Creative Therapy Consultants (CTC) is committed to ensure all CE courses are provided with evidence-based, relevant, up to date knowledge and skill development. Speakers are sought out by CTC who are experts in their topic, often having publishe or presented on a given topic. CTC is committed to ensuring there is no perceived or actual conflict and discloses to the learner any relevant information. Furthermore, all courses will be provided free from the appearance of or actual conflicts of interest (COI) and will not be influenced by other organizations through Sponsorship, In-Kind Support or Financial Support regarding the planning, delivery or evaluation of any courses. Any introduction/demonstration of any product or service will be provided without any bias in favor or against a product, service, or device, but instead presented as one of other options to meet a patient or family need. Creative Therapy Consultants has a process to ensure that any potential conflict will be identified openly so that the course participants may form their own judgments about the presentation with the full disclosure of facts.
The process for collecting all Speaker/Presenter information related to Relevant Financial Relationships, Non-Financial Relationships, Conflict of Interest, Copyright information, HIPPA, and Education Ownership is initiated in the early planning stages of continuing education prior to speaker recording or presentation. This information is submitted by all presenters, planners, or CE team via On-Line Speaker Agreement which states CTC policies and provides needed information for planning, preparing, disclosing, and evaluating continuing education. This information is then used to identify conflicts, mitigate and disclose conflicts, and assure compliance with all relevant policies and regulations.
Relevant Financial Relationships, Non-Financial Relationships, Conflict of Interest
Creative Therapy Consultants requires all team members and speakers to disclose any financial or non-financial interest in any company, product, instrument, device, service, or material which may be discussed during, planning, execution, or evaluation of continuing education. Likewise, the disclosures must be identified, documented and presented to the learner prior to initiation of the education and the disclosures must be reviewed/confirmed with each individual within 30 days of continuing education launch.
CTC does not view interest in or affiliation with any corporate organization as implying bias or decreasing the value of participation. In fact, having an interest in an organization does not prevent a speaker from making a presentation, but CTC requires that the audience be informed of this relationship, including any financial or non-financial interests, prior to the start of the activity and any potential conflict be resolved. All planners, faculty, and content specialists for Creative Therapy Consultants must be discloses to CTC and the audience any of the following:
- Relationship with companies who manufacture products or provide services used in the treatment of the subjects under discussion in the educational activity.
- Relationship between the planner, faculty or content specialist and commercial supporter(s) of the activity.
- Intent to discuss unlabeled uses of a commercial product, or an investigational use of a product not yet approved for this purpose.
All CTC Speakers and Team will be informed of this policy on the Creative Therapy Consultants Speaker Agreement and if questions, CTC staff is available to discuss. If a speaker refuses to complete required forms, the speaker will be removed from the education planning, execution, or evaluation.
Process for Disclosures & Conflicts
1.Collect information through On-Line Speaker Agreement:
During initial course planning, collect information from all speakers and planners, or others in control of educational content about all their financial and non-relationships with all companies within the prior 24 months. There is no minimum financial threshold; individuals must disclose all financial relationships, regardless of the amount, with companies. Individuals must disclose regardless of their view of the relevance of the relationship to the education. Disclosure information includes:
a. The name of the company with which the person has a financial or non-relationship.
b. The nature of the financial or non- financial relationship. Examples of financial relationships include employee, researcher, consultant,
advisor, speaker, independent contractor (including contracted research), royalties or patent beneficiary, executive role, and ownership
interest. Individual stocks and stock options should be disclosed; diversified mutual funds do not need to be disclosed. Research funding
from ineligible companies should be disclosed by the principal or named investigator even if that individual’s institution receives the
research grant and manages the funds. Examples of non-financial relationships may include boards, honorary member, consultant.
c. If any financial relationships changes, the speaker/planner acknowledges they will disclose to CTC via email such change. CTC will confirm
with speaker and planner 30days prior to a course going live that disclosures have not changed since disclosure.
2. Exclude owners or employees of ineligible companies:
Review the information about financial relationships to identify individuals who are owners or employees of ineligible companies. (Ineligible Company: Those whose primary business is producing, marketing, selling, re-selling, or distributing healthcare products used by or on patients. Each person with the ability to control content of the activity must disclose any relevant financial relationships with ineligible companies that have occurred in the last 24 months) These individuals must be excluded from controlling content or participating as planners or faculty in accredited education. There are three exceptions to this exclusion—employees of ineligible companies can participate as planners or faculty in these specific situations:
a. When the content of the activity is not related to the business lines or products of their employer/company.
b. When the content of the accredited activity is limited to basic science research, such as pre-clinical research and drug discovery, or the
methodologies of research, and they do not make care recommendations.
c. When they are participating as technicians to teach the safe and proper use of medical devices, and do not recommend whether or when a
device is used.
3. Identify relevant financial and non-financial relationships:
Review the information about financial or non-financial relationships to determine which relationships are relevant. Financial relationships are relevant if the educational content an individual can control is related to the business lines or products of the ineligible company.
4. Mitigate relevant financial and non-financial relationships:
Take steps to prevent all those with relevant financial relationships from inserting commercial bias into content.
a. Mitigate relationships prior to the individuals assuming their roles. Take steps appropriate to the role of the individual. For example,
steps for planners will likely be different than for speakers and would occur before planning begins.
b. Document the steps taken to mitigate relevant financial relationships and maintain these records for a minimum of 7 years.
c. Utilize CTC Mitigation Tool and Documentation.
5. Disclose all relevant financial and non-financial relationships to learners:
Disclosure to learners must include each of the following:
a. The names of the individuals with relevant financial or non- financial relationships.
b. The names of the ineligible companies with which they have relationships.
c. The nature of the relationships.
d. A statement that all relevant financial and non-financial relationships have been mitigated.
e. Upload disclosures HERE on CTC site.
6. Disclose Absence of all relevant financial and non-financial relationships:
These disclosures will be made readily available to the learner prior to their presentation either listed as a link on CTC webinar page (distance learning course) or as part of the presentation slides (live course).
a. Upload Absence of relevant financial and non-financial relationships HERE on CTC site.
All disclosures will be made readily available to the learner prior to their presentation either listed on CTC webinar page/slides (distance learning course) or as part of the presentation slides (live course) or discussion.
Tools and Documentation of Mitigation:
Course Sponsorship, In-Kind Support, Financial Support
Creative Therapy Consultants will consider, manage and disclose any financial support, in-kind support, or product support from other organizations with a clear message that no outside organization will have any input or services from them concerning course planning, implementation, or evaluation. Likewise, disclosures will be identified, documented and presented to the learner prior to initiation of the education and the disclosures must be reviewed/confirmed with everyone within 30 days of continuing education launch.