Potential Conflicts of Interest in the Planning of Continuing Education
As an approved sponsor of continuing education, the Division on Addiction and co-sponsor, Health Resources in Action, are committed to the identification and resolution of potential conflicts of interest in the planning, promotion, delivery, and evaluation of continuing education through the Massachusetts Technical Assistance Center for Problem Gambling Treatment (M-TAC) and Project Build-Up (PBU) programs. Consistent with concepts outlined in the American Psychological Association (APA) Ethical Principles of Psychologists and Code of Conduct, potential conflicts of interest occur when an individual assumes a professional role in the planning, promotion, delivery, or evaluation of continuing education where personal, professional, legal, financial, or other interests could reasonably be expected to impair their objectivity, competence, or effectiveness.
M-TAC and PBU programs are facilitated by staff at the Division on Addiction and Health Resources in Action. These programs are funded by the Massachusetts Department of Public Health, Office of Problem Gambling Services.
The Division on Addiction is a part of the Department of Psychiatry at the Cambridge Health Alliance, a Harvard Medical School teaching hospital. A full list of the Division on Addiction’s funding sources can be found here. Health Resources in Action is a non-profit consulting organization serving government, non-profits, philanthropy, and communities across the U.S. A full list of Health Resource in Action’s affiliations and fiscally sponsored programs can be found here.
Policy and Procedure Concerning Potential Conflicts of Interest
The Directors of the M-TAC/PBU project in conjunction with the Capacity Building Manager are responsible for identifying, declaring, and resolving any potential conflict of interest the Division on Addiction and co-sponsor, Health Resources in Action, or their contracted presenters, may have in offering any specific program of continuing education through the M-TAC/PBU programs. The Division on Addiction and co-sponsor, Health Resources in Action, require that their staff members who participate in the planning of continuing education through the M-TAC/PBU programs identify, at the start of each fiscal year, any potential conflict of interest they may have in the review, selection, development, delivery, or evaluation of those programs and disclose the conflict or recuse themselves from any decision-making concerning that program. Contracted presenters are required to disclose in writing to the Directors and Capacity Building Manager any relevant financial relationships that could significantly impact the training/course content, design, and evaluation at the time that they deliver their planned course content (i.e. slide sets). These disclosures will be kept on file until the end of the fiscal year. At least one Director or the Capacity Building Manager will review the disclosed financial relationships in relation to the planned course content to determine if a financial conflict of interest may be present. If a conflict has been identified, the Directors and Capacity Building Manager associated with the M-TAC/PBU programs will confer about the potential implications and consequences of this conflict and develop a management plan. In the event of a potential conflict of interest, the Capacity Building Manager will ensure that the presenter recuses themselves from the planning/facilitation process or removes the conflict.
If a presenter chooses to collaborate on another M-TAC/PBU project after the end of the fiscal year, they will be required to submit a new financial relationship disclosure. If a presenter chooses not to disclose their financial support or any relevant relationships that could be reasonably construed as a conflict of interest, or decides that they would not like this information shared with the public (see Potential Conflicts of Interest in the Delivery of Continuing Education section), the Directors and Capacity Building Manager will ask the presenter to recuse themselves from the development/delivery of the training/course.
Any information disclosed by a professional participating in the planning, delivery, and evaluation of M-TAC/PBU programs as required by this policy shall be used solely for the purpose administering this policy and remaining compliant with APA’s continuing education regulations. The Division on Addiction and co-sponsor, Health Resources in Action, have the right to use and share any information for the purpose of evaluating, auditing, resolving, and reporting conflict of interest issues.
If a significant conflict of interest was not disclosed prior to the development and delivery of a training/course, the Directors and Capacity Building Manager will implement and ongoingly monitor a management plan to determine if the content, design, or evaluation of the training was biased as a result of this conflict of interest.
