Resources for Joint Providership

Frequently Asked Questions

Commercial Support

Commercial Support Information

• AANS CME activities are strictly educational and NOT promotional.
• ACCME requires the separation of education from all promotional activities, materials and messages.
• Payment and arrangements for advertising and exhibits must be separate business transactions and cannot be conditions for commercial support.
• Promotional materials are not allowed to be displayed or distributed within the scientific program education space before, during or after the educational activity.
• If equipment is supplied for an educational activity, it must be for demonstration and educational purposes only.

Income vs. Exhibit Income

Educational Grant

• An educational grant is used to support the educational components of a CME activity. It can be in the form of a monetary grant or an “in-kind” donation.
• Educational grants support expenses for developing and presenting a CME activity.
  • They can be used to pay for the expenses of faculty as well as others who are working on the activity.
  • They can also be used to pay for meals, audio/visual, honoraria and other meeting related expenses.
• Educational grants must go directly to the joint provider organization.
• A Letter of Agreement is required documentation for the commercial support.
• All Letters of Agreement must be signed and dated by the commercial supporter prior to the start of the activity.
  • All Letters of Agreement must be approved, countersigned and dated by an AANS staff representative prior to the start of your CME activity.
  • Commercial funds contributed in support of a specific activity are to be used for that activity per the Letter of Agreement.
• There can be levels of designation with different categories and amounts for commercial support.
  • You CANNOT offer commercial support levels combined with exhibit space or other marketing and/or advertising opportunities as part of these levels of commercial support.
• A complete listing of all the commercial supporters must be included in your final program book.
• Commercial support must be listed separately from exhibits both in the final program and in the budget.
  • Advertisements and promotional material CANNOT be interleafed within the pages of your program book, because it contains CME content.
  • You CANNOT put corporate logos on the final program
• A commercial supporter can ask for an accounting of how their commercial support has been spent and/or ask that unused funds be returned.
• If funds are received after the completion of the program without acknowledgement to learners before the activity occurs, or prior knowledge by the AANS, then the funds will need to be returned to the commercial supporter.

Exhibit Income

Exhibit income is not considered commercial support because the exhibitor is given booth space in exchange for their payment. It is often used to help offset general costs related to an activity.

• Exhibit income does not require a Letter of Agreement.
• Payment and arrangements for exhibits must be separate business transactions and cannot be conditions for commercial support.
  • The company can pay for the grant and exhibit with one check, however, the actual Letter of Agreement for the educational grant must not include the exhibit funds.
• Exhibits must be kept physically separate from the CME education space and exhibit social events must not take place during the CME activity.
• Revenue received from exhibits must be recorded separately from revenue received from commercial support in the activity budget.
• ACCME Commercial Support Information

Useful Resources

• Joint Provider Worksheet of Eligibility
• ACCME Standards for Integrity and Independence in Accredited Continuing Education 
• Accreditation standards, practice gaps, disclosures and conflicts of interest 
  • ACCME Standard 3: Identify, Mitigate, and Disclose Relevant Financial Relationships 
  • Template for Collecting Financial Relationships (Disclosures)
  • Template for Mitigation of Financial Relationships and instructions for how to mitigate conflicts of interest

