| Gifts & Meals |
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This institution’s gifts policy is generally in line with PhRMA guidelines, with an additional $300 annual aggregate limit, which continues to allow for substantial gifting. |
| Consulting relationships |
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The institution goes to great lengths to ensure that all consulting arrangements of its employees are appropriate. Consulting arrangements must be reviewed by the Corporate Compliance Office prior to acceptance. In addition, the arrangements, including deliverables, must be described in a contract, and all remuneration must be based on fair market value for services provided. |
| Industry-funded speaking relationships |
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Excellent language: "Vendor relationships with physicians…where compensation is paid for marketing activities such as speaking…are suspect and payment may not be accepted as 'consulting' fees, even if the physicians is required to perform services…" |
| Disclosure |
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No annual or periodic disclosure is required. |
| Pharmaceutical samples |
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The institution does not allow samples at the campus hospital, but the policy language suggests that they are permitted at affiliated and off-site practices. |
| Purchasing & Formularies |
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If a committee member has an applicable relationship or conflict, he/she may not participate in decision-making processes. |
| Site Access |
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The institution requires industry representatives to have pre-scheduled appointments. In addition, it requires representatives to pay an annual fee for a campus identification badge that is required to be worn at all times on site. |
| On-campus Education |
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The restrictions that the institution has placed on industry funding of CME events do not address industry influence over speakers or educational content at such conferences, they only address the funding of speakers |
| Attendance at Industry-Sponsored Lectures & Meetings Off-Campus |
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The provided policy effectively prevents industry from funding individuals for travel to and registration at off-site educational conferences. The policy requires that industry support be directed to the conference sponsor in order to defray the costs for all |
| Industry Support for Scholarships & Funds for Trainees |
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Industry may make scholarships available for students and trainees, but the recipients must be selected by the institution. |
| Medical school curriculum |
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No policy or policy not provided |
| Do the policies specify an oversight mechanism? |
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The institution has designated responsibly for enforcement in its policies. |
| Are there explicit sanctions for noncompliance? |
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Sanctions referenced |