Program Integrity Safeguards

The Massachusetts General Hospital (MGH) Psychiatry Academy (MGH-PA) is dedicated to development and delivery of the highest quality, independent and trust-worthy continuing medical education curriculum in the field. We welcome the financial support provided by companies in the pharmaceutical industry and the participation of faculty members who may be actively pursuing research programs sponsored by these companies or rendering consulting services to these companies. In order to assure the integrity, independence and non-biased nature of the MGH-PA curriculum as a whole and the content of each program in particular, we have developed and adhere to the following standards for (i) Disclosure, (ii) Oversight, (iii) Separation and (iv) Continuous Improvement:

  1. Disclosure.
    1. Each proposed MGH-PA faculty member must disclose to MGH-PA in advance of each program for the evaluation and oversight described below all potentially material financial and business connections to commercial interests relating to psychiatry diagnosis, treatment and research.
    2. If the MGH-PA review results in approval for such faculty member to teach an MGH-PA program, all such disclosures are in turn disclosed in program opening remarks, printed program materials, slides, the MGH-PA website and other enduring materials disseminated by MGH-PA.
    3. MGH-PA itself discloses the identity of every supporter of the MGH-PA curriculum.
  2. Oversight.
    1. MGH-PA program integrity is assured by close oversight by several advisory groups whose members are listed on www.mghcme.org. These panels include:
      1. An steering committee which includes the clinical program directors of the clinical programs located within the psychiatry department at MGH;
      2. A senior advisory board, which meets semiannually and includes hospital presidents and their designates;
      3. The Partners Healthcare System, Inc. Education Committee; and
      4. The Elsevier's Office of Continuing Medical Education, which provides accreditation oversight;
      5. An external, peer-review process, conducted by experts from institutions outside MGH or HMS.
    2. All faculty disclosures are reviewed and evaluated in detail personally by MGH-PA's accreditation personnel, content manager, associate director and program director, and are subject to the recommendations of several of the advisory groups.
    3. All proposed curriculum and specific program topics, as well as actual presentations and materials, are evaluated by, and subject to, the recommendations of certain of the advisory groups.
    4. All participants are asked to rate MGH-PA programming for both the appearance and reality of integrity and independence and the resulting reviews are provided to the advisory groups and used to change and enhance the MGH-PA approach from cycle to cycle.
  3. Separation.
    1. MGH-PA is structured to support both the reality and the appearance of independence from our providers of financial support, including by:
      1. Requiring supporters to provide financial support without input into topic selection or faculty and to co-support multiple CME events;
      2. Separating supporters from any opportunity for participation in any content development and faculty design or decisions;
      3. Limiting supporter presence at and in MGH-PA events and materials;
      4. Prohibiting any supporter advertising, display booths, sales or marketing staff, banners and similar branding materials in any MGH-PA activity including live, broadcast, satellite and web-based events and enduring materials other than a collective thank you to the panel of supporters by name; and
      5. Focusing not only on the independence and integrity of the MGH-PA educational programming but also on presenting a diversity of opinions by ensuring equitable presentation of alternative viewpoints and approaches.
    2. Because MGH itself is a healthcare provider in a position to recommend or purchase the goods or services offered by many of the MGH-PA supporters, MGH-PA has established a range of safeguards to insulate clinical decision-making from the financial support provided by these companies including:
      1. Requiring specific line-items budgets for each MGH-PA program cycle that strictly allocate funds from supporters to specific and relevant MGH and third party efforts to create, enhance and provide the MGH-PA curriculum;
      2. Ensuring these budgets and MGH-PA books and records are auditable by supporters and any funds not applied to the agreed MGH-PA activities are returned to supporters;
      3. Subjecting all budgets to review by several Advisory Groups;
      4. Administering all supporter funding through an independent third party, Reed Elsevier; and
      5. Barring from service on MGH formulary committees any MGH-PA faculty and MGH-PA administrative or operations personnel.
  4. Continuous Improvement.
    1. MGH-PA devotes significant resources to evaluation of the educational experience of participants, participant's feedback about the substance and the integrity of the program content and the recommendations of the Advisory Groups. Using an objective, data-driven iterative process, MGH-PA completes needs-assessments and gap analyses to identify areas that could be improved in the future.
    2. These evaluations drive a process of continuous modifications of and enhancements to the MGH approach to developing and providing educational programming.
    3. MGH-PA continually desires to enhance the safeguards applicable to MGH-PA, and this summary of our safeguards will be updated as these approaches evolve and change. For additional information, please visit our website at www.mghcme.org.