Sample Disclosure Process

Step 1. Each course planner and instructor completes the Provider’s disclosure form.

Step 2. The Provider reviews the disclosure form, the learner outcomes, the individual’s biography or resume, and all other course-related materials.

• If any questions arise about the disclosure information submitted, the Provider engages with the planner or instructor to understand if any identified relationship influences the course content or design.
• The following resources may help with disclosure discussions:
  • Dealing With Conflicts of Interest (MindTools)
  • Guide to Assessment and Management of Competing Interests (Royal Australasian College of Physicians)
  • Principles for Identifying and Assessing Conflicts of Interest (National Library of Medicine)

Step 3. Based on the form review and subsequent discussions, the Provider determines:

• If the individual has relevant relationship(s) that may impact course content or design and if a resolution process is required (go to Resolution of Disclosed Relevant Relationships).
• If the individual has no relevant relationship to the course content or design—in which case, no resolution process is required (go to Disclosure to Learners).
• If the individual has disclosed relationships deemed not relevant to the course content or design—in which case, no resolution process is required (go to Disclosure to Learners).

Resolution of Disclosed Relevant Relationships

The following methods may be used to resolve identified relevant relationship(s) and enhance transparency:

• Determine that disclosing the relevant relationship(s) to learners is sufficient to minimize potential conflict of interest.
• Use a peer review process by which experts in that topic area review materials to ensure that the data support the conclusions before these materials are accepted for presentation or publication. If necessary, instructional personnel will be required to revise content based on recommendations from the peer review.
• Alter control over the course content by:
  • Changing the focus of the content so that it does not relate to the relevant relationship.
  • Changing the content/topic of the individual’s educational assignment so that it does not relate to the relevant relationship.
  • Limiting the individual’s content to a report without practice recommendations (e.g., if the individual was funded by a commercial company to perform research, then their presentation may be limited to research data and results).
  • Limiting the role of the individual to reporting practice recommendations based on formal structured review of the literature with the inclusion and exclusion criteria stated (evidence-based).
• Choose not to select the individual as a planner and/or instructor.

Disclosure to Learners (for Instructors only)

The process for creating and publicizing disclosures includes:

• Developing the disclosure statement with information from the disclosure form and discussions with the instructor.
• Sending the draft disclosure statement to the instructor for review and approval.
• Finalizing and providing disclosure statements to potential registrants on primary promotional materials.
• Ensuring that the disclosure statements are announced verbally and/or in writing at the start of the course.