ASRM Relevant Financial Relationship Policy
1.0 Purpose
The American Society for Reproductive Medicine designs educational activities to enhance physician and healthcare provider knowledge, competence, and professional performance. To achieve this, we rely on the active voluntary involvement of volunteer experts, most of whom have multiple financial relationships within the reproductive health space. Therefore, to achieve this and maintain credibility as a valued resource, all parties engaged must carefully avoid any conflict between their own personal, professional, or business interests and the interests of ASRM in any activities performed on its behalf.As an accredited provider with the Accredited Council for Continuing Education (ACCME), ASRM must remain transparent in providing accredited activities under the Standards for Integrity and Independence in Accredited Continuing Education (Standard 1-Ensures Content is Valid and Standard 3- Identify, Mitigate and Disclose Relevant Financial Relationships). The Standards for Integrity ensures that continuing education materials are developed from evidence-based, valid content free from commercial influence. The purpose of ASRM’s Financial Relationships Disclosure Policy is to:
- enhance transparency regarding accredited continuing medical education being offered by ASRM,
- meet the requirement of identifying and mitigating relevant financial relationships with ineligible companies,
- ensure that ASRM is providing CME that is accurate, balanced, and free from any influence from ineligible companies.
2.0 Policy
ASRM's policy is that all financial relationships and roles with ineligible companies be subject to review. All voluntary non-employee persons involved in accredited activities must report all financial relationships, regardless of the monetary amount received, annually and whenever a change occurs. Financial relationships will be mitigated by the procedures outlined below. This policy is intended to supplement, but not replace, any applicable state and federal laws governing financial relationships applicable to nonprofit and charitable organizations.
3.0 Policy Scope
All voluntary individuals involved in controlling, developing, or disseminating any content within an educational activity will be required to fully disclose all financial relationships and roles with ineligible companies (see section 6.0 for definition).
4.0 Mitigation of Relevant Financial Relationships
The mitigation strategies are designed to help ASRM assess volunteers’ relevant financial relationships while serving in various ASRM CME program roles. The nature of the relationship will determine the mitigation plan. All financial relationships will be reviewed based on the role a volunteer is asked to serve within the educational activity. Owners/Executive leadership of ineligible companies cannot hold chair positions on any CME activities. All speakers approved to serve will be required to limit their discussion and presentations to evidence-based content and research and are not permitted to include or acknowledge specific trade names, products, or companies.ASRM mitigation strategies include:
- Divest the financial relationship,•
- Recusal from conversation and/or decision-making aspects of the program planning with which there is a financial relationship,•
- Peer review of planning decisions or content by persons without relevant financial relationships•
- Attest that clinical recommendations are evidence-based and free of commercial bias (e.g., peer-reviewed literature, adhering to evidence-based practice guidelines)•
- Recusal from discussion related to therapies and treatments that acknowledge a specific trade name, product, or company,•
- Recusal from discussion related to data and/or best practices and research that acknowledge a specific trade name, product, or company,•
- Elimination of or recusal from discussions that reference company trade names and products/services.•
- Recusal from conversation and/or decision-making aspects regarding collaboration of activities/events with which there is a relevant financial relationship.
5.0 Failure or Refusal to Disclose
Failing to disclose all financial relationships or roles with ineligible companies can cause harm to the reputation of ASRM, or the ACCME accreditation standing, and may impact the ability to provide CME. If a volunteer subject to the relevant financial relationship policy realizes they failed to disclose a financial relationship, they should do so immediately. If a relevant financial relationship is discovered by someone other than the volunteer, then the ASRM Chief Education and Science Officer (CESO) will be informed, and the relevant financial relationship will be investigated, adjudicated, and mitigated. Deliberate failure to disclose will result in removal from the educational activity role. Additionally, any refusal to disclose all financial relationships will result in removal from the educational activity role.
6.0 Definitions
Organization: ASRM or any of its affiliate societies or groups.Ineligible companies are those whose primary business is producing, marketing, selling, reselling, or distributing healthcare products used by or on patients.
Eligible companies are those whose mission and functions are to provide clinical services directly to patients, educate healthcare professionals, or serve as fiduciaries to patients, the public, or the population health.
Financial relationships are those relationships in which the individual benefits by receiving a salary, royalty, intellectual property rights, consulting fee, honoraria for promotional speaker's bureau, ownership interest (e.g., stock, stock options, or other ownership interest, excluding diversified mutual funds), or other financial benefit.
Relevant financial relationships are those between individuals controlling content related to an ineligible company's business lines or products.
7.0 Supporting Information
ACCME Standard 1 policyACCME Standard 3 policy