As you may know, more than a year ago the ACCME began requiring that “stock ownership” in privately held companies be mitigated differently than with publicly traded organizations. As such planners or faculty reporting that they own stock in any amount with a privately help Ineligible Company be treated as if  that person “owns” the company. This means that the person is not eligible to participate in CME/CE activities when the products relate to the presentation.

The ACCME has indicated that they intend to enforce this requirement despite the difficulties many providers are having making the determination and having to replace the planner or faculty. They have indicated that a few bad apples in the CE Community have been using the complexity of organizational structures to hide these relationships. This is important if you are jointly providing the activity with a non-accredited entity.

Be aware that developing procedures for making this determination is important. If you have questions or need assistance, don’t hesitate to contact Steve Passin, president, at passin@passinassociates.com.