The College has a complete ban on gifts, and exemplary language concerning on-site meals: "The direct provision of any meals, desserts, etc. by pharmaceutical/ industry representatives on [university] property is prohibited. This includes the provision of meals during any organized, scheduled educational activity (e.g., grand rounds, journal club, faculty development, etc.) or reception. Industry representatives who wish to provide support to the [university] may, however, do so in the form of an unrestricted educational grant to the [university].  Such grants are expended for food solely at the discretion of [university] departments/ divisions/ regional campuses/ residency programs."
 

This policy contains no specific requirements regarding approval or contracts for consulting relationships. Consultants must disclose their relationships before participating in decisions product/device decisions, but there is no further mention of such relationships.
 

The policy language on speaking relationships is ethically commendable, but may not be sufficiently rigorous in practice. Honoraria furnished by industry are prohibited when the recipient's status as College of Medicine personnel is acknowledged.  Such a provision provides an easy workaround for personnel to engage in speaking relationships without oversight or constraint, and therefore does not safeguard integrity of content or prevent participation in long-term engagements such as speakers bureaus.
 

Annual disclosure to Personnel office is mandated, but without stipulation for patient or public notification. 

This policy does not prohibit individuals with external financial relationships from participating in purchasing decisions concerning the company with which they are involved, but it does stipulate that committee heads must decide whether the conflicted individual must recuse her/himself from the decision.
 

This policy refers to detailing twice: first in the preamble of the policy, and then in a separate Site Access section which establishes a clear ban on industry sales representatives. 

Although the policy stipulates that scholarships for students must go to a central fund, no similar limit exists for general educational grants applicable faculty, staff and trainees. Thus, funds for on-site educational activities may not be adequately restricted.
 

This policy suffers from the same non-rigorous language as discussed under speaking relationships. The policy bans receipt of funds defraying costs of simply attending events, but allows the acceptance of industry honoraria, provided an individual's employment status is not acknowledged.
 

Grants may not be given directly to individuals, and all funds should be directed to the College of Medicine. This strong policy prevents "earmarking" and provides oversight.
 

An excellent policy. Along with providing guidelines, this policy states that seminars and faculty development sessions will cover:

• "How activities can influence judgment in prescribing decisions and research activities. How to manage encounters with Industry representatives.

• How to handle patient requests for medication, particularly regarding direct-to-consumer advertising of drugs.

• The purpose, development, and application of drug formularies and clinical guidelines and discussing such issues as branding, generic drugs, off-label use, and use of free samples."
 

The College of Medicine establishes clear responsibility for oversight: "administration, department heads, division heads, campus deans, program directors, etc. are responsible for compliance with this policy and for ensuring the personnel under their supervision understand and comply with this policy."