FAQs About Requirement 3 for CE Providers: Course Financial and In-Kind Support Questions (Required Practice 3.3)
What can be done in the situation where Organization XYZ that is not the Provider wants to provide financial support to fund a course instructor's expenses, but Organization XYZ's policy stipulates that the financial support they provide must be paid directly to the instructor? Organization XYZ does not want to select the course instructor, just fund his or her expenses.
The Provider must make all decisions regarding the allocation and disbursement of funds received from other organizations (see ). The Provider must also manage the disbursement of the funds. Therefore, in this situation, it will not be possible for the other organization to provide financial support directly to the instructor.
An exception would be if the instructor is employed by Organization XYZ. The instructor's disclosure of relevant financial relationships and nonfinancial relationships or no relevant financial or nonfinancial relationships must be provided in promotional efforts and at the start of the course. The employer organization contributing financial support for the instructor(s) must be disclosed prior to and at the start of the CE course.
Can a course or training on the use of a medical device be provided in the facility or office space of the device manufacturer or the device manufacturer's representative?
Yes. The course or training can be provided in the facility or office space of the manufacturer or the manufacturer's representative. The use of such office space would be considered in-kind support and must be disclosed to learners prior to the beginning of the CE course. In addition, commercial influence (e.g., visual displays, exhibits, or promotional material) should not be evident in the space where the course takes place.
Can an organization other than the ASHA Approved CE Provider offer in-kind support such as lunch at a course?
Another organization may offer in-kind support, if the Provider manages the support and that support is disclosed to learners in promotional efforts. The Provider must make all decisions regarding the allocation of funds and in-kind support from another organization. Ultimately, the Provider decides whether to allow another organization's in-kind support of lunch at the course.
Can an ASHA Approved CE Provider pay for attendees' hotel accommodations?
Requirement 3.3.e states that "The Provider may use financial or in-kind support received from other organizations to pay for travel, lodging and other expenses for learners. The Provider must manage the disbursement of this assistance." Attendees who have conference-related expenses paid should be advised to review the ASHA Ethics guidance statement on Conflict of Interest (COI) to be certain they are not placed in a situation that might introduce bias or preferences that could interfere with clinical judgment or research interests.
What should be disclosed for instructional personnel when an ASHA Approved CE Provider conducts a cooperative CE course with an organization that is not an ASHA Approved CE Provider? If the non-Provider wishes to pay conference-related expenses for several course instructors who have financial and/or nonfinancial relationships with that organization, what must be disclosed, in terms of identifying the instructional personnel and disclosing their financial and nonfinancial relationships with the non-Provider as well as other organizations?
The ASHA Approved CE Provider must oversee the identification, resolution, and disclosure of relevant financial and nonfinancial relationships and work with the non-Provider co-op party to do this for all instructional personnel and planners. The process developed by the ASHA Approved CE Provider should be the process used with the Provider's CE courses as well as co-op courses.Keep in mind that the ASHA Approved CE Provider is responsible for all decisions regarding the allocation and disbursement of funds, even with cooperative courses. Therefore, if the non-Provider co-op party wishes to fund instructional personnel, that organization must discuss the plan with the Provider. The non-Provider as the co-op party can pay the speakers (see Requirement 3.3.d [PDF], page 27), but the ASHA Approved CE Provider needs to manage this arrangement and keep records of what is paid and to whom and oversee decisions about disbursement of the funds (see Requirement 3.3.a [PDF], page 27). Financial relationships need to be disclosed prior to the course with any other information related to the instructor's financial or nonfinancial relationships.
A course is planned and offered for ASHA CEUs by an ASHA Approved CE Provider that is also an organization that manufactures and sells a medical device. The instructor is an employee of the ASHA Approved CE Provider and the Provider pays for the instructor's lodging and travel expenses. What disclosure and recordkeeping requirements apply?
As with all Providers and all courses, the instructor's disclosure of relevant financial relationships and nonfinancial relationships or no relevant financial or non-financial relationships must be provided in promotional efforts and at the start of the course. In this instance, the instructor would disclose that he or she is employed by the Provider and that the Provider is paying travel expenses. Because the instructor works for the Provider, it is likely the instructor has a professional or personal bias toward the organization's medical devices. Therefore, a nonfinancial relationship exists and must be disclosed.
If another organization is contributing financial support, then the Provider must follow Requirement 3.3 for recordkeeping purposes.