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regarding industry relations at
Harvard Medical School

Harvard Medical School

City: Boston

State: MA

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Commentary:

In 2009, Harvard Medical School submitted its own policies and those of affiliated hospitals, including Partners Healthcare and Children’s Hospital, Boston. Harvard does not operate its own clinical facilities, and has many affiliate institutions, each of which has its own policies and practices. In scoring this institution — especially in the clinical domains — we took this structure into consideration. HMS addresses, on some level, most of the domains on which it was scored. A detailed system has been developed to disclose and address conflicts of interest due to external relationships.

While conflicts of interest are effectively addressed for most of the HMS faculty and students by affiliated institutions' policies, the complicated patchwork of rules may hinder their effectiveness to ameliorate conflicts of interest. As some other AMCs have done, HMS could implement its own strong policies to be applied to all clinical settings in which its faculty and students work and train.

This institution made a submission for the first time to the AMSA PharmFree Scorecard in 2009. Their grade improves from an F to a B. Harvard Medical School received an F in 2008 because it did not submit policies, and indicated that it did not have applicable policies.

This institution's evaluation was last updated: 6/16/2009

Gifts & Meals		While this institution does not have its own comprehensive gifts policy, Partners HealthCare, which operates clinical sites for a large proportion of HMS faculty and trainees, bans gifts that do not serve patient care or educational purposes. All educational and patient care-related gifts must be approved by the Department Chief and must have a value less than $100.
Consulting relationships		This institution has an extensive policy on external consulting that limits or bans many inappropriate types of relationships. Pre-approval of consulting agreements is required.
Industry-funded speaking relationships		While HMS policies do not explicitly address "speaker's bureaus," Partners HealthCare's policy on external consulting requires pre-approval of speaking relationships in certain circumstances. Another clinical affiliate requires that lecture content not be subject to industry control.
Disclosure		All HMS Faculty of Medicine are required to submit disclosure forms periodically, as well as when situations requiring disclosure arise.
Pharmaceutical samples		Partners HealthCare's drug samples policy only allows samples to be distributed directly to physicians in limited circumstances, as part of approved programs.
Purchasing & Formularies		All Partners HealthCare formulary committees must at a minimum require members to disclose potential conflicts of interest and abstain from voting in situations in which they may have a conflict.
Industry Sales Representatives		Partners HealthCare policies restrict industry representative access to Partners HealthCare sites. Interactions are limited to pre-scheduled appointment times, and are only permitted in non-patient care areas.
On-campus Education		HMS policies do not provide details on the management of education funding from outside sources, however they do address some strategies to handle conflicts of interest in CME, by providing examples from ACCME resources on the subject. This policy does not state that ACCME requirements apply to all (i.e. including non-accredited) educational events.
Attendance at Industry-Sponsored Lectures & Meetings Off-Campus		HMS policies do not directly address the issue of commercial support for off-site education in its policies. Affiliated clinical sites prevent direct compensation or reimbursement for attendance or related costs.
Industry Support for Scholarships & Funds for Trainees		HMS policies do not place explicit restrictions on scholarships or trainee funds. Affiliated clinical sites allow scholarships to trainees, but prevent "earmarking" the funds for individuals.
Medical school curriculum		HMS provided information on sessions and courses that address conflicts of interest in medicine. The sessions that most directly address pharmaceutical marketing, however, do not appear to be part of required courses, suggesting that education on this issue has not been institutionalized.
Do the policies specify an oversight mechanism?		HMS will create a Standing Committee on Conflicts of Interest and Commitment to assist with the implementation of conflict of interest policies and will be responsible for reviewing cases brought to the attention of the Office of the Dean.
Are there explicit sanctions for noncompliance?		The Standing Committee will have the opportunity to make recommendations for further action to the Office of the Dean in circumstances of noncompliance.


	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)