| Gifts & Meals |
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"[Gifts] intended for personal benefit of Health professionals may not be offered or accepted." Infrequent gifts for patients, lacking substantial value, may also be accepted. |
| Consulting relationships |
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Exemplary language. This policy requires a formal contract for all consulting relationships, including the nature of services to be rendered and the amount of compensation for those services, which must be reasonable. Importantly, all such arrangements must be approved by the department chair or the dean. |
| Industry-funded speaking relationships |
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Although this policy does not address long-term speaking relationships (in fact it expressly allows participation in speakers’ bureaus), it is otherwise very strong. The policy requires institutional review and endorsement of all contracts, and asserts that presentation content must be determined solely by the speaker. |
| Disclosure |
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All outside professional activities disclosed by faculty are available on a publicly accessible website. |
| Pharmaceutical samples |
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"No samples of drugs, medical devices, or any other product" are permitted. |
| Purchasing & Formularies |
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A strong policy which requires employees to recuse themselves from purchasing decisions when either they or a close relation (family member, partner, close personal friend) have a financial interest in the business being considered. However, the policy does allow these same individuals to contribute to discussions surrounding the decision (without taking part in the actual vote), which risks undue influence on the outcome. |
| Industry Sales Representatives |
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"Industry representatives may interact with professionals in non-patient care areas by appointment only." |
| On-campus Education |
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The School of Medicine has taken an important first step in decoupling industry support from the individual recipients (facilitators, practitioners) but has not established a complete firewall, such as a central fund, to ensure all CME activities are spared undue industry influence. |
| Attendance at Industry-Sponsored Lectures & Meetings Off-Campus |
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The School of Medicine uses model language to prohibit industry support for off-site educational events and conferences, banning industry support (for travel, lodging and other expenses for non-speakers) both directly to the individual and via the conference sponsor. |
| Industry Support for Scholarships & Funds for Trainees |
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This policy regulates industry support for scholarships and trainees without inhibiting the opportunity for general educational support. Selection of recipients must be by the institution, and all funds must be given to the department, not directly to individuals. |
| Medical school curriculum |
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No curriculum supplied, noted that medical center states that conflict of interest policy is taught by the ethics department. |
| Do the policies specify an oversight mechanism? |
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Department chairs are responsible for enforcing policy. |
| Are there explicit sanctions for noncompliance? |
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Varied levels of sanctions were provided: Unintentional, Subsequent unintentional, and Additional intentional offenses. |
