Who exactly is considered to be in a position to control content, according to SCS 2.1?

Standard of Commercial Support 2.1 states that the provider is required to “demonstrate that anyone in a position to control the content of a CME activity has disclosed any relevant financial relationships with commercial interests to the provider”.  Any individual who has the opportunity to change the content, or affect it in any way, is considered to be “in control of content”.  These individuals include: planners, faculty, authors, committee members, content reviewers, editors and staff.  Frequently, providers end up in noncompliance because they collect disclosures from the faculty, but no other contributors.