Subject: Faculty Management Date of Last Revision: July Upon acceptance of the Activity/Program Director s invitation to participate as faculty,

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1 Plicy #: 11.0 Originatin Date: 2003 Subject: Faculty Management Date f Last Revisin: July 2015 Upn acceptance f the Activity/Prgram Directr s invitatin t participate as faculty, electrnic requests fr faculty planning data are cmmunicated (the PD is t prvide the OCME with faculty name, title, affiliatin and address) as part f the CME applicatin r by after the planning f the activity has cmmenced. Timely cmpletin f the faculty/speaker frms thrugh ICMES is critical in the executin f the CME prcess. The faculty must cmplete all paperwrk at least 7 days prir t the CME activity Cpyright Agreement When submitting a CME activity fr OCME apprval, the planner is warranting that the material used in the CME activity is riginal r adheres t cpyright laws and/r the CME activity will be cnducted in cmpliance with cpyright laws. Cpyright entitles the cpyright hlder t exclusive rights t the reprductin r distributin f his/ her wrk. If any part f an riginal wrk (e.g., text, graphics, tables, images, etc.) is used, the planner and/r presenter must btain reprint permissin frm the cpyright hlder (i.e., authr, publisher). The Inva OCME des nt evaluate whether the educatinal material is riginal wrk and Inva OCME is held harmless (nt respnsible) fr any cpyright infringements by the planner/presenter.

2 Activity faculties are required t utilize citatins fr all diagnstic, therapeutic and scientific references Faculty Hnraria Travel and Expense Reimbursement Hnraria Guidelines: Hnraria fr prgram faculty wh cntribute t r participate in a CME activity will be determined by the Prgram Directr. Industry supprters f the activity cannt determine hnraria amunts. The fllwing hnraria ranges have been determined t be apprpriate and usual by the Inva CME Advisry Cmmittee. This plicy gverns nly thse activities spnsred by Inva OCME. In mst cases Inva faculty speaking fr an Inva CME event will nt receive an hnrarium fr participatin. In ccasinal instances, Inva faculty might be paid an educatinal stipend. This payment shall nt exceed $1,000. Hnraria fr guest faculty fr an Inva CME activity shall nt exceed $2500. In the case f an exceptinal speaker that requires a larger hnrarium, the Prgram Directr must btain apprval frm the Directr f OCME. N payment shall be given t the directr f the activity, planning cmmittee members, teachers r authrs, jint prvider, r any thers invlved with the supprted activity. If teachers r authrs are listed n the agenda as facilitating r cnducting a presentatin r sessin, but participate in the remainder f an educatinal event as a learner, their expenses can be reimbursed and hnraria can be paid fr their teacher r authr rle nly. Travel Guidelines: Speakers are requested t make their wn travel arrangements.

3 Travelers are expected t bk the lwest available ecnmy class airfare, cnsistent with business requirements. Inva will nt reimburse fr first class travel. If a penalty is incurred due t a traveler vilating airline ticketing rules, the traveler will be respnsible fr the additinal cst. Hwever, penalties fr making changes t r nt using nn-refundable tickets can be reimbursed if the penalty was unavidable due t business reasns r circumstances beynd the traveler s cntrl. Travelers shuld chse a reasnably priced htel with a single ccupancy rate. Use the lwest cst grund transprtatin cnsistent with business needs. Fr example, many htels ffer free airprt shuttles, which shuld be used whenever practical. Private car service will nt be reimbursed unless there are extenuating circumstances. Travelers will be reimbursed fr reasnable actual meal expenses. When it is nt practical t claim actual meal expenses, travelers may use the federally published dmestic per diem r freign per diem rates fr meals and incidental expenses applicable fr the city f travel. Prcess: Travelers are expected t submit reimbursement request t the OCME with required supprting dcumentatin within 30 days f incurring the expense r returning frm the trip. Out-f-pcket expenses (i.e. airfare, cnference fees, mileage, htel, meals, bks, etc.) lder than 120 days will nt be reimbursed. This means that the faculty and staff have a maximum f 120 days frm the date f the transactins t submit expenses t the OCME.

4 Faculty shuld use the Faculty Reimbursement frm and include riginal receipts. All expenses shuld be frwarded t the OCME pint f cntact fr prcessing. CME staff will initiate all payments fr speakers. Direct payments t speakers by cmmercial supprters and spnsring departments are prhibited. The OCME must dcument a full accunt f the disbursing f funds. The Inva OCME will nt use cmmercial supprt t pay fr travel, ldging, hnraria, r persnal expenses fr nn-teacher r nn-authr participants f a CME activity. Payments frm cst centers and fundatin accunts The individual department must prvide CME with a cst cde t pay fr the speaker s hnrarium and travel expenses. The CME Office will initiate the transfer f funds. The Fundatin must prvide CME with the fundatin fund name and number t pay fr the speaker s hnrarium and travel expenses. The CME Office will submit the prper paperwrk t the fundatin fr prcessing Presentatins Slide sets must be submitted fr cntent review tw weeks prir t the activity fr OCME review t ensure it is nn-biased. If necessary, an expert nt affiliated with the activity and/r Inva will be cnsulted t ensure cntent is evidence-based and nn-biased

