|Medical College of Wisconsin|
|City: Milwaukee||State: WI|
Summary: Medical College of Wisconsin submitted policies after the submission deadline for the current cycle. The submitted policies include strong language in most domains evaluated, with model policies in the areas of on-site and off-site continuing medical education. Areas for improvement include setting explicit standards for consulting relationships, as well as providing clearer language on the area of purchasing and formularies. Further, policies submitted did not include information on curricula used to teach medical students about conflicts of interest.
Demographics: The major training sites for students are Froedtert Hospital, Children's Hospital of Wisconsin, and Clement J. Zablocki VA Medical Center. Submitted policies apply to all of these institutions.
* Please note that an evaluation of the Medical College of Wisconsin's policies was performed after the release of the 2011-12 Scorecard. The changes are noted below. These changes are unofficial, as they were not performed by our standard double-blinded process. The policies will be reviewed again by AMSA's typical processes in the fall of 2012.
Updates: This institution did not submit any new or additional policies for the 2012-13 AMSA PharmFree Scorecard.
This institution has not indicated consent to allow the public posting of their policies.
This institution's evaluation was last updated: 7/2/2012.
|Gifts & Meals||Meals are allowed only in ACCME-accredited programming. Otherwise, industry-provided food is not allowed in any location.|
|Consulting relationships||Consulting relationships require only reporting, not approval, unless they involve the use of institutional personnel or property. There is currently no requirement for written consulting contracts; nor is there guidance on the amount of payment given for consulting relative to services provided.|
|Industry-funded speaking relationships||Speaking arrangements must be compensated at "fair market value" and be disclosed. However, there is no explicit language about allowable frequency or duration of speaking relationships with industry groups.|
|Disclosure||While there is a process of annual reporting of conflicts of interest, the submitted policy does not include language on uniform public disclosure or disclosure to patients.|
|Pharmaceutical samples||Samples are to be given only to a Medical Director or delegate and further requires the cataloguing of dispensation of said samples for at least 6 months.|
|Purchasing & Formularies||The policy submitted applies to institutional faculty generally and is not specific to the purchasing decisions of medical practice. Generally, when contracts or leases involve the staff member, his/her immediate family, or an associated organization (defined as ownership or control personally or by immediate family member), staff members are required to report such conflicts of interest and receive prior approval before such agreements are made. The submitted policy, however, does not specify that staff with such conflicts of interest recuse themselves from such decisions. Staff are themselves banned from creating contracts with the institution when they are in a position to influence the institution's decision.|
|Industry Sales Representatives||Sales and marketing representatives are in most cases banned from clinical care areas and are allowed to enter non-clinical areas only by appointment. However, the policy allows appointments for not only on-site education but also for the evaluation of potential purchases.|
|On-campus Education||Industry funding for CME must be for events that meet ACCME standards and must be delivered to Divisions/Departments, not individuals, and further be approved by a central Corporate Compliance Office.|
|Attendance at Industry-Sponsored Lectures & Meetings Off-Campus||Attendance of industry-sponsored events must be ACCME accredited, without compensation for attendance, and without gifts. Industry funding of travel outside of reimbursement for contractual services and activities related to a current clinical trial is prohibited.|
|Industry Support for Scholarships & Funds for Trainees||Educational training grants must be unrestricted and approved by the Corporate Compliance Office. Educational funding by industry must be held by a central authority, awarded by a department or division of the institution, and be without any quid pro quo or direct benefit to the industry sponsor.|
|Medical school curriculum||The submitted policies do not detail any curricula on conflicts of interest for medical students.|
|Do the policies specify an oversight mechanism?||The institution has a centralized Corporate Compliance Office for relationships that require prior approval and also has a clear reporting policy for allowed activities.|
|Are there explicit sanctions for noncompliance?||The submitted policy specifies that failure to make complete disclosure may constitute grounds for termination or other penalties per the institutional faculty handbook|
|Good progress toward model policy|
|No policy, or policy unlikely to have a substantial effect on behavior|
|Did not report|
|Policy not relevant to this institution (e.g., does not make purchasing decisions)|