This document describes the process and considerations for COI Mitigation.

Instructions for Disclosing Financial Relationships 

How often are Disclosure of Financial Relationship forms Completed?

Timeline Considerations for Live Courses/ Non-RSS Activities

Timeline Considerations for RSS Activities

COI Mitigation FAQ

Disclosure of Financial Relationships - Yearly Renewal

• Disclosure of Financial Relationships forms are valid for 1 Calendar Year from the date of completion.

For example: If the disclosure form is completed on July 1, 2024, then the form will need to be resubmitted no later than July 1, 2025 in order to remain in compliance.

Timeline for Live Courses/ Non RSS Activities:

• COI Information and Disclosures are due by EOD on the 15th of the month prior to the month in which the activity starts.

• For example: For an activity that starts any day in June, COI is due by EOD on May 15th. Please see below.

Timeline for Regularly Scheduled Sessions

Note: RSS Sessions are referred to as RSS Children in the new MiCME system.

Timeline Requirements:

• Faculty/Presenters must be assigned to the activity and Disclosure of Financial Relationship forms must be submitted 1 week before the start of the first RSS Child.

• For Example: An RSS beginning on Friday July 12, 2024 will have had all COI documentation submitted by EOD Friday July 5, 2024.

• The Faculty/Presenter only has to complete the form once. All RSS Children for the activity will inherit the Faculty/Presenter’s COI information.

Note:Tumor Board activity timelines may vary and are communicated to the Activity Coordinator/Planner by the COI manager on a case by case basis.

Frequently Asked Questions

Q. Are there any Financial Relationships that do not need to be identified?

Yes, there is no need to disclose financial relationships with companies whose mission and function include:

• Providing clinical services directly to patients
• The education of healthcare professionals
• Serving as a fiduciary to patients, the public, or population health.

A full list of such organizations can be found here

Q. Who cannot plan or present educational content at a CME activity?

• Individuals who refuse to identify their financial relationships.
• Individuals who are employees or owners of an ineligible company, except in some very rare instances.

Q. When should mitigation of relevant financial relationships take place?

All financial relationships must be identified and mitigated before the individual assumes their assigned role in the activity, whether that is planning the content or delivering a lecture. The timing depends upon the individual’s role in the activity:

• For Planners and Co-Planners, all relevant financial relationships must be identified and mitigated before the application can be submitted.
• For presenters, all relevant financial relationships must be identified and mitigated before the start of the CME activity.

Q. How can the identification and mitigation process be monitored to ensure it remains on track and the activity can go ahead as planned?

The Activity Coordinator uses the Financial Relationship Mitigation Summary to monitor which financial forms have been completed and if any financial relationships have been identified. The OCME-LL Financial Relationships Mitigator will review and assess all financial relationships for relevance to the proposed educational topic or content, and propose mitigation steps (if possible). Once all financial information has been finalized, the Activity Information Sheet can be easily shared with participants by email, physically posting at the activity, or included in print or electronic activity materials.

Q. Must physicians in training complete a disclosure of all financial relationships before presenting at a CME activity?

Yes, in general all physicians in training are required to complete the disclosure process before contributing to an educational activity providing CME credit.  However, they are not required to complete a disclosure before presenting information regarding the care of a specific patient in which they helped to provide direct clinical care (for instance a case discussion at a morbidity and mortality conference).

Q. Are planners or presenters only required to disclose financial relationships that they consider relevant to the topic or content of the educational activity?

No, they must disclose all financial relationships with ineligible companies.

Q. Can a planner or presenter decide for themselves which financial relationships are relevant to the educational activity?

No, they must disclose all financial relationships with sufficient time for the Financial Relationship Mitigator in the Office of CME and Lifelong Learning to review and provide mitigation steps, should this be possible.