| Gifts & Meals |
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This policy does allow gifting, but contains some of the strictest control of gifting we have seen. Gifts are capped at $50 max per year, and $20 max per instance. Still, a complete ban on gifting would seem to be a simpler and stronger policy choice. |
| Consulting relationships |
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The University requires strict review of all external relationships. A contract is not required, but a high level of detail is required in individual reporting for review. |
| Industry-funded speaking relationships |
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Stringent review (as above) is a substantial limit on speaking relationships. Speakers may only speak on areas of general expertise. Their presentation may not be more than 10% on their specific (government) research. Longevity of speaking relationships is not addressed in the policy, although stringent review may help to prevent participation in speakers’ bureaus. |
| Disclosure |
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This policy stipulates public disclosure for employees above a certain pay level, and private disclosure for those involved in procurement etc. However, there is no general disclosure provision. |
| Pharmaceutical samples |
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Military teaching hospitals may have samples policies, but USU itself does not dispense prescription drugs. |
| Purchasing & Formularies |
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Recusal is required for individuals in decision-making bodies when they have financial relationships with the entity under consideration. |
| Site Access |
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Vendor access policies are hospital-specific and not regulated by USU. However overarching policy does require vendors go through a contracting office to show their products. |
| On-campus Education |
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This policy seems to only address CME activity, rather than all on-site education. For CME, the policy says USU must be responsible for content and speaker selection. A stronger policy would ensure funds are anonymized and establish a process for content review to ensure independence. |
| Attendance at Industry-Sponsored Lectures & Meetings Off-Campus |
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Travel funds for off-site event attendance must be approved. Gifts for attendance are prohibited under gifts policy. |
| Industry Support for Scholarships & Funds for Trainees |
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Oversight of scholarship funds in place. |
| Medical school curriculum |
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It was unclear whether medical school curriculum covers explicitly pharmaceutical interactions with physicians and trainees. |
| Do the policies specify an oversight mechanism? |
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Significant oversight established in policies. |
| Are there explicit sanctions for noncompliance? |
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Well-delineated sanctions established in policies. |