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Oregon Health & Science University School of Medicine | |
| City: Portland | State: OR | |
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Links:
Commentary:Conflicts_of_Interest_10-01-020.doc 10-01-030.docx 10-01-025.pdf 10-01-020.docx Curriculum SampleMedsClin05-23.pdf Sales_Representative_policy.doc Policy_compliance01-01-005.docx OUTSIDE_ACTIVITY10-01-015.doc Institutional_Conflicts_of_Interest_10-01-021.doc 10-01-035.doc This institution has exemplary gifts and samples policies, as well as a strong annual disclosure policy that includes disclosure to patients in some cases. Prior review is also required for consulting relationships. While industry may not select the recipients of scholarships, there are weaker firewalls in place for industry support of on- and off-site education. This institution submitted revised policies for review in August of 2009. A subsequent reassessment improved their domain scores for gifts and meals, disclosure, and industry support for scholarships.
This institution's evaluation was last updated: 12/4/2009 |
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| Gifts & Meals |  |
Gifts (including food) to employees are generally prohibited. No employees in positions of authority (including all prescribers) may accept any gifts, and no employee, regardless of authority, may accept branded gifts. Exceptions include reimbursement for provided services such as presentations. |
| Consulting relationships |  |
Prior institutional approval is required, but no limits on payment are established, and explicit reference to the possibility of 'oral agreements' seems to rule out any requirement for a formal contract. |
| Industry-funded speaking relationships |  |
Speaking relationships are exempted from prior institutional approval. |
| Disclosure | |
Annual disclosure for all full- or part-time employees is required under policy no. 10-01-015 and policy no. 10-01-021 Conflicts of Interest and Commitment. This institution also requires review of financial relationships that may impact patient care. Commendably, review may require conflict management including disclosure to patients, corroboration of prescribing decision by a colleague, or transfer of patient care to another colleague. |
| Pharmaceutical samples | |
"…staff are prohibited from receiving and accepting supplies of sample medications from pharmaceutical representatives for redistribution or dispensing with the single exception of the Casey Eye Institute Ambulatory Surgery." |
| Purchasing & Formularies | |
Employees participating in purchasing decisions must disclose their significant financial interests annually; the purchasing committee or appropriate official will determine how conflicts should be managed. Recusal from decision-making is a management option, but is not necessarily required. |
| Industry Sales Representatives | |
Appointment required for all sales representatives on campus, but reps are allowed in some patient-care areas accompanied by a staff member of the institution. |
| On-campus Education | |
According to policy no 10-01-030, industry support for educational events may be accepted if the event is ACCME-compliant. It is not clear that educational grants may not be earmarked by industry for a specific department. |
| Attendance at Industry-Sponsored Lectures & Meetings Off-Campus | |
Policy 10-01-030 stipulates that personnel providing substantive contributions to an off-site event may only do so if attendees are not compensated solely for attendance. However it is not clear that OHSU personnel are prevented from accepting compensation for attendance at events where an OHSU member is not providing substantive contributions. Further, policy 10-01-025restricts the ability of personnel in positions of authority to accept payments for attendance at lectures, but it is not clear students are constrained in their ability to accept such payments. |
| Industry Support for Scholarships & Funds for Trainees | |
Policy 10-01-030 stipulates that industry scholarships may be accepted only if the institution selects the individual recipient(s) |
| Medical school curriculum | |
Coursework on pharmaceutical marketing and impact on the medical profession occurs in the second year. The goals of the course are to familiarize students with industry marketing strategies and prepare them for interaction with sales representatives. |
| Do the policies specify an oversight mechanism? |  |
Integrity office responsible for implementation and compliance. |
| Are there explicit sanctions for noncompliance? | |
Sanctions: "may result in loss of privileges, disciplinary actions, termination of relationship …” with the institution. |
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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) |
