IFM Commercial Support Guidelines
As an organization accredited by the Accreditation Council for Continuing Medical Education (ACCME), The Institute For Functional Medicine (“IFM”) has developed the following commercial support guidelines. Please review the following guidelines, which ensure that educational activities are held without commercial influence and in full compliance with ACCME Standards for Integrity and Independence in Accredited Continuing Education.
Commercial Support Definitions
Commercial support is categorized as financial or in-kind (equipment, supplies, services, and so on) contributions provided by an ACCME-defined ineligible company.
Ineligible Company: Defined by the ACCME as “Ineligible Company those whose primary business is producing, marketing, selling, re-selling, or distributing healthcare products used by or on patients.”
Examples of such organizations include:
- Advertising, marketing, or communication firms whose clients are ineligible companies
- Bio-medical startups that have begun a governmental regulatory approval process
- Compounding pharmacies that manufacture proprietary compounds
- Device manufacturers or distributors
- Diagnostic labs that sell proprietary products
- Growers, distributors, manufacturers or sellers of medical foods and dietary supplements
- Manufacturers of health-related wearable products
- Pharmaceutical companies or distributors
- Pharmacy benefit managers
- Reagent manufacturers or sellers
Commercial supporter: An Ineligible Company that provides financial or in-kind support for an accredited continuing education (ACE) activity.
Commercial Support Types:
The two types of commercial support are:
- Financial support: A monetary donation used to pay for all or part of the costs of an ACE activity.
- In-kind support: Non-monetary contributions provided by an Ineligible Company in support of an ACE activity in one of the following categories:
- Equipment loan
- Disposable supplies (non-biological, such as instruments/materials)
Planning aN ACE Activity with Commercial Support
Requirements for Commercial Supporters:
Commercial supporters will not direct content nor influence the planning or implementation of educational activities.
Commercial supporters are not permitted to be involved in the following:
- Identification of practice gaps and needs that become the foundation for the activity.
- Preparation of or input into the learning objectives.
- Selection and/or presentation of content.
- Recommendation of individuals to assist who would be able to control the content of the activity (for example, planners, editorial committee, faculty, and so on).
- Influence over the selection of the educational design for the activity.
- Selection of vendors or methods for the evaluation of the activity.
- Requests for “technical review” of the content of the activity.
Applying for Commercial Support
For each company providing commercial support a Letter of Agreement for Commercial Support must be executed and sent to the SPI Philanthropic Service Specialist, Kristin Holschbach at email@example.com prior to the activity.
The IFM team must review all mailings/materials used to solicit commercial support from Ineligible Companies prior to distribution in order to ensure compliance with IFM and ACCME requirements.
Letter of Agreement
The Letter of Agreement template discussed in this section can be found here:
If a company agrees to provide commercial support for an ACE activity, a Letter of Agreement (“LOA”) for Commercial Support is required.
The IFM LOA template must be used, which includes the following components:
- Contact information of the commercial supporter.
- Name, date, and location (for live meetings only) of the ACE activity.
- Terms and conditions for compliance with ACCME Standards for Integrity and Independence in Accredited Continuing Education.
- Amount of monetary support and/or description/value of in-kind support.
- Signature of commercial company representative.
For Directly Sponsored activities, the commercial supporter representative must sign off prior to the IFM representative’s signature.
All LOAs must be signed by all parties and submitted to IFM at least five (5) days before the educational activity.