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Columbia University College of Physicians and Surgeons | |
| City: New York | State: NY | |
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Commentary:Generally strong policies are in place at Columbia University College of Physicians and Surgeons. Particularly noteworthy is the College's watchful control of distributed drugs, via both a rigorous ban on samples, and the recusal of individuals with conflicts of interest from purchasing and formulary decisions. Areas that could be strengthened include the gifts policy, which does not currently seem to apply to faculty, and institutional oversight of consulting and speaking relationships. The College is in the process of developing policies governing attendance at off-site educational events, and the receipt of scholarships and funds for trainees.
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| Gifts & Meals |  |
The College bans gifts, including promotional items, and meals not delivered through an unrestricted educational grant. However, this policy, which focuses on the conduct of medical sales representatives, does not seem to include faculty in its restrictions. |
| Consulting relationships |  |
Consulting relationships require prior disclosure, but are not subject to prior approval and this policy’s limit of one-day-a-week is not meaningful insurance of appropriateness or commensurate compensation. |
| Industry-funded speaking relationships | |
A one-in-seven-day limit and prior disclosure are required for speaking relationships. |
| Disclosure | |
Internal disclosure is required. |
| Pharmaceutical samples |  |
The College has implemeneted an excellent, clear ban of all drug samples, and made explicit reference to accountability. |
| Purchasing & Formularies | |
The participation of individuals with financial conflicts in purchasing and formulary decisions is defined as not normally allowable. Neither disclosure nor permission are cited as the mechanism to make this allowable; therefore, we read this as a complete ban of individuals with financial conflicts from purchasing and formulary deliberations. |
| Site Access | |
Medical Sales Representatives are required to have appointments, are not allowed in patient care areas, and are prohibited from meeting with students and staff (although not faculty), which establishes good limits on a sales rep’s territory while visiting the medical center. |
| On-campus Education | |
Checks and unrestricted educational funds must go to the University or Hospital. Industry may not stipulate the content of the educational event. |
| Attendance at Industry-Sponsored Lectures & Meetings Off-Campus | |
The College has indicated that it is creating new policies to address off-site education. Based on other aspects of the policy, we expect these guidelines will be strong. |
| Industry Support for Scholarships & Funds for Trainees | |
The College has indicated that it is creating new policies to address industry support of scholarships and trainee funds. Based on other aspects of the policy, we expect these guidelines will be strong. |
| Medical school curriculum | |
No policy, or policy not provided. |
| Do the policies specify an oversight mechanism? |  |
The Joint Standing Committee on Conflict of Interest is given oversight/authority to uphold policies by Dean of Faculty of Medicine and by the Chief Medical Officer. |
| Are there explicit sanctions for noncompliance? | |
This policy references sanctions for non-compliance. |
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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) |
