Identification and Mitigation of Relevant Financial Relationships of Planners, Presenters, and Others

STEP 1: Review collected information about financial relationships and exclude owners or employees of ineligible companies from participating as planners or presenters.

After collecting all financial relationships from prospective planners, presenters, and others, exclude any persons who are owners or employees of ineligible companies. Ineligible companies are those whose primary business is producing, marketing, selling, reselling, or distributing healthcare products used by or on patients. For information about exceptions to this exclusion, see

STEP 2: Determine relevant financial relationships

Review the information for all persons whom you did not exclude in Step 1 and determine whether each person’s financial relationships with ineligible companies are relevant to the content of the education you are planning. Financial relationships are relevant if the following three conditions are met for the prospective person who will control content of the education:
• A financial relationship, in any amount, exists between the person in control of content and an ineligible company.
• The financial relationship existed during the past 24 months.
• The content of the education is related to the products of an ineligible company with whom the person has a financial relationship.

STEP 3: Choose a mitigation strategy for each person who has a relevant financial relationship and implement that strategy before the person assumes their role.

Using the lists below, identify which mitigation strategy(ies) will be used for all persons with relevant financial relationships who control the educational content of the educational activity. You may select multiple strategies but be sure to use strategies appropriate to the role(s) that each person has. You can also identify your own strategies for mitigation.