5 11.4 Disclsure, Bias & Cnflict f Interest Disclsure Faculty must disclse real r apparent cnflict f interest relating t the tpics f the educatinal activity. In additin, faculty will als disclse any discussins f unlabeled r nn-fda apprved drugs r devices, diagnstic r treatment therapies during their presentatin(s). All faculties must cmplete the nline Faculty Disclsure Frm, linked t their prfile in ICMES. This frm is intended t disclse t the activity attendees the existence f any real r apparent significant financial interest r ther relatinship a speaker and their spuse r partner has: with the manufacturer(s) f any cmmercial prduct(s) with prvider(s) f any cmmercial service(s) that exists at the time f the activity r existed in the 12 mnths preceding the activity discussed in an educatinal presentatin, whether r nt there is direct cmmercial supprt fr the CME activity. Each faculty member scheduled t speak at an apprved CME activity is required t cmplete the nline Faculty Disclsure Frm, linked t their prfile in ICMES, whether they are Inva-affiliated r guest faculty. The nline frm includes: name f the CME Activity, activity date and faculty names faculty member shuld answer questins by checking the apprpriate bx faculty member must disclse nature f relevant financial relatinship(s), including that there are n relatinships t disclse

6 if there are relevant financial relatinship(s) with nn-gvernmental entities such as cmmercial supprters within the 12 mnths prir t the date f the activity, the faculty member must specify: name f the cmmercial interest nature f relatinship the persn has with the cmmercial interest (such as cnsultant, speaker s bureau) faculty member signs and dates the frm. Verbal Disclsure At the start f the activity, the activity directr r speaker will annunce t the attendees verbally and/r with visual media (i.e. a slideshw presentatin) the disclsure infrmatin cncerning the event faculty. This includes either: disclsure listing specific relatins with any pharmaceutical cmpanies n significant relatinship t disclse Refusal t Disclse If a ptential faculty member refuses t prvide the disclsure, that individual will be nt be eligible t serve in any capacity in the delivery f the CME activity. Refusal shuld be anntated n the nline frm by the CME crdinatr and ntice escalated t the Prgram Directr and Directr f CME.

7 Cnflict f Interest It is the plicy f the Office f CME at Inva Health System t ensure balance, independence, bjectivity, and scientific rigr in all its educatinal activities. The ACCME/Medical Sciety f Virginia defines a cnflict f interest as existing in presence f any financial benefit t an individual wh is in a psitin t cntrl the cntent f a CME activity. They have delegated respnsibility fr defining implementatin plicy and prcedures fr this t the accredited prviders. Relevant ACCME/Medical Sciety f Virginia Standards The (CME) prvider must be able t shw that everyne wh is in a psitin t cntrl the cntent f an educatin activity has disclsed all relevant relatinships with any cmmercial interest t the prvider. An individual wh refuses t disclse relevant financial relatinships will be disqualified frm being a planning cmmittee member, teacher, r an authr f CME, and cannt have cntrl f r respnsibility fr, the develpment, management, presentatin r evaluatin f the CME activity. The (CME) prvider must have implemented a mechanism t identify and reslve all cnflicts f interest prir t the educatin activity being delivered t learners. An individual must disclse t learners any relevant financial relatinship(s), t include the fllwing infrmatin: The name f the individual; The name f the cmmercial interest(s); The nature f the relatinship the persn has with each cmmercial interest.

8 Identificatin f Cnflicts f Interest (COI) Planning team members must disclse their relevant financial relatinships prir t the activity planning using the Faculty Disclsure & Cnflict f Interest Reslutin frm. The speakers, presenters and authrs must submit their cmpleted disclsure frms at least 30 days prir t their presentatins. If this is nt dne and there is a cnflict f interest fund it will be up t the Prgram Directr t find a replacement fr the Planning Cmmittee Member r exclude them frm the planning f the activity. Disclsures are used t determine whether r nt a cnflict exists. Factrs t be cnsidered in identifying whether an individual wh is in a psitin t cntrl the cntent f an activity has a COI include: The fcus and cntent f the educatinal activity The individual s rle in the activity An individual s past financial relatinships with r interests in a cmmercial entity An individual s past financial relatinships with r interests in a cmmercial entity pertaining t cntent f the activity Prcedure t Reslve Cnflicts f Interest (COI) If the individual has n financial relatinship, n further actin is required. If the individual has financial relatinships with ne r mre cmmercial interests, the CME staff assesses ptential risk. If a cnflict is suspected, the review is escalated t the Directr f CME, and the Medical Directr f CME, if necessary, fr reslutin. Inva CME may identify an independent cntent reviewer t cnduct a secndary review.

9 Mechanisms t Reslve Cnflicts f Interest (COI) The fllwing are ptential mechanisms that can be used t reslve a cnflict: Cmpletin & OCME apprval f the Faculty Disclsure & Cnflict f Interest Reslutin frm Change the fcus f the presentatin s that the cntent is nt abut prducts r services related t the cmmercial entity and make recmmendatins that are based n structured review fr best evidence Review the presentatin slides and handuts prir t activity in light f evidencebased guidelines by the Prgram Directr r the Department Chair and recmmend changes if apprpriate Limit the presentatin r material t specific areas in which the financial relatinship is nt relevant (e.g., presentatin limited t data/research smene else address recmmendatins) Selecting an alternate speaker Omitting recmmendatins fr specific prducts Refusal f credit Mnitring A variety f mnitring effrts will be implemented as part f this plicy. Review f COI statements and actins taken in accrdance with this plicy The OCME review f materials t be presented, as apprpriate t the Prgram Directr the Directr f CME and the Medical Directr f CME, as needed. Review f evaluatin data fr presence f bias. Indicatins f >20% f participants indicating bias in a presentatin r in the verall activity will trigger a

10 retractive review f all materials presented t the participants, discussin with the Prgram Directr, the Directr f CME and/r the CME Advisry Cmmittee. Individuals whse ratings indicate presence f bias may be precluded frm future Inva CME activity planning r presentatin.