Course Financial and In-Kind Support Disclosure (Required Practice 3.3)
What Must Be Disclosed
What: Learners must be informed of financial and in-kind support given to the Provider by other organizations (see 3.3f)
Who: ASHA Approved CE Provider
When: Prior to the beginning of the course
How: Options include disclosing the names of organizations that contributed financial or in-kind support in promotional materials, in materials distributed prior to the course, and at the beginning of a course. Remember to include organizations contributing things such as products, materials and equipment; volunteers; professional services; publicity; etc.
Required Practice 3.3
3.3 The Provider must manage and disclose all financial and in-kind support given by other organizations that is used to pay all or part of the costs of the CE course.
3.3.a The Provider must make all decisions regarding the allocation and disbursement of funds received from other organizations.
3.3.b The Provider must be able to produce accurate and detailed written documentation of:
- Names of organizations that provided financial and/or in-kind support,
- Dollar amount received from each organization,
- Monetary value and description of in-kind support received,
- How the money and in-kind support were used.
3.3.c As a condition of receiving financial and in-kind support, a Provider is not required to accept advice or services from contributing organizations concerning planners, instructional personnel, learners, course content, planning, implementation, or evaluation.
3.3.d If payment for planners and instructional personnel is involved, it must come directly from the Provider or cooperative party (or parties) involved in course content development, not from the other organization(s) providing financial or in-kind support for the CE course.
3.3.e 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.
3.3.f The names of other organizations contributing financial and in-kind support must be disclosed to learners prior to the beginning of the CE course.
Financial and In-Kind Support (Sponsorship) Disclosure
Sponsorship is when an entity/organization provides financial and/or in-kind support for an ASHA CE course/offering(s) but is not involved in the planning, delivery, or evaluation of the course. The organization providing sponsorship has no influence over the
content of the course.
Financial Support – Money given by another organization used to pay all or part of the costs of a CE course.
In-Kind Support – Support or contributions of things such as products, materials and equipment; volunteers; professional or other services; publicity; etc.; not money.
Frequently Asked Questions About Course Financial and In-Kind Support Disclosure
What is considered financial support of a course?
Financial support is money given by another entity, which the ASHA Approved CE Provider then uses to pay all or part of the costs of a CE course. The Provider might use the money to pay for meals or cover speaker fees or travel. The Provider must keep records of the organization providing the financial support, the dollar amount given, and how the Provider used the money. Don't forget to disclose the financial support to the learners prior to the course.
What is considered in-kind support of a course?
In-kind support consists of goods, services, and human resources given by another entity. Examples of in-kind gifts include:
- Goods—computers, software, furniture, and office equipment, food, supplies
- Services—meeting space, photocopy and mail services, and administrative support
- Human resources/expertise—course planning advice and marketing and website development. People resources are persons giving their time free of charge. Anyone who provides technical assistance or consultation is offering in-kind support.
The Provider must keep records of the entity or people providing the in-kind support and a description of the in-kind support received. Don't forget to disclose the in-kind support to the learners prior to the course.
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
Required Practice 3.3.a). 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, advertisements (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), 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). Financial contributions 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.