Policy on the separation of individuals who conduct marketing or promotional activities for commercial firms from those who participate in IAS–USA educational activities

The International AIDS Society–USA (IAS–USA) endeavors to provide independent, expert, certified continuing medical education (CME) and guidelines for health care practitioners involved in HIV and AIDS care. As part of this commitment, the IAS–USA will no longer allow medical professionals involved in commercial marketing efforts to contribute to IAS–USA educational and informational programs. The IAS–USA defines a promotional or marketing effort as any activity in which the commercial entity controls key elements, such as speaker or topic selection, that could be used to serve the entity’s commercial interests.

Under the new policy, individuals may not participate in IAS–USA programs for 12 months after taking part in a promotional or marketing effort sponsored by the pharmaceutical or medical device industry. Among the promotional and marketing efforts covered by the IAS–USA policy are:

• appearances or presentations at company-sponsored exhibit booths during professional events;
• lectures or appearances that are controlled and coordinated by commercial companies, including industry-sponsored “speakers’ bureaus”;
• advertising and marketing campaigns, including “advertorials”
  

This policy applies to IAS–USA participation as speakers, moderators, CME course co-chairs, authors, and members of the Board of Directors, program development committees, and guidelines panels.

This provision of IAS–USA policies erects another firewall between IAS–USA program activities and potential commercial influence. With this policy—one of the strictest of any CME provider—the IAS–USA reaffirms its commitment to ensuring independence, objectivity, and scientific rigor in its programs and publications.

In drafting the new policy, the IAS–USA recognizes the distinction between speaking activities that serve academic or informational purposes and “speakers’ bureau” activities that primarily serve commercial interests. By speakers’ bureau, the IAS–USA means a relationship in which a company controls elements such as speaker selection, topic choice, audience selection and recruitment, and content of presentation; and for which speaker honoraria, fees and/or costs are paid directly by the company or through an agent or individual acting on behalf of the company.

The IAS–USA recognizes that although the distinction between promotional and non-promotional events is well defined in the United States, particularly by Food and Drug Administration (FDA) laws and regulations, such rigorously defined distinctions do not necessarily exist outside of the United States. Moreover, local customs and perceptions of promotional versus independent activities vary outside the United States. In countries where there is no Accreditation Council for Continuing Medical Education (ACCME) structure or equivalent arbiter of the independence of educational content from the marketing objectives of commercial companies, individuals who participate in IAS–USA activities must agree not to accept direct payment from commercial companies for lectures or presentations, other educational events, or single-company satellite conferences. Any personal compensation (eg, honoraria or speaker fees) for participation in such events must be coordinated through an independent third party, such as the speaker’s academic or medical institution or a charity. Other clearly promotional activities are included in the policy as described above.

IAS–USA program staff will work with prospective program participants to determine whether they meet the new policy’s compliance criteria. Individuals who have had no association with an industry promotional or marketing effort in the previous 12 months are eligible to serve in IAS–USA programs, providing they also comply with existing IAS–USA policies on conflict of interest and disclosure. Individuals who are currently associated with an industry promotional or marketing effort will not be eligible to serve in IAS–USA programs until 12 months from the date their industry association ends. This policy does not exclude individuals who serve as consultants on company advisory boards, receive support to conduct scientific or clinical research, or participate in certified CME activities, with or without commercial support.

This policy went into effect on January 1, 2009. Individuals associated with promotional or marketing efforts who were confirmed for IAS–USA programs before this policy took effect were allowed to participate in IAS–USA programs through 2009 but will not be allowed to participate in 2010 or until they are 12 months beyond their last promotional or marketing activity.

The above-described provision expands an IAS–USA policy designed to ensure CME programming that is objective, balanced, scientifically rigorous, and free of commercial control. The IAS–USA ethics policy also requires that:

• Any IAS–USA program that receives commercial support must have support from several companies with competing products; these grants are pooled and used to support efforts as designated and controlled by the IAS–USA.
• Before medical professionals can create or present content for IAS–USA programs, they must disclose all relationships, financial or otherwise, with all commercial and other outside entities.
• If IAS–USA officials perceive a real or potential conflict of interest involving a CME program participant, that conflict will be resolved before the individual’s participation in program development or implementation can continue.
• The content and recommendations of all IAS–USA activities are subject to independent peer review.

Through its policies, the IAS–USA reinforces its commitment to standards that meet or exceed those set by others in the field, including the American Medical Association and the Accreditation Council for Continuing Medical Education. The IAS–USA will continue to re-evaluate its policies and programs to ensure that they uphold the organization’s mission:

To improve the treatment, care, and quality of life of persons with HIV and AIDS through balanced, relevant, innovative, and state-of-the-art education and information for practitioners who are actively involved in HIV and AIDS care.