Potential Conflicts of Interest in the Promotion of Continuing Education
When preparing promotional material for continuing education, the Division on Addiction and co-sponsor, Health Resources in Action, will include information concerning any financial support, including in-kind support, provided by another party. The Division on Addiction and co-sponsor, Health Resources in Action, will also inform potential participants of any potential conflicts of interest of an instructor. If there is no financial support or any potential conflict of interest or commercial support, the Division on Addiction and co-sponsor, Health Resources in Action, will ensure that is clearly stated in the promotional material. If information about financial support or any potential conflict of interest is not included in the promotional material prepared for continuing education, the Division on Addiction and co-sponsor, Health Resources in Action, will clearly indicate how a potential participant can secure that information.
Potential Conflicts of Interest in the Delivery of Continuing Education
The Division on Addiction and co-sponsor, Health Resources in Action, require that there is a process to clearly describe any financial support for a continuing education program at the time the continuing education program begins. Any other relationship that could be reasonably construed as a conflict of interest will also be disclosed, for each presenter. The Division on Addiction and co-sponsor, Health Resources in Action, require presenters to identify sources of funding for M-TAC/PBU projects in addition to any relevant financial relationships of presenters. This will be achieved by presenting a slide disclosing any sources of funding at the onset of each live training. Funding statements will also be included on all training registration pages and online course module pages. To remain transparent, the Division on Addiction and co-sponsor, Health Resources in Action, will require all presenters to provide a biography detailing their educational experience and background knowledge of the topic being presented. This information will be displayed on all training registration and online course module pages.
Grievance Procedure
The Division on Addiction and co-sponsor, Health Resources in Action, are fully committed to conducting all activities in strict conformance with the American Psychological Association’s Ethical Principles of Psychologists. The Division on Addiction and co-sponsor, Health Resources in Action, will comply with all legal and ethical responsibilities to be non-discriminatory in promotional activities, program content and in the treatment of program participants. The monitoring and assessment of compliance with these standards will be the responsibility of the subcontract PI, Dr. Heather Gray in consultation with the members of the continuing education committee made up of the M-TAC/PBU Directors and Capacity Building Manager.
While the Division on Addiction and co-sponsor, Health Resources in Action, go to great lengths to assure fair treatment for all participants and attempts to anticipate problems, there may be occasional issues which come to the attention of the program staff which require intervention and/or action on the part of the convention staff or an officer of the Division on Addiction. This procedural description serves as a guideline for handling such grievances.
Grievances can be submitted to the subcontract PI, Dr. Gray, via email at hgray@cha.harvard.edu or via phone at (617) 575-5612, and should include the following information:
- Contact name(s)*:
- Email(s):
- Telephone number(s):
- Address:
*Please ensure that an alternative name is listed if the contact person listed is also an instructor.
When a participant, either orally or in written format, files a grievance and expects action on the complaint, the following actions will be taken:
- If the grievance concerns a speaker, the content presented by the speaker, or the style of presentation, the individual filing the grievance will be asked to put his/her comments in written format. The subcontract PI, Dr. Gray, will then pass on the comments to the speaker, assuring the confidentiality of the grieved individual.
- If the grievance concerns a training, its content, level of presentation, or the facilities in which the workshop was offered, the Capacity Building Manager will mediate and will be the final arbitrator. If the participant requests action, the Capacity Building Manager will pass the comments to the training facilitator(s), assuring the confidentiality of the grieved individual.
- If the grievance concerns the Division on Addiction and co-sponsor, Health Resources in Action, CE program, in a specific regard, the subcontract PI, Dr. Gray, will attempt to arbitrate but will bring any unresolved disputes to the attention of the Massachusetts Department of Public Health, Office of Problem Gambling Services.
- The Division on Addiction and co-sponsor, Health Resources in Action, will notify participants if a live training is canceled or rescheduled at least 24 hours in advance of the scheduled training session via the email used to register for the training.
Payment to participate in live training and online courses are not required. Therefore, refunds in cases of non-attendance will not be issued.