entity in which they’re practicing. Pharmaceutical samples provided for research purposes must comply with this policy for gifts for research purposes.
C. Other gifts to UC CoM: Gifts not described above, such as support for non-CME educational events and cash donations, should be managed through the UC Foundation. Donors who want to give to the COM can work directly with the UC Foundation and the College of Medicine to discuss the various forms of which contributions are made.
2. MEALS
CoM personnel may not accept on-site meals or any other gifts of food for themselves or others if sponsored, catered, or provided directly by Industry unless such meals are explicitly permitted by this policy. Industry funding for meals or in-kind contributions of food or beverages may not be accepted by CoM personnel or for CoM meetings, retreats or social events without approval from the CoM Industry Interactions Committee. Meals related to investigator meetings where participation is necessary for the investigator and his or her study staff to receive the appropriate training and experience to conduct the study are permitted. CoM personnel who choose to accept meals during their outside professional activities must be cognizant of the UC research-related conflict of interest policies and procedures and, if appropriate, it is their responsibility to report the monetary value of meals funded by Industry via the OAR system. For licensed providers, the value of such meals may be reported under the Physician Payment Sunshine Act (http://www.cms.gov/regulations-and- guidance/legislation/national-physician-payment-transparency-program/index.html).
3. CONSULTING RELATIONSHIPS
CoM personnel may serve as consultants to industry; such relationships can lead to research, innovation and improvements in medical and surgical products, and can ultimately promote advances in patient care and in the research enterprise. Such consulting relationships must not: (a) interfere with University duties; (b) compromise professional ethics; (c) have elements that may be construed by the government as an illegal kickback (like an inappropriate Stark relationship); or (d) be used as a vehicle for direct payment to faculty aimed at convincing them to use an industry company’s products. Outside consulting relationships with industry paid directly to CoM personnel are permitted under the following conditions: A. The relationships must be disclosed via the OAR system prior to engaging in the outside activity; and approved by both the Department Chair and Dean; and B. Any outside activity must comply with UC CoM Conflict of Commitment policies. C. CoM personnel are advised that the relationship should be described in a formal written contract which documents the specific, legitimate tasks and deliverables, and that payments for services must be commensurate with the tasks performed considering the faculty member’s specialty, expertise, experience, and regional/national/international reputation. CoM personnel are responsible for ensuring their outside consulting activities comply with all applicable local, state, and federal
College of Medicine Operating Procedure/Guideline Industry Relationships, Page 6 of 12
Made with FlippingBook Online newsletter maker