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Miller School of Medicine, University of Miami | |
| City: Miami | State: FL | |
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Commentary:The Miller School of Medicine at the University of Miami has strong, clearly organized policies on individual conflicts of interest. These policies could be made stronger with a complete ban on gifts, tighter restrictions on samples, and a stronger firewall between industry funding and on-site educational activities. This institution has not consented to allow portions of its policy to be cited for illustrative purposes. |
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| Gifts & Meals |  |
The School of Medicine's limits on meals may not significantly curb on-site or off-site (restaurant) meals. Provisions to be occasional, informational, and 'modest by local standards' are not significant disincentives for meals. |
| Consulting relationships |  |
Exemplary language. This policy requires a formal contract for all consulting relationships, including the nature of services to be rendered and the amount of compensation for those services, which must be reasonable. Importantly, all such arrangements must be approved by the department chair of the dean. |
| Industry-funded speaking relationships | |
Although this policy does not address long-term speaking relationships (in fact it expressly allows participation in speakers’ bureaus), it is otherwise very strong. The policy requires institutional review and endorsement of all contracts, and asserts that presentation content must be determined solely by the speaker. |
| Disclosure | |
Although it was not provided, the School of Medicine refers to a policy for general disclosure of all conflicts of interest or activities that could be perceived as conflicts of interest. There is no provision for public disclosure of these relationships, however. |
| Pharmaceutical samples | |
Samples are allowed, but must be requested formally by the practitioner interested in receiving them. The manufacturer is then issued a permit to distribute requested samples. This emphasis on practitioner initiative would seem to be a limiting factor on the presence of samples in the institution. The policy also states that in hospital settings, sample distribution occurs under the direction of School of Medicine pharmacies. |
| Purchasing & Formularies | |
A strong policy which requires employees to recuse themselves from purchasing decisions when either they or a close relation (family member, partner, close personal friend) have a financial interest in the business being considered. However, the policy does allow these same individuals to contribute to discussions surrounding the decision (without taking part in the actual vote), which risks undue influence on the outcome. |
| Site Access | |
Industry representatives are allowed on-site, but by appointment only and not in patient-care areas. |
| On-campus Education | |
The School of Medicine has taken an important first step in decoupling industry support from the individual recipients (facilitators, practitioners) but has not established a complete firewall, such as a central fund, to ensure all CME activities are spared undue industry influence. |
| Attendance at Industry-Sponsored Lectures & Meetings Off-Campus | |
The School of Medicine uses model language to prohibit industry support for off-site educational events and conferences, banning industry support (for travel, lodging and other expenses for non-speakers) both directly to the individual and via the conference sponsor. |
| Industry Support for Scholarships & Funds for Trainees | |
This policy regulates industry support for scholarships and trainees without inhibiting the opportunity for general educational support. Selection of recipients must be by the institution, and all funds must be given to the department, not directly to individuals. |
| Medical school curriculum |  |
The School of Medicine notes that curriculum development is in process. |
| Do the policies specify an oversight mechanism? |  |
Clear, model language is used to designate oversight, placing responsibility with department chairs. |
| Are there explicit sanctions for noncompliance? | |
Brief but clear hierarchical sanctions laid out for practitioners and staff who violate institutional policy including reprimands, salary fines, and termination. |
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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) |
