Do we need to take stocks into account when reviewing someone's financial relationships?
Yes. Stock information will help you determine if an individual should be considered an "owner" of an ineligible company, and whether they can participate in your accredited CE activity. According to the ACCME:
- An individual that owns stock in a publicly traded ineligible company is NOT considered an owner.
- An individual that owns stock in a privately traded ineligible company IS considered an owner (but those who simply have stock options in the company are not).
If you determine that the individual is an owner, you must exclude him/her from participating in your accredited CE activity. There are three special (and rare) exceptions, which you can read about here.
Do I need to require financial documents like tax returns and bank statements when collecting faculty disclosure information?
Per Standard 3, ACCME requires that accredited providers identify, mitigate, and disclose relevant financial relationships--but it does not require you to dive into individual finances! When it comes to collecting information, be clear in your requirements for disclosure (all financial relationships with ineligible companies within the prior 24 months, in any amount, including the name of the ineligible company and the nature of the relationship) and vet responses for completeness. Some reported relationships might require due diligence/more review than others, but you are not required to go down a financial rabbit hole.
