|Harvard Medical School|
|City: Boston||State: MA|
Summary: Harvard Medical School submitted a mix of ongoing documents which greatly improved their overall score for 2011-2012. There are several model domains, including gifts, speaking, samples, purchasing, on-site education and industry sponsored scholarships. The institution has established oversight and sanctions for noncompliance. Consulting relationships could be stronger with the requirement of a written contract, in addition to the enacted pre-approval of consulting relationships. Overall, this is a strong model policy.
Demographics: The primary sites of student training are Beth Israel Deaconess Medical Center, Brigham and Women's Hospital, Children's Hospital Boston, and Massachusetts General Hospital. Policies for Brigham and Women's Hospital and Massachusetts General Hospital as well as Harvard Medical School were provided. Medical School policies apply to all students and faculty, regardless of their location.
Updates: This institution submitted updated policies to the 2012-3
This institution has not granted permission for the posting of their policies on this website for illustrative purposes.
This institution's evaluation was last updated: 4/9/2013.
|Gifts & Meals||The policy clearly bans the acceptance of gifts and on-site meals.|
|Consulting relationships||The policy requires pre-approval of consulting relationships from a department head, but does not require a written contract or a provision to ensure compensation is appropriate to the service. Financial compensation for consulting is limited to $10,000 per annum.|
|Industry-funded speaking relationships||The policy prohibits participation in industry "speaker's bureaus" and requires speakers to retain full control over the presentation.|
|Disclosure||Internal disclosure is required by all faculty, but the information is held confidentially and not released to the public.|
|Pharmaceutical samples||Physicians are prohibited from accepting samples, with the exception of an approved policy or program in approved locations.|
|Purchasing & Formularies||Committee members are required to disclose financial conflicts of interest and are prohibited from all committee decisions, including discussions and votes.|
|Industry Sales Representatives||The policy mandates an invitation from a faculty member for meeting with industry sales representatives.|
|On-campus Education||The policy mandates a central fund for industry contributions, with no control from industry.|
|Attendance at Industry-Sponsored Lectures & Meetings Off-Campus||The policy prohibits the receipt of payment of registration fees and travel, yet does not explicitly prohibit the payment or compensation of time for attending an industry sponsored off-site event.|
|Industry Support for Scholarships & Funds for Trainees||The policy prohibits industry from selecting the recipient of the industry sponsored funds.|
|Medical school curriculum||The training materials submitted demonstrate an understanding of financial conflicts of interest and the pharmaceutical industry.|
|Do the policies specify an oversight mechanism?||Oversight is specified in the policy.|
|Are there explicit sanctions for noncompliance?||Sanctions are referenced in the policy.|
|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)|