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POLICIES

COMMERCIAL SUPPORT FOR CME PROGRAMS 
CME of Southwest Virginia
Commercial Support Policy
Effective September 2003
Updated January 2005
Updated October 2013

CME of SWVA Organization receives, on an ongoing basis, financial 
support from many areas both within the organization and from 
outside (commercial) sources.  In an effort to comply with 
guidelines set by Medical Society of Virginia (MSV), ACCME, the 
Office of the Inspector General (OIG) for Health and Human Services, 
the Pharmaceutical Researchers and Manufacturers of America (PHARMA) 
Code, the Food and Drug Administration (FDA) and others, the CME of SWVA agrees to follow the Commercial Support Policy 
written below when soliciting and receiving financial support from 
outside (commercial) sources.  This policy incorporates 
the “Standards of Commercial Support” as written by the ACCME, and 
the “Memorandum of Understanding” between CME of SWVA and HCA Corporate Counsel.  It is not intended to 
replace either of these documents nor any of the industry guidelines 
set forth by the governing bodies listed above.  Rather, it is 
merely a summary of these standards and guidelines as they may be 
applied to CME of SWVA.

CME Program Coordinators and Physician Planners are required to 
determine CME activity topics using guidelines set forth in the CME 
Goals and Objectives.  Tools to accomplish this may include, for 
example, Needs Assessments, Medical Staff Surveys, or physician 
and/or hospital staff requests, among others. 
CME Activity Coordinators and Physician Planners may NOT create CME 
activities based solely upon input and/or solicitation from 
pharmaceutical companies or manufacturer representatives. 
CME Activity Coordinators and Physician Planners are responsible for 
locating and contracting qualified program faculty and venues.  Use 
of objective lecture bureaus, such as those listed with medical 
colleges and professional organizations, is encouraged.  Use of a 
national speaker list is acceptable as long as the CME activity is 
scheduled and the speaker is chosen BEFORE a grant is requested. 

Under no circumstances may any representative of CME of SWVA solicit or accept funds from a pharmaceutical company 
or manufacturer that are restricted to a specific speaker or program 
title.  ALL GRANTS MUST BE UNRESTRICTED in this regard. 

Pharmaceutical companies may not make any payments directly to CME 
program faculty, caterers, venues, or any other CME activity cost.  
The only financial support that may be accepted by CME of SWVA from pharmaceutical companies or manufacturers are in 
the form of unrestricted grants.  A pharmaceutical or manufacturer 
company’s requirement that the grant be used solely for educational 
or scientific purposes is okay, as long as no further restrictions 
apply. 

Pharmaceutical companies may not make any payments directly to area 
medical societies for programs presented to or in conjunction with 
the CME organization. 

Under no circumstances may there be any Commercial Support provided 
in relation to a CME activity of which the CME of SWVA is not aware. 

Commercial Supporters may not act as a Joint Sponsor of a CME 
activity. 

Full disclosure of all Commercial Support received for a CME 
activity must be made to the participants prior to the beginning of 
the activity. 

All CME committee members must disclose any individual relationship
(s) they have with a Commercial Supporter of a CME activity as part 
of the CME planning process.  As such, the CME Administrator should 
inquire as to any financial relationship(s) of CME committee members 
with the Commercial Supporter(s) of a given CME activity at the time 
the activity is presented to the CME Planning Committee for 
approval.  A notation of such inquiry and resulting responses must 
be made in the minutes of the Planning Committee session. 

Faculty disclosure of financial relationship(s) between themselves 
and/or their spouse (if applicable) with the Commercial Supporter(s) 
of a CME activity should be obtained during the planning process of 
the activity.  This will enable the CME Coordinator to identify and 
resolve any potential conflict(s) of interest before the CME 
activity takes place. 

All Commercial Support provided to CME of SWVA 
and/or its Joint Sponsors must be documented in writing.  Such 
Letter of Agreement, whether originating from CME of SWVA 
or the Commercial Supporter, must specify the 
following: 

A full itemization of the use of funds expected for the activity, 

A full itemization of any Joint Sponsors of the activity, 

A specific listing of funds originating from the Commercial 
Supporter for the activity, and 

Signatures of representatives for BOTH the Commercial Supporter and 
the Accredited Provider. 

Any honoraria to be paid to faculty of a CME activity should be 
determined by CME of SWVA and/or its Joint Sponsor(s).  Such honoraria must comply with the CME of SWVA “Speaker Honoraria Policy.” 

All CME activities presented by CME of SWVA and/or its Joint Sponsors must report complete and full accounting by way 
of an approved Financial Statement form and supporting receipts 
and/or documentation. 

CME of SWVA will not allow any advertisements or 
product-promotional material to appear on any slides, graphics, 
abstracts, handouts, or any other educational materials associated 
with any of its CME activities.  Advertisements or product-
promotional material will only be allowed on CME activity
fliers, “save-the-date” cards, brochures, etc. that are NOT 
considered part of the educational activity itself.