Ventura County Medical Center

VENTURA COUNTY MEDICAL CENTER SANTA PAULA HOSPITAL Associated with the UCLA School of Medicine ADMINISTRATIVE POLICY 1.6 PROCEDURE: PAGE 1 OF 2 VCMC COMMERCIAL SUPPORT POLICY

SUBJECT: PURPOSE OF DEPARTMENT

DEPARTMENT: OFFICE OF MEDICAL EDUCATION EFFECTIVE DATE: REVISION DATES: 12/5/2013 12/5/13 AFFECTS: ALL DEPARTMENTS

APPROVED BY: Cheryl Lambing, M.D., FAAFP, CME Director REVIEW DATES: Medical Director, Professional Education, Ventura County Health Care Agency

Renee Higgins, M.D. Chief Operations Officer, Ventura County Health Care Agency

Continuing Medical Education Committee Medical Staff, Staff and Members

PURPOSE AND BACKGROUND The Ventura County Medical Center (VCMC) is accredited by the Institute for Medical Quality (IMQ)/California Medical Association (CMA) to sponsor (designate credit) continuing medical education (CME) for physicians. The VCMC CME Committee is responsible for ensuring compliance with the ACCME Standards for Commercial Support SM.

APPROPRIATE USE OF COMMERCIAL SUPPORT Ventura County Health Care Agency (VCHCA)/Ventura County Medical Center (VCMC) CME Provider does not solicit, accept nor utilize commercial support for CME activities. VCHCA/VCMC CME Provider does not accept commercial interest advice or services for CME.

VCHCA/VCMC CME Provider does allow the Activity Medical Directors to invite speakers outside of the VCHCA Medical Staff to address a specific CME requested topic. VCMC CME Committee maintains control of the topic, objectives, Cultural and Linguistic Components and Disclosures/Conflicts of Interest. VCHCA CME Budget Allocation funds, paid directly by VCHCA, provide speaker honoraria and speaker expenses in accordance with our Honoraria/Reimbursement process documented in Administrative Policy 1.7.

Additionally, funds could be distributed by the Medical Staff should a particularly important topic or speaker be identified or requested by the CME Committee. These funds are not Commercial Support, as they represent Medical Staff Dues paid by all VCHCA/VCMC physicians every 2 years during reappointment and the funds would be provided to serve our target audience—the VCHCA Medical Staff.

All Learner expenditures are VCHCA CME Budget Allocation funds only. There is no commercial interest providing commercial support for any VCHCA/VCMC CME activity.

TERMS AND ACCOUNTABILITY FOR THE USE OF COMMERCIAL SUPPORT The following policy exists at the request of IMQ as VCHCA/VCMC does not accept commercial support:

When VCHCA/VCMC accepts Commercial Support for CME this policy will be applied.

1. The terms, conditions and purposes of the commercial support must be documented in a written and signed agreement between the commercial interest providing the commercial support and the CME Provider, VCHCA/VCMC, prior to the CME activity. Commercial support must be unconditional – the commercial interest will not influence or participate in the planning of or execution of the CME activity. The terms and conditions must state that VCHCA/VCMC will make all decisions regarding the disposition and disbursement of commercial support. The agreement will include Administrative Policy’s 1.6 and 1.7 to ensure knowledge of and agreement to by all signing parties. 2. The agreement must include VCHCA/VCMC even if the commercial support is given to the educational partner or joint sponsor of a CME activity. 3. The agreement must include detailed income and expenses. 4. Commercial support may not be used to pay for travel, lodging, honoraria or personal expenses for non- teachers or non-author participants (Learners) of a CME activity. Commercial support may be used by VCHCA to directly pay for travel, lodging, honoraria or personal expenses for CME activity speakers or individuals giving a presentation at a CME activity. Such expenses must follow our Honoraria/Reimbursement process as documented in Administrative Policy 1.7. 5. Social events, meals or snacks may not take precedence over CME activities. 6. Commercial exhibits may not be present, may not influence or interfere with a CME activity or be a provision of money provided for the activity. 7. Product promotion may not occur in the same place, space or time of the CME activity. 8. Slides/Handouts may not have messages for trade names or product groups.

Additionally, before VCHCA/VCMC may accept commercial support, the CME Committee will meet to discuss the details of the potential educational grant to determine the specific need and whether to proceed to a Letter of Agreement. The CME Committee will make a recommendation regarding any commercial support and it will be the decision of the VCMC CME Director on whether to proceed to a Letter of Agreement.

DEFINITIONS

Activity Medical Director: The Ventura County Medical Center faculty member in charge of planning, implementing and evaluating the CME activity and who is responsible for collaborating with VCMC CME Provider to ensure compliance.

Commercial Interest: Any entity producing, marketing, re-selling, or distributing health care goods or services consumed by, or used on, patients.

Commercial Support: Financial, or in-kind, contributions given by a commercial interest, which is used to pay all or part of the costs of a CME activity.

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. (Source: ACCME)

Faculty: An individual speaking at or giving a presentation at a CME activity.

Joint Sponsor: A non-ACCME accredited organization that plans and presents a CME activity in partnership with an ACCME-accredited organization.

Learner: An individual in attendance at a CME activity.