Glossary of Terms

• AANS: The acronym AANS refers to both the American Association of Neurological Surgeons, a 501(c)(6) organization, and the American Association of Neurosurgeons, a 501(c)(3)
• ACCME: Accreditation Council for Continuing Medical Education
• ACCME-accredited Provider: An accredited provider is an institution or organization that meets the requirements of a CME provider as outlined by the ACCME. The AANS is the accredited provider for your AANS jointly provided activity.
• CME Activity: An educational offering that is planned, implemented and evaluated in accordance with the ACCME Accreditation Criteria, Standards for Integrity and Independence in Accredited Continuing Education and policies
• Commercial Bias: A personal judgment in favor of a specific proprietary business interest of a commercial interest
• Commercial Support: Financial, or in-kind, contributions given by an ineligible company that is used to pay all or part of the costs of a CME activity. The definition of roles and requirements when commercial support is received are outlined in the ACCME Standards for Integrity and Independence.
  • Advertising and exhibit income is not considered commercial support.
• Competence: Competence is a standardized requirement for an individual to properly perform a specific job. Competence is the ability to apply knowledge, skills or judgment in practice if called upon to do so.
• Conflict of Interest (COI): When an individual’s interests are aligned with those of an ineligible company, the interests of the individual are in “conflict” with the interests of the public. The ACCME considers financial relationships to create actual conflicts of interest in CME when individuals have both a financial relationship with a ineligible company and the opportunity to affect the content of CME about the products or services of that ineligible company. The potential for maintaining or increasing the value of the financial relationship with the ineligible company creates an incentive to influence the content of the CME – an incentive to insert commercial bias.
• Continuing Medical Education (CME): Continuing medical education consists of educational activities which serve to maintain, develop or increase the knowledge, skills and professional performance and relationships that a physician uses to provide services for patients, the public or the profession. The content of CME is that body of knowledge and skills generally recognized and accepted by the profession as within the basic medical sciences, the discipline of clinical medicine, and the provision of health care to the public.
• Credit: The “currency” assigned to CME activities. Requirements for the designation of credit are determined by the organization responsible for the credit system, e.g., AMA PRA (Category 1 and 2 Credit). Credit is based on 15-minute increments (.25 credits) of medical education.
• Data Sources: Data sources indicate how an organization determines the professional practice gap. Examples of data sources: expert opinion; measures required by government; national guidelines; specialty guidelines; hospital QI information; research findings; previous activity evaluations; etc.
• Educational Grants: Educational grants are used to support the educational components of a CME activity. It can be in the form of a monetary grant or an “in-kind” donation.
• Exhibit: Exhibit income is not considered commercial support because the exhibitor is given something (booth space) in exchange for their payment. It is often used to help offset general costs related to an activity.
• [Relevant] Financial Relationships: The ACCME defines “relevant financial relationships” as financial relationships in any amount occurring within the past 24 months that create a conflict of interest. ACCME focuses on financial relationships with ineligible companies in the 24-month period preceding the time that the individual is being asked to assume a role in controlling content of the CME activity. ACCME has not set a minimal dollar amount for relationships to be significant. Inherent in any amount is the incentive to maintain or increase the value of the relationship.
• Ineligible Company: Ineligible companies are those whose primary business is producing, marketing, re-selling or distributing health care goods or services consumed by, or used on, patients. The ACCME does not consider providers of clinical service directly to patients to be ineligible companies. An ineligible company is not eligible for ACCME accreditation.
• “In-Kind” Commercial Support: “In-kind” refers to the loan or donation of equipment or supplies as well as services from an ineligible company. Letters of Agreement must be completed for in-kind support. Examples of in-kind support include equipment, supplies, and facilities.
• Joint Providership: Joint Providership is the providership of a CME activity by two institutions or organizations when only one of the institutions or organizations is accredited. The accredited provider must take responsibility for a CME activity when it is presented in cooperation with a non-accredited institution or organization and must use the appropriate accreditation statement. An ineligible company cannot take the role of non-accredited entity in a joint providership relationship.
• Letter of Agreement (LOA) or Educational Grant: The terms, conditions and purposes of the commercial support must be documented in a written agreement between the commercial supporter and the CME provider. Both the commercial supporter and the CME provider must date and sign the written agreement prior to the activity. The agreement must include the CME provider, even if the support is given directly to the provider’s jointly provided organization. The written agreement must specify the ineligible company that is the source of commercial support and the monetary amount or type of in-kind support.
• Professional Practice Gap: The difference between actual and ideal performance and/or patient outcomes. When there is a difference between what the professional is doing or accomplishing compared to what is “achievable on the basis of current knowledge”, there is a professional practice gap.
• Standards for Integrity and Independence in Accredited Continuing Education: The ACCME’s standards to ensure independence in planning and implementing CME activities.