The Conseil Québécois de développement professionnel continu des médecins (The Quebec Council of continuing professional development of physicians) ("CQDPCM") has updated its code of ethics (PDF) which came into force on January 1, 2016 ("Code of Ethics").
There are substantial changes to the guiding principles and in particular those related to: (i) transparency; (ii) potential bias and conflicts of interest; and (iii) independence of resource persons (i.e. any person who is involved in a continuing professional development ("CPD") activity or program as an expert, lecturer, scientific or organizing committee member, facilitator, moderator or administrative staff member).
The Code of Ethics now provides that:
Organizers must implement transparent accounting procedures that allow all stakeholders to be informed of revenue sources and expenditure allocation.
This is of particular importance because all sources of financing activities and the allocation of expenditure must be approved by the organizers.
To further ensure transparency, a fully independent and autonomous scientific committee will now be responsible for determining the content, resource persons and teaching method that will be used for CPD activities, while maintaining interaction with the organizing committee.
Potential Bias and Conflict of Interest
According to the Code of Ethics, while some biases may be tolerated, others, such as commercial bias, e.g. when information presented is not well-balanced and may be misleading, has no place in CPD:
The organizer of a CPD activity must be aware of biases, both positive and negative, that resources persons, medical organizations and funding organizations that are involved in a CPD activity may have. He or she must also ensure that the CPD activity is well-balanced and not unduly influenced by these biases and is free from any inappropriate preferences.
To this end, the Code of Ethics provides that, where possible, activities should obtain grants from multiple funding organization.
Likewise, the CQDPCM's Code of Ethics aims to ensure that neither the organizers, resource persons or participants of a training activity place themselves in a real or potential conflict of interest situation.
Accordingly, all resource persons, organizers and members of the scientific committee must, from the outset of the activity, disclose any financial and organizational affiliation. The organizer or association must also establish how to manage mandatory disclosure of conflicts of interest.
Independence of Resource Persons
In addition, the Code of Ethics requires that resource persons should not be involved in any CPD activity that could threaten their independence, for example one that promotes a particular product or service.
To further ensure that resource persons are not subject to potential conflicts of interest, their fees must be paid by the CPD activity organizer and not an industry sponsor. This may, arguably be the most important change to the Code of Ethics.
In particular, all payments to resource persons - notably healthcare professionals - for learning activities, must be made via a third party and cannot be made directly by an industry sponsor. For example, the provisions related to funding provide that:
The organizers of CPD activities are responsible for the funding arrangements of these activities. Such arrangements must comply with the following:
- All contributions, including those from a commercial source, must be made in the form of an educational grant payable to the institution or health professional organization which is responsible for the activity.
- Resource persons must not accept any compensation from the funding organization.
Canada's research-based pharmaceutical companies ("Rx&D"), a regular member of the CQDPCM, does not endorse the new Code of Ethics. It remains to be seen what the real legal and practical impact of Rx&D not endorsing the Code will be.