| Gifts & Meals |
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This policy contains no serious limits on gifts; the only gifts language is embedded in pharmaceutical vendor site access policy, and allows for explicitly promotional gifts ("even if labeled with the donor's name.") |
| Consulting relationships |
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Annual disclosure is required only of consulting relationships maintained by researchers/investigators. There is no institutional oversight of consulting relationships generally. |
| Industry-funded speaking relationships |
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No policy, or policy not provided. |
| Disclosure |
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No general disclosure; Only research applicants must annually file COI disclosure. Otherwise, disclosure is mandated only for P&T members and publications. |
| Pharmaceutical samples |
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The pharmacy director must approve cases in which samples can be used, and if pharmacy services are temporarily unavailable, no more than 48 hours worth of medication may be given. |
| Purchasing & Formularies |
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Annual disclosure for all P&T members will be vetted at each new drug request, and "any member of the P&T committee who receives funds from a pharmaceutical company agrees to abstain on any vote pertaining to formulary changes regarding that company's drugs." Additionally, conflicts will be announced during deliberation. |
| Site Access |
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Drug detailers are allowed on campus only by invitation and only in non-patient care areas. |
| On-campus Education |
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It was not clear whether this policy applies to educational activities outside the CME accreditation system. However, within it:
"…funds should be in the form of an educational grant made payable to [the institution's] Faculty Student Association CME" and "there will be no scripting, emphasis, or influence on content by the Grantor or its agents." |
| Attendance at Industry-Sponsored Lectures & Meetings Off-Campus |
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No policy, or policy not provided. |
| Industry Support for Scholarships & Funds for Trainees |
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No policy, or policy not provided. |
| Medical school curriculum |
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The Medical University included an example of a case study on COI from an ethics course, and indicated that the graduate medical education department was in the process of developing a more comprehensive curriculum "relating to drug development, marketing, and relationships with industry for use across programs in the institution." |
| Do the policies specify an oversight mechanism? |
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Only pharmaceutical vendors are subject to oversight and sanctions. |
| Are there explicit sanctions for noncompliance? |
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Only pharmaceutical vendors are subject to oversight and sanctions. |
