Policy UCCOM-IIC, Frequently Asked Questions
Policy UCCOM-IIC, Frequently Asked Questions
Gifts, Meals, and Products
Q. Why preclude meals? Do they really affect patient care decisions?
A. Research suggests that even di mimimus gifts, such as pens, engender a sense of obligation on the part of the recipient. Moreover, research has shown that in cases where a doctor has a pen or pad advertising a particular product, that product gets prescribed more often (AMA Guidelines Regarding Industry Interactions; Drug Makers Pay for Lunch as They Pitch, New York Times, July 28, 2006). Thus it has been shown that such gifts, including meals provided by Pharma, can influence the decision-making process. Our goal is to provide our patients with the best, most objective care. This is why we have chosen to eliminate such incentives.
Q. In the past, one of our pharma reps provided lunch for our meetings. Is this still allowed under the new policy?
A. As discussed above the main thrust of our policy is to eliminate incentives from Pharma. These incentives include meals, and consequently no meals may be provided to any UC College of Medicine personnel, including all faculty, staff, students, residents, and fellows.
Q. I understand that we no longer allow pharmaceutical sponsors to purchase meals on campus, but what about using funds that are derived from industry for research and education?
A. The policy allows pharmaceutical, device, and biotech companies to fund departments or divisions or the CME office (although not to individual faculty members) in support of their educational activities and programs by means of an unrestricted grant (which does not involve a “quid pro quo”).
Q. Isn't there a big loophole in the policy if a company can support education to a department and the department can turn around and use that money for the same purpose?
A. It may seem that way, but there is no loophole. Let's look at the difference. Prior to implementing this policy industry reps provided meals for talks, may have directed the subject of the talk and the speaker, and were at the event with promotional materials. They may have discussed their products with participants. This essentially makes it a company marketing event.
Under the new policy, when educational events take place they are free of company intervention or direction. If food is provided it is provided by the department. And while the department may have received funds from a company that has products in that area, these funds are spent at the department's discretion. Most importantly, no one will feel any obligation to any company. With or without industry support and with or without food incentives, educational events will continue at UCCOM.
Q. Can an Industry representative take a doctor out to lunch or dinner for a business purpose?
A. No. The policy prohibits restaurant meals with industry reps because of the implied quid pro quo that is present in such situations. We suggest, instead, that industry reps be invited to meet with University of Cincinnati faculty or medical staff in accordance with the site access provisions of this policy. During these interactions, no gifts may be accepted by University of Cincinnati representatives, except as reasonable compensation for bone fide services offered.
Q. Does the policy affect free samples for needy patients?
A. Yes and no. Under certain circumstances, free samples may be important source of pharmaceuticals for needy patients. Therefore, they may be accepted by individual departments only in keeping with a department specific policy, which ensures the absence of inappropriate influence by industry in connection with such distribution.
Q. Are we allowed to accept free materials and practice models from an outside supplier for resident and student training?
A. No, because there is an implicit expectation that the University of Cincinnati would purchase these materials or practice models. Such purchasing decisions need to be evaluated on objective criteria and be free of even implied obligation.
Site Access by Sales and Marketing Representatives
Q. Under the policy are sales and marketing reps allowed on the UC or affiliated campuses?
A. Industry representatives other than service personnel are not permitted on the premises of the College of Medicine except for specific appointments with faculty or authorized staff members. Presence at all times must be approved. Approvals may be granted at the discretion of the faculty member or his/her division or department. The access rules of the policy do not apply to premises of our affiliates, which typically have their own policies governing site access by Industry representatives.
Continuing Medical Education
Q. Can pharmaceutical companies and device manufacturers continue to support our CME programs?
A. Commercial entities, such as pharmaceutical companies and device manufacturers may support CME activities as long as the support is given with the knowledge and permission of the CME Office and the CME activities are conducted in compliance with the American College on Continuing Medical Education (ACCME) Standards for Commercial Support and the other requirements of section VI(E) of the Policy.
Q. Can commercial supporters (ie., pharmaceutical companies and device manufacturers) pay the expenses of attendees at our CME events?
A. No. Commercial supporters are not permitted to pay (directly or indirectly) registration costs, travel, or other educational event-related expenses.
Q. If a potential speaker has a relationship with a commercial entity, are we permitted to use them as a speaker at our CME courses?
A. Disclosing a relationship with a commercial entity does not automatically exclude an individual from speaking at a CME event. However, if the potential speaker is planning to discuss therapies or therapeutic agents that may be related to the companies for which there is a relationship, the potential conflict of interest must be examined and managed. This typically means that the CME Office will direct a review of the content of the presentation to ensure that the presentation is evidence-based and does not present a biased view of products or therapies, in accordance with the ACCME Standards for Commercial Support.
Q. Can course directors include an honorarium or other reimbursement for the time it takes to organize a CME event?
A. Yes. The Policy permits reasonable compensation provided for bona fide services. When the CME event budget is developed, all costs associated with developing and implementing the event should be itemized. That includes the effort of course directors, coordinators, staff, and others who are devoting time to the event. These costs should be reasonable and verifiable. The University of Cincinnati CME Office can assist with all questions concerning CME events.
Industry Funding for Education
Q. I have been invited by a pharmaceutical company to give a talk to community physicians. Am I allowed to do this?
A. University policy allows faculty to consult and such talks would be considered consulting activities and are permissible. In instances in which UCCOM faculty and staff do participate in such talks, they should follow the guidelines below, which represent in part, section VI. E. 5., and VII A of the policy:
- Financial support by industry is fully disclosed by the meeting sponsor.
- The educational content promotes scientific and educational activities and discourse.
- The consulting does not interfere with nor is inconsistent with the performance of the individual’s university duties.
- Reporting of collateral employment shall be made in accordance with University Rule 30-21-02 and 30-21-03.
Q. Is it still allowable for our department to receive grants from industry for scholarships or other educational funds for students and trainees?
A. Yes. However, according to section VI. D. of the policy, industry support of students and trainees must be specifically for the purpose of education and must comply with all of the following provisions:
- The student or trainee to receive such support must not be selected by the industry providing the support.
- The funds are approved by the department, program, or division responsible for the student or trainee;
- The department, program or division has determined that the funded conference or program has educational merit; and
- The recipient is not subject to any implicit or explicit expectation of providing something in return for the support, i.e., a "quid pro quo."
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