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Harvard Medical School | |
| City: Boston | State: MA | |
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Commentary:In 2010, Harvard Medical School submitted recommendations made by its Conflict of Interest Committee in addition to pre-existing policies from both Harvard and it’s clinical affiliate hospitals. Harvard does not operate its own clinical facilities, and has many affiliate institutions, each of which has its own policies and practices. These new recommendations make strong strides towards limiting marketing influence and potential conflicts of interests at the medical school, in particular they help streamline and clarify Harvard’s policies, addressing a previous concern of AMSA that Harvard and its affiliate institutions complicated patchwork of rules could hinder their effectiveness to ameliorate conflicts of interest. Harvard joins other academic medical centers in creating a unifying set of policies which apply to all clinical settings in which faculty and students work and train. Other institutions would benefit from a similar approach.
All of the recommendations submitted to AMSA have been approved by Harvard’s Dean, some recommendations have already been implemented or have a clear timeline for implementation and these policies are included in the Harvard’s evaluation for the 2010 AMSA PharmFree Scorecard. Other recommendations are still undergoing an approval process and are not included in the 2010 scoring. However notes regarding the proposed recommendations are presented in each domain alongside the current grade.
The active 2010 recommendations increase Harvard’s scores in the domains of On-Campus Education and Scholarships. Full approval of the recommendations will increase scores in the domains of Gifts and Meals, Industry-Funded Speaking Relationships, Disclosure, Off-Campus Education, and Curriculum. Harvard’s overall evaluation for the 2010 AMSA PharmFree Scorecard remains a B.
This institution's evaluation was last updated: 12/14/2010 |
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| Gifts & Meals |  |
While this institution does not have its own comprehensive gifts policy, Partners HealthCare, which operates clinical sites for a large proportion of HMS faculty and trainees, bans gifts that do not serve patient care or educational purposes. All educational and patient care-related gifts must be approved by the Department Chief and must have a value less than $100. The 2010 recommendations are still awaiting full approval. They clearly prohibit the accptance of all gifts and on-site meals and would increase this domain score to a 3. |
| Consulting relationships | |
This institution has an extensive policy on external consulting that limits or bans many inappropriate types of relationships. Pre-approval of consulting agreements is required. |
| Industry-funded speaking relationships |  |
While HMS policies do not explicitly address "speaker's bureaus," Partners HealthCare's policy on external consulting requires pre-approval of speaking relationships in certain circumstances. Another clinical affiliate requires that lecture content not be subject to industry control. The 2010 recommendations include formalization of a speaking policy by the Medical School along with affiliate policies, require all speakers to be in complete control of presented material and in some situations require pre-approval of speaking arrangements. These changes, once fully approved, would increase this domain score to a 2. |
| Disclosure | |
The 2010 recommendations require all faculty to disclose all outside financial relationships at least annually which is an improvement over the past policy. Furthermore public disclosure is planned but not yet implemented, the initiation of public disclosure practices will increase the score for this domain to a 3. |
| Pharmaceutical samples | |
Partners HealthCare's drug samples policy only allows samples to be distributed directly to physicians in limited circumstances, as part of approved programs. |
| Purchasing & Formularies |  |
All Partners HealthCare formulary committees must at a minimum require members to disclose potential conflicts of interest and abstain from voting in situations in which they may have a conflict. |
| Industry Sales Representatives | |
Partners HealthCare policies restrict industry representative access to Partners HealthCare sites. Interactions are limited to pre-scheduled appointment times, and are only permitted in non-patient care areas. |
| On-campus Education | |
The approved 2010 recommendations requires all contributions from industry be contributed to a central fund and that industry shall have no control of the funds. |
| Attendance at Industry-Sponsored Lectures & Meetings Off-Campus | |
HMS policies do not directly address the issue of commercial support for off-site education in its policies. Affiliated clinical sites prevent direct compensation or reimbursement for attendance or related costs. The 2010 recommendations include the addition of a formal Medical School policy to the affiliate policies clearly prohibits the receipt of payment for attendance to off site events and prohibits any industry support for travel. These policies are currently in place for clinical faculty but not yet non-clinical faculty. Full implementation of prohibition of payment for attendance to offsite events will increase this domain score to a 3. |
| Industry Support for Scholarships & Funds for Trainees | |
The 2010 recommendation clearly prevents industry from choosing the recipient of scholarships. |
| Medical school curriculum | |
HMS provided information on sessions and courses that address conflicts of interest in medicine. The sessions that most directly address pharmaceutical marketing, however, do not appear to be part of required courses, suggesting that education on this issue has not been institutionalized. The 2010 recommendations include plans to advance a curriculum on conflict of interest however, the descriptions are unclear on how conflicts of interest due to industry marketing will be covered. |
| Do the policies specify an oversight mechanism? |  |
Oversight is deligated in the policy. |
| Are there explicit sanctions for noncompliance? | |
Sanctions are referenced in the policy. |
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 | Model 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) |
