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Medical College of Wisconsin | |
| City: Milwaukee | State: WI | |
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Commentary:Most of the scorecard domains are addressed by Medical College of Wisconsin in a strong and straightforward way. Commendable policies developed over the past year include a new gifts ban and a prohibition of the direct receipt of samples by doctors as well as policies on attendance at off-site events. However some ambiguities remain, including regulation of speaking relationships, purchasing and formulary committees, and industry donations. Also, while there is a clear chain-of-command for dealing with conflicts as they arise, the Office of Compliance is not required to be highly active in seeking those conflicts out. In 2008 the policies of this institution were under review. Final policies provided for 2009 show broad improvements over draft policies submitted for provisional assessment. This institution moves from an in-process designation to a grade of B. This institution has not consented to allow portions of their policy be cited for illustrative purposes.
This institution's evaluation was last updated: 6/16/2009 |
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| Gifts & Meals |  |
According to the most recent policy, gifts, including all meals, textbooks, and equipment, may not be accepted at any time. Although the Code of Conduct does make an exception for gifts of nominal value, the newer and more stringent policy was assumed to have precedence. The Code of Conduct should be updated to reflect the new policy. |
| Consulting relationships |  |
The only restriction on consulting relationships is disclosure. Stronger policies would include institutional review and a requirement for formal contract. |
| Industry-funded speaking relationships |  |
Speaking relationships are not explicitly addressed anywhere in this policy. However, ‘de facto employment’ requires prior approval from the school and 'Covered Persons' at the school are required to receive fair market value for services rendered. |
| Disclosure | |
This policy requires annual internal disclosure of any potential conflicts of interest, as well as any outside activities that resulted in payment. However, conflicts of interest are not clearly defined in this policy. |
| Pharmaceutical samples | |
Samples cannot be accepted by physicians, under the gifts policy, but samples for use in clinics or clinical trials can be accepted by the Medical Director for distribution and use. |
| Purchasing & Formularies | |
Although this policy makes an effort to restrict conflicted individuals from making purchasing decisions at the school, there is no clear policy concerning P&T committees and it is unclear how the present policy would apply. |
| Industry Sales Representatives | |
Industry representatives are only permitted to meet with faculty in non-clinical areas by appointment. They must be supervised by the faculty member who scheduled their visit. |
| On-campus Education | |
Although all contributions must be made to the central CME office, this policy does not clearly prevent industry from earmarking where their donations go. |
| Attendance at Industry-Sponsored Lectures & Meetings Off-Campus | |
Travel cost payments are defined as gifts and banned |
| Industry Support for Scholarships & Funds for Trainees | |
Students, residents and post-doc fellows may receive industry funding, but the funds must go through the central department and may not be earmarked by industry. |
| Medical school curriculum | |
No policy, or policy not provided. |
| Do the policies specify an oversight mechanism? |  |
Although the Office of Compliance is responsible for oversight, it does not appear to be very active in seeking out conflicts. |
| Are there explicit sanctions for noncompliance? | |
There is a clear sanctions 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) |
