Washington University Employees Ownership or Other Employment for CME purposes
For CME activity planners and coordinators at Washington University, we are providing a list of the companies that WU employees have indicated ownership of or employment at to help determine if a company is designated as ineligible (formerly commercial interests). This list will be updated periodically.
Because owners and employees of ineligible companies are individuals who have a legal duty to act in the company’s best interests, which is considered an unmitigable conflict, they must be excluded from controlling content of an accredited continuing education (CE) activity as either a planner or speaker. There are only 3 circumstances in which owners or employees of ineligible companies can participate:
- when activity content is not related to business lines or products of the company,
- when activity content is limited to basic science research, and they do not make care recommendations, or
- when participating as technicians to teach safe and proper use of medical devices and do not recommend whether or when a device is used.
ACCME has incorporated eligibility information directly into the Standards for Integrity and Independence in Accredited Continuing Education. Companies that are ineligible to be accredited in the ACCME System (ineligible companies) are those whose primary business is producing, marketing, selling, re-selling, or distributing healthcare products used by or on patients. Examples of such organizations include:
- Advertising, marketing, or communication firms whose clients are ineligible companies
- Bio-medical startups that have begun a governmental regulatory approval process
- Compounding pharmacies that manufacture proprietary compounds
- Device manufacturers or distributors
- Diagnostic labs that sell proprietary products
- Growers, distributors, manufacturers or sellers of medical foods and dietary supplements
- Manufacturers of health-related wearable products
- Pharmaceutical companies or distributors
- Pharmacy benefit managers
- Reagent manufacturers or sellers
According to ACCME definitions, biomedical startups become ineligible companies when they begin a governmental regulatory approval process. In the U.S., the regulatory approval process operationally begins when an IND for drugs or PMA (premarket approval) for devices has been submitted; that is, before clinical trials have started.
Last updated 5/24/2022
