Welcome to the ASHA Continuing Education Board’s (CEB) webinar focused on Required Practice 3.2. In this module, we’ll take a closer look at what ASHA Approved CE Providers must do to manage conflicts of interest in courses offered for ASHA CEUs. This presentation is about 25 minutes long. 1
Requirement 3 is focused on transparency issues related to course planning, course delivery and marketing of courses offered for ASHA CEUs. The focus of Required Practice 3.2 outlines how the ASHA Approved CE Provider manages course planners’ and instructional personnel’s conflicts of interest. 2
Requirement #3 has 4 major components. Those components are (1) management of course content, (2) management of conflicts of interest, (3) management of financial and in ‐ kind support, and (4) management of exhibits and advertisements. This webinar focuses solely on Required Practice 3.2 which is about the management of conflicts of interest. You should read the entire requirement to become familiar with the other 3 components and consult the requirement as you implement your course planning, delivery and marketing efforts. Additional webinars are available that go into more detail about the other 3 components. Below this screen is a list of resources including a hyperlink to other webinars that you may want to access after viewing this webinar. 3
We all have a working definition of conflicts of interest but let me take a minute to go over how the CEB has defined conflicts of interest in CE courses. Conflicts of Interest in continuing education arise when financial and/or nonfinancial considerations or relationships, relevant to the course content, compromise or have the potential to compromise professional judgment. The key to defining conflicts of interest is those financial or nonfinancial relationships that are related to the course content you are developing or delivering. The CEB isn’t asking planners and instructional personnel to reveal all the details of their financial history; only those relationships that relate to the course content . 4
So after going over the conflicts of interest definition the next logical question is “When is a relationship relevant to course content?” Financial and nonfinancial relationships are relevant if they: Influence the information presented in the course, and/or Could be perceived as a conflict of interest by learners. I’ll define financial and nonfinancial relationships a little later in the webinar. 5
So we’re all on the same page, let me define the term instructional personnel. The CEB is using instructional personnel to encompass other terms like presenter, speaker, instructor, faculty, author, subject matter expert, curriculum developer and so on. We use the term instructional personnel because our ASHA CE Providers offer a wide variety of courses for ASHA CEUs. Many of them are live courses with instructors, presenters, speakers, facilitators. Other courses in the form of journal articles, newsletters or other types of enduring materials have instructional personnel that are called authors, subject matter experts, or curriculum developers. In order to include all these different terms used for individuals who develop and deliver learning, we are using the term instructional personnel. 6
The ASHA CEB has always had requirements around disclosure of conflicts of interest. However, Requirement 3 provides more guidance and definition around this issue. Requirement 3 stipulates that course planners as well as course instructional personnel must go through a process with the CE Provider to identify financial and nonfinancial relationships relevant to the course content they are involved in planning and/or delivering. The CEB understands that providers choose planners and instructional personnel BECAUSE of their expertise. Individuals with expertise often come with a portfolio of published materials, ownership of intellectual property, etc. They may also have appointments on boards or committees that are related to their area of expertise. Required practice 3.2 acknowledges the value of those relationships but at the same time seeks to ensure that the existence of those relationships are made known to the ASHA 7
Approved CE Provider and learners in a simple, straightforward manner. 7
You may be thinking wow! just a few slides into the webinar and there’s already a lot of definitions and details to remember…a mnemonic to the rescue! When managing conflicts of interest, remember CEU. ASHA Approved CE Providers are required to • Collect disclosure information, • Evaluate that information, and • Use the disclosure information when promoting courses and prior to the start of courses. 8
While the mnemonic device can help you focus on the 3 keys to managing conflicts of interest, let me take you through the specifics of Required Practice 3.2. This is a slide you’ll see 2 other times in this webinar as I take you through the specifics of collecting, evaluating and using disclosure information. 3.2 stipulates that the CE Provider must have a process in place to identify relevant financial and nonfinancial relationships of planners and instructional personnel. Second, that process must include how the provider will determine if the identified conflicts of interest can be handled through disclosure or disqualify planners or instructional personnel. And third, the provider’s process must include how instructional personnel disclosures will be made available in promotional materials and at the course. After viewing this webinar, you may want to click on the Conflict of 9
Interest Policy hyperlink below this screen for an example of a written process that addresses these 3 items. http://www.asha.org/uploadedFiles/CE ‐ Provider ‐ Conflict ‐ Policy.pdf 9
Let’s start with identifying relevant conflicts of interest. According to our mnemonic, this “C” stands for Collecting disclosure information. 10
Who must the Provider collect disclosure information from; course planners and instructional personnel. Each individual must provide disclosure to you, the Provider. If you are a CE Administrator and are involved in planning and delivering a course, you must also provide disclosure information. You want to make sure you have disclosure information before engaging an individual as a course planner or instructional personnel. Individuals who don’t provide disclosure information must be disqualified from being involved in the course. 11
You’re going to collect disclosure information from planners and instructional personnel before course planning begins. But you also need to communicate to planners and instructional personnel that they must let you know if any relevant relationship changes during planning. Specifically for instructional personnel, you’ll need to have a system set up where you ask them to review their disclosure information and update as needed after course planning has concluded but prior to the start of the course. 12
OK, so you know the who and when of collecting disclosure information but that begs the question what are planners and instructional personnel disclosing? Course planners and instructional personnel are required to disclose financial and nonfinancial relationships that relate to the content of the course they are planning or delivering. Earlier relevant to course content was defined as financial or nonfinancial relationships that could influence the information presented in the course, and/or be perceived as a conflict of interest by learners. Now, let’s talk about financial and nonfinancial relationships that could be related to course content. 13
What are relevant financial relationships? Relevant financial relationships are those relationships in which the planner or instructional personnel benefits by receiving a salary, royalty, intellectual property rights, gift, speaking fee, consulting fee, honoraria, ownership interest (e.g., stocks, stock options, or other ownership interest, excluding diversified mutual funds), or other financial benefit. Financial relationships can also include "contracted research" where an institution gets a grant and manages the funds and the planner or instructional personnel is the principal or named investigator on the grant. Remember, relevant financial relationships are those relationships that are relevant to the course content the planner or instructional personnel is involved in planning or delivering. 14
What are relevant nonfinancial relationships? Examples of relevant nonfinancial relationships are those relationships that might bias the planner or instructional personnel including any personal, professional, political, institutional, religious or other relationships. Again, a nonfinancial relationship is relevant if it pertains to the course content the individual is planning or delivering. After viewing this webinar, consider clicking on the Provider Frequently Asked Questions hyperlink found just below this screen for a more detailed explanation of financial and nonfinancial relationships. http://www.asha.org/CE/for ‐ providers/FAQs ‐ About ‐ Requirement ‐ 3 ‐ for ‐ CE ‐ Providers ‐‐ Instructional ‐ Personnel/ 15
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