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Understanding When Conflict of Interest (COI) Exists
When you need COI Forms and when you don’t!
Amy L. Charette, MS, RN
WMSD Nurse Peer Review Leader
Understand Conflict of Interest
The Confusing 4 C’s
➢Content Integrity
➢Conflict of Interest (COI)
➢Commercial Interest
➢Commercial Support
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ANCC Content Integrity Standards
http://www.nursecredentialing.org/Accreditation-
CEContentIntegrity.pdf
.
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GOAL: Quality Education -- Free of Bias
Content Integrity
Actual or potential conflicts of interest are resolved
Content is based on best available evidence
Independence from commercial interest organization funding for the activity (commercial support)
Free from promotional activity
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Quality Education -- Free of Bias
Content Integrity
Actual or potential conflicts of interest are resolved
Content is based on best available evidence
Independence from commercial interest organization funding for the activity (commercial support)
Free from promotional activity
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Conflict of Interest
A conflict of interest (COI) exists when three conditions are
present:
1. An individual is in a position to control content of the
educational activity, and
2. The individual has a financial relationship with a
commercial interest* organization, and
3. The products and/or services of the commercial
interest* organization are relevant to the content of the
educational activity
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Commercial Interest Organization
The American Nurses Credentialing Center (ANCC)
defines an organization as having a commercial
interest (“Commercial Interest Organization”)* if it:
Produces, markets, sells or distributes health care goods or
services consumed by or used on patients;
Is owned or operated, in whole or in part, by an organization
that produces, markets, sells or distributes health care
goods or services consumed by or used on patients; or
Advocates for use of the products or services of commercial
interest organizations.
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Relevant relationships in COI
Relevant relationships, as defined by ANCC, are relationships with a commercial interest if the products or services of the commercial interest are related to the content of the educational activity.
Relationships with any commercial interest of the individual’s spouse/partner may be relevant relationships and must be reported, evaluated, and resolved.
Relationships are considered relevant if they have occurred within the past 12 months
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Eligibility to participate in planning/presenting
Employees of commercial interest organizations are not permitted to
serve as planners, speakers, presenters, authors and/or content
reviewers if the content of the educational activity is related to the
products or services of the commercial interest organization.
Employees of commercial interest organizations are permitted to
serve as planners, speakers, presenters, authors and/or content
reviewers if the content of the educational activity is NOT related to
the products of the commercial interest organization.
Individuals who have non-employee relationships with commercial
interest organizations are permitted to serve as planners, speakers,
presenters, authors and/or content reviewers as long as the nurse
planner has implemented a mechanism to identify, resolve and
disclose the relationship according to ANCC standards.
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Nurse Planner Decision Matrix
1. Are the products or services of any commercial interest
relevant to the content of educational activity?
2. Identify who has the opportunity to influence the content of
the educational activity.
3. For all individuals who have the opportunity to influence
content: document relationships the individual (including
spouse/significant other) has with commercial interest
organizations within the past 12 months that are relevant to
the content.
4. If the relationship is relevant, COI form with resolution is
required.
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Documenting COI
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Documenting Control of Content
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2016 WMSD COI Form
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COI Resolution Process
Removing the individual with conflict of interest from participating in all parts of the educational activity.
Revising the role of the individual with conflict of interest so that the relationship is no longer relevant to the educational activity.
Not awarding continuing education contact hours for a portion or all of the educational activity.
Undertaking review of the educational activity by the Nurse Planner to evaluate for potential bias, balance in presentation, evidence-based content or other indicator of integrity and absence of bias AND monitoring the educational activity to evaluate for commercial bias in the presentation.
Undertaking review of the educational activity by the Nurse Planner to evaluate for potential bias, balance in presentation, evidence-based content or other indicator of integrity and absence of bias AND reviewing participant feedback to evaluate for commercial bias in the activity
Undertaking review of the educational activity by a content reviewer to evaluate for potential bias, balance in presentation, evidence-based content or other indicator of integrity and absence of bias AND monitoring the educational activity to evaluate for commercial bias in the presentation.
Undertaking review of the educational activity by a content reviewer to evaluate for potential bias, balance in presentation, evidence-based content or other indicator of integrity and absence of bias AND reviewing participant feedback to evaluate for commercial bias in the activity
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Key Takeaways
It’s all about preventing commercial influence in CNE.
No COI for anyone if the content does not involve clinical
treatment or management of patients with discussion of
products or services used on patients.
Not a commercial interest company by ANCC definition if the
company’s products and services are not used on patients.
No COI if the planner/presenter has no commercial
relationships relevant to content that does discuss products
and services used on patients.
Actual COI often can be resolved, always is disclosed.
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WMSD Resources
• WMSD Website
• http://www.westernmsd.org/MainMenu/CE
• WMSD Resources – Individual Activity Applications or
Approved Providers• ANCC Content Integrity Standards
• http://www.nursecredentialing.org/Accreditation-
CEContentIntegrity.pdf
• Evaluating Conflict of Interest Flowchart 2015
• WMSD Website FAQs
• http://westernmsd.org/MainMenu/CE/Frequently-
Asked-CNE-Questions
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