alter    (9) Bar       (10)    w/Industry Disclosure
                                                                                                                                                  (2)     Speaker      (4)              Control     (6) Peer  Reviewer      Financial      from        Signed   Statement to Relevant
                                                                                                                              (1) Signed       Audience Disclosure Follow-up              over      Audit &     Name        Relation-    Participa-    Annual     at each   Peers/          Other
                                                                                                                              Attestation      Evaluation  Slide   Phone call           Content    Evaluation   Below )        ships        tion      Statement  meeting    Audience
Dr. XXXX,
                                             N/A           NOTHING TO DISCLOSE                                    No              Yes              Yes           Yes
Director/Editor
                                                           Glaxo Smith Kline
                                                           -Sanofi Aventis/Bristol Myers Squibb
                                                           Parnetship
                                                           -Schering Plough
SAMPLE - Presenter #1                          9                                                                  Yes             Yes              Yes           Yes
                                                           -Merck/Schering Plough Partnership
                                                           -Merck
                                                           -AstraZeneca
                                                           -Accumetrics
                                              1            Ortho Diagnosics
                                              9            -Genentech
                                              9            -United Health Care
                                              1            -Glaxosmithkline Foundation
SAMPLE - Presenter #2                         1            -BG Medicine                                           Yes             Yes              Yes           Yes
                                              1            -Northpoint Domain
                                              3            -Millennum
                                              3            -Northpoint Domain
                                              3            -Cardio DX
SAMPLE - Presenter #3                         1            McKesson Corp                                          Yes             Yes              Yes           Yes
SAMPLE Member #4                             N/A           NOTHING TO DISCLOSE                                    No              Yes              Yes           Yes
SAMPLE Member #6                             N/A           NOTHING TO DISCLOSE                                    No              Yes              Yes           Yes
                                                           Sanofi Aventis
SAMPLE Member #8                                                                                                  Yes             Yes              Yes           Yes
                                              13           Humana
Karen N. Thompson
                                             N/A           NOTHING TO DISCLOSE                                    No              Yes              Yes           Yes
Activity Manager
                                                                                                                           SAMPLE
                                            ACCF Conflict of Interest (COI) Resolution Chart - For Committees Overseeing CME/CE
                                                                                        Name of Committee

        Instructions:
1.   The Chair of the Accreditation Committee will conduct COI resolution for the Chair of each committee overseeing CME/CE activities.
2.   Activity Committee Chair must conduct COI resolution for his/her committee members. If member has nothing to disclose, there is nothing to resolve.
3.   Staff liaison: fill in the requested info below for each committee member; automatic committee level resolutions are checked; share this chart with your committee chair and ask if any further resolution is needed for any members
4.   Definitions for each mechanism is attached.
5. Definitions for a "conflict of interest", a "commercial interest", and for each "resolution mechanism" are attached.
5. Followup with members as needed for implementation of any additional COI mechanisms

Activity Committee Chair who resolved each committee member's COI:                                          Dr. XXXXX XXX, Chair                                             KEY: Relationship Category
                                                                                                                                                                             1. Consulting Fees, Honoraria                             7. Officer, director or any other fiduciary role
                                                                                                                                                                             2. Speaker's Bureau                                       8. Ownership/partnership/principal
                                                                                                                                                                             3. Equity interest/stock options                          9. Research grants
                                                                                                                                                                             4. Equity interests                                       10. Fellowship support
Chair COI Review Date:                                   Enter date of COI resolution                                                                                        5. Royalty income                                         11. Salary
                                                                                                                                                                             6. Non-royalty payments                                   12. Intellectual property rights
                                                                                                                                                                                                                                       13. Other financial benefit

Electronic Signature of Activity Committee Chair conducting COI review: {Signature Here}
      I certify that I have reviewed the following disclosure information for each committee member and I approve the indicated COI resolution mechanisms

      Further follow up required based on conflicts identified below:

      ______________________________________________________________________

Your selection above constitutes an electronic signature and indicates complete review and approval of all key planners' disclosures provided for the above listed program




                                                                                                                                                                       Committee Member Conflict of Interest Resolution Mechanisms
                                                                                                                                                                             Check all that apply; see next page for definitions of each mechanism
                                                                                                              Does
                                                         Disclosure Information                              Conflict
     Committee Member                 Relationship                                                              of
          Name                         Category    List Name of Commercial Interest                          Interest
                                      (see key above)                                                                                                                                                           (7) Peer                                    (11) Read
                                                                                                              (COI)                                                                                           Review of                                      Relation-    (12)
                                                                                                              exist?                                                                        (5)                Content                                         ship    Disclosure
                                                                                                                                                           (3)                           Altering                 (List    (8) Alter    (9) Bar     (10)    w/Industry      to
                                                                                                                                                 (2)     Speaker      (4)                Control     (6) Peer  Reviewer    Financial     from      Signed    Statement Relevant
                                                                                                                             (1) Signed       Audience Disclosure Follow-up               over       Audit &     Name      Relation-   Participa- Annual      at each   Peers/            Other
                                                                                                                             Attestation      Evaluation   Slide  Phone call             Contentl   Evaluation Below )       ships        tion    Statement meeting     Audience
Dr. XXXX,
                                            N/A          NOTHING TO DISCLOSE                                     No                                                                                                                                   Yes         Yes          Yes
Chair
                                                         Glaxo Smith Kline
                                                         -Sanofi Aventis/Bristol Myers Squibb
                                                         Parnetship
SAMPLE - Member #1                           9                                                                   Yes                                                                                                                                  Yes         Yes          Yes
                                                         -Merck
                                                         -AstraZeneca
                                                         -Accumetrics
                                             1           Ortho Diagnosics
                                             1           -Genentech
                                             1           -United Health Care
                                             9           -Reata
SAMPLE - Member #2                           9           -Lab Corp                                               Yes                                                                                                                                  Yes         Yes          Yes
                                             1           -Northpoint Domain
                                             3           -Millennum
                                             3           -Northpoint Domain
                                             3           -Cardio DX
SAMPLE - Member #3                           1           McKesson Corp                                           Yes                                                                                                                                  Yes         Yes          Yes
                                             8           AKKA LLC
                                             1           HCA
SAMPLE - Member #4                                                                                               Yes                                                                                                                                  Yes         Yes          Yes
                                             9           Diagenics
                                            13           Johnson & Johnson
SAMPLE Member #5                            N/A          NOTHING TO DISCLOSE                                     No                                                                                                                                   Yes         Yes          Yes
SAMPLE Member #6                            N/A          NOTHING TO DISCLOSE                                     No                                                                                                                                   Yes         Yes          Yes
SAMPLE Member #7                            N/A          NOTHING TO DISCLOSE                                     No                                                                                                                                   Yes         Yes          Yes
                                                         Sanofi Aventis
SAMPLE Member #8                                                                                                 Yes                                                                                                                                  Yes         Yes          Yes
                                            13           Humana
SAMPLE Member #9                            N/A          NOTHING TO DISCLOSE                                     No                                                                                                                                   Yes         Yes          Yes
STAFFER NAME
                                            N/A          NOTHING TO DISCLOSE                                     No                                                                                                                                   Yes         Yes          Yes
primary staff liaison

				
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