|Northwestern University Feinberg School of Medicine|
|City: Chicago||State: IL|
Summary: The institution provides a policy with strengths and weaknesses. One highlight is the prohibition of the solicitation and acceptance of gifts. However, meals are permitted as part of a conference or event. Payments for outside employment must be of fair market value. Presentation content and format must abide by FDA regulations. Funds for educational purposes and the selection of participants for off-site events are managed internally. Sanctions and oversight are outlined.
Demographics: On average students spend 70% of their training at Northwestern Memorial Hospital, 12% at Jesse Brown VA Medical Center, and 10% at Children's Memorial Hospital. Submitted policies apply to all Feinberg School of Medicine faculty and students/trainees who are obligated to follow policies at all affiliated institutions. Additional policies governing pharmaceutical samples, as well as formulary and medical device evaluating and purchasing decisions, were submitted and are maintained by affiliate institutions (Northwestern Memorial Hospital, Northwestern Medical Faculty Foundation, Children's Memorial Hospital, and The Rehabilitation Institute of Chicago).
Updates: Northwestern has requested a reevaluation of their score after the release of the 2012-3 AMSA PharmFree Scorecard. An review was performed and as a result there were increases in the Industry-Funded speaking arrangements, Purchasing & Forumularies, and Curriculum domains. They overall grade remains a B.
This institution's evaluation was last updated: 4/9/2013.
|Gifts & Meals||Employees are not permitted to solicit or accept gifts. Meals are only permissible if provided as part of a conference or event.|
|Consulting relationships||Faculty are required to report COI and COC annually. All outside employment must be according to fair market value and requests must be put forward in writing.|
|Industry-funded speaking relationships||This institution permits faculty participation in speakers bureaus, but strongly discourages it. They require fair compensation and speaker control of content. There are no limits in place regarding long-term speaking relationships.|
An exemplary disclosure policy. All faculty must disclose all income from the pharmaceutical industry, both on an annual and per-transaction basis. There is no de minimus threshold for disclosure, and all disclosures are posted on a public website and updated regularly.
|Pharmaceutical samples||The policy ensures good records are kept of samples received and dispensed but will in no way prevent the occurrence of any conflicts of interest that may arise.|
|Purchasing & Formularies||Members of the P&T committee are required to submit a special conflict of interest disclosure annually, that must be updated if there are any material changes. This statement is available to other members of the committee upon request. Members with conflicts of interest are required to recuse themselves from voting on drugs/devices where they have a conflict. They are permitted to participate in discussions.|
|Industry Sales Representatives||Access by vendor representatives is restricted to non-patient care areas and should take place only by appointment.|
|On-campus Education||Contributions for educational events are made to the Corporation. The policy does not clearly state that funds must be utilized independent of industry control.|
|Attendance at Industry-Sponsored Lectures & Meetings Off-Campus||If the individual's role at a conference/meeting is solely as an attendee or key opinion leader, he/she may not accept either honoraria or reimbursement for travel, lodging and meal expenses.|
|Industry Support for Scholarships & Funds for Trainees||Offers of scholarships and fellowships from industry must be submitted to the office of the Vice Dean of Regulatory Affairs for prior approval. Selection of recipients is the responsibility of relevant departments.|
|Medical school curriculum||The training PDF submitted addresses many issues regarding marketing and financial COIs.|
|Do the policies specify an oversight mechanism?||The department chairs, deans, center directors are responsible for ensuring compliance with policy requirements.|
|Are there explicit sanctions for noncompliance?||Disciplinary policies and procedures are outlined in the 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)|