Yes! There is a difference, and they both are required.
Disclosure is a requirement in Criterion 7 for both standards (Standard 2 and Standard 6) of the ACCME Standards for Commercial Support: Standards to Ensure Independence in CME Activities (SCS).
The differences between the two types of disclosure are explained at ACCME.org:
SCS 2.1 requires that anyone who is in a position to control the content of an education activity disclose information to the accredited CME provider about relevant financial relationships that the individual and their spouse or partner have with ACCME-defined commercial interests. This information is used by the provider to meet the expectations of SCS 2.3 and SCS 6.
In SCS 6, disclosure is made by the accredited CME provider to learners prior to the beginning of an educational activity. This disclosure is part of CME’s accountability to the public – by providing participants of a CME activity with information that may inform their perspectives on the content of the educational activity. In order to be compliant with this expectation, providers need to communicate to the participants both those relevant financial relationships that they discovered in their process of complying with SCS 2.1 as well as the source of all financial support – both monetary and in-kind – given to the provider from commercial interests for the activity. In addition, this information must be conveyed prior to the start of the activity.
