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ForwardFrequently Asked Questions about Disclosure of Stocks and Investments
With the release of the new ACCME Standards for Integrity and Independence, new questions have arisen about the requirements for disclosure of stocks and investments in companies that are considered ineligible for ACCME accreditation. The following chart is intended to help clarify the different types of relationships. We used the ACCME Standards for Integrity and Independence and the ACCME FAQs as the basis for this chart.
Note: the definition of an ineligible company is those whose primary business is producing, marketing, selling, re-selling, or distributing healthcare products used by or on patients. This chart is only related to financial relationships with companies that meet this definition.
Note 2: Standard 3.1.b states, “Individual stocks and stock options should be disclosed; diversified mutual funds do not need to be disclosed.” According to the ACCME, the spirit behind this is based on the level of control individuals have in choosing which specific stocks are owned.
Type of Relationship with Ineligible Company | Details | Disclose or Not | Consider person “owner?” |
Stockholder of publicly traded ACCME-defined ineligible company | Direct ownership of stock | YES | NO |
Stockholder of shares in a pension fund | Does not control which individual stocks they own | NO | NO |
Stockholder of shares in a mutual fund | Does not control which individual stocks they own | NO | NO |
Stockholder of shares in a 401K | Does not control which individual stocks they own | NO | NO |
Stockholder of shares in a 401K* | *Individual has the ability to control which individual stocks they own | YES | NO |
Stockholder of publicly traded companies in an investment fund controlled by an advisor | Individual still has the potential to control which individual stocks they own | YES | NO |
Equity interest/ownership in a bio- tech start-up that has not entered regulatory phase | Still doing “bench science,” and not yet submitted IDE/IND | NO | NO |
Equity interest/ownership in bio- tech start-up that has entered regulatory phase | Company has entered clinical trials, submitted IDE/IND | YES | YES |
Stock options in bio-tech start-up that has entered regulatory phase | Stock options only | YES | NO |
Royalties for a patent | Recommend asking additional questions about their payments and relationship with the company | YES | NO |
This document was drafted by Erin Schwarz and the SAGES COI Committee Chairs (Dr. Caroline Reinke, Chair; Dr. Peter Denk, Co-Chair; Dr. Prashant Sinha, Co-Chair; Dr. Phil Shadduck, Mentor) April 2022.