faq: aan disclosure management system
The AAN's Disclosure Management System serves as a centralized place for AAN members and nonmembers serving as leaders, faculty members, clinical practice guideline or quality measure developers, authors, consultants, and other positions of official AAN responsibility to disclose relationships with commercial interests, non-profit organizations, and government entities that may impact their AAN activities. Disclosure Forms are reviewed and managed in accordance with the AAN’s Relationships and Conflicts of Interest Policy.
September 11, 2020
Why does the AAN collect disclosure information?
As described in the Relationships and Conflicts of Interest Policy, the AAN takes management of conflicts of interest seriously. An individual has a conflict of interest in a situation where their professional responsibilities, such as patient welfare or their AAN role or service, are or may be compromised by the influence of financial gain or a relationship with another entity that confers personal benefit. Recognizing that it may be difficult to determine whether a relationship constitutes a conflict of interest for purposes of an AAN role, program, product or activity, the AAN requires comprehensive disclosure of relationships with certain entities (commercial interests, non-profit organizations, and government entities) in certain contexts (i.e., consultancies, research, leadership positions, etc.).
Why was this new Disclosure Management System developed?
The online portal will minimize the amount of times individuals need to complete a disclosure form for the Academy. For example, when a member is appointed to a committee they will be required complete the form, then when that member volunteers or interacts with the AAN in other capacities (e.g., submits an abstract, authors a guideline, or serves as CME faculty), the member is simply asked to confirm their disclosures in the system are current for that activity without having to complete a new form.
What has changed from previous iterations of AAN disclosure forms?
While formatting has changed to optimize ease of use, the content is primarily based on the existing disclosure form the AAN has used for board and committee membership, guideline development, and Neurology® since 2017. The most substantive change has been the addition of asking for a “Dollar Range” for several questions, for the two-year period in which the form applies. The 2019-2020 Industry Principles Task Force and the AAN Boards of Directors felt having at least general ranges (public databases like Open Payments track to the specific dollar amount) clarified the scope of disclosed relationships.
How do I enter a new, or update an existing, disclosure form?
Visit AAN.com/disclosures/portal and select “UPDATE MY DISCLOSURE.” There is no need to search for your name in the search fields.
What time period is relevant for the disclosure form (i.e., what’s the look-back period)?
The AAN requires disclosure of current relationships and those from the past two years regardless of whether the relationships are related to the topic of the AAN activity.
When does my disclosure form need to be updated?
Forms will be kept in the AAN's Disclosure Management System and must be updated annually or promptly whenever any of the answers provided are no longer correct, current, or complete.
How will my disclosure form be used by the AAN?
Your completed disclosure form will be available to members and nonmembers via the Disclosure Management System search feature. In addition, a summary "Publication Statement" is automatically generated from your responses and will be used in conjunction with the AAN activity you are participating in. The information made available on this member and public portal has been traditionally made available across the various AAN platforms and programs that require disclosure.
For Question 1, do I need to disclose my employer?
Question 1 is only seeking disclosure for employers who are “Commercial Interests” (e.g., pharmaceutical, medical device, and scientific product companies, manufacturers of health-related wearable products, group purchasing organizations, pharmacy benefit managers, contract research organizations, electronic health record companies, health care technology companies, and insurers) or “Non-Profit Organizations” (e.g., medical specialty societies like AAN). As defined in the disclosure form, Commercial Interests and Non-Profit Organizations do not include organizations that provide clinical services directly to patients or organizations whose primary mission is to educate health care professionals (e.g., academic medical centers or neurology practices).
Where are the definitions for the key terms used in the disclosure form (e.g., Commercial Interest, Personal Compensation, etc.)?
Definitions are available at the beginning of the form by clicking “+ Definitions (click to show).”
Is Question 7 asking for any Expert Witness work?
No, Question 7 is asking specifically for compensation received from a “Commercial Interest” for serving as an Expert Witness. Unless a person has been paid and retained on behalf of a Commercial Interest, the answer would be “No” to this question.