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Johns Hopkins School of Medicine | |
| City: Baltimore | State: MD | |
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Commentary:This institution has a strong annual disclosure requirement, but its policies on gifts, consulting, and speaking are less stringent, as is its language on continuing medical education, site access, and scholarships. Curriculum and formulary, while addressed in the cover letter of the submission, seem to be missing from the policies themselves. This institution has not indicated consent to allow portions of their policy be cited for illustrative purposes. |
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| Gifts & Meals |  |
This policy limits gifts to those for direct patient use and/or educational benefit to the physician. Modest meals are allowed. |
| Consulting relationships | |
A written agreement for prior review by the School of Medicine is required for all ongoing external relationships. However, this COI policy does not require all consulting relationships to be established in a formal contract with the payer. |
| Industry-funded speaking relationships | |
Though isolated speaking engagements are exempt from prior institutional review, the clause requiring repetitive engagements to be disclosed would seem to exact some review and perhaps limit on long-term speaking relationships. |
| Disclosure | |
Clear annual and ongoing disclosure required of all faculty, staff, trainees, and students. |
| Pharmaceutical samples |  |
This School of Medicine's drug samples policy is merely procedural and would not curb the use of samples as a marketing tool at the institution. |
| Purchasing & Formularies | |
Disclosure required. Annual disclosure requirement would apply to those serving on P & T and other purchasing committees. |
| Site Access | |
This site access policy imposes some limits on detailers, who must have an appt. booked three days in advance of visiting the hospital. Despite this limit, this policy is weaker than many AMC site access policies because it permits detailers to access patient care areas of the hospital. |
| On-campus Education | |
Though adherence to ACCME standards for commercial support for some activities is indicated in cover letter, no correlating policy was provided. |
| Attendance at Industry-Sponsored Lectures & Meetings Off-Campus | |
As it stands, the policy does not seem to address off-site education. If gifting limits apply, this must be codified in the policy. |
| Industry Support for Scholarships & Funds for Trainees | |
The cover letter indicates that scholarships may have 'no quid pro quo," but no policy was provided to confirm this. |
| Medical school curriculum | |
Cover sheet indicates faculty must take an online COI course and a research ethics course, but this is not codified within provided policy. |
| Do the policies specify an oversight mechanism? |  |
This policy makes reference to oversight. |
| Are there explicit sanctions for noncompliance? | |
This policy makes reference to sanctions. |
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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) |
