Apr 01, 2015
Continuing Professional Development
Conflict of Interest
This presentation has been developed by the COI Working Group to assist in the implementation of “Policy and Guidelines for Interactions between Schulich School of Medicine and Dentistry and Pharmaceutical, Biotech, Medical Device, Medical/Dental Supply, and Research Equipment Supplies Industry”
Version 4 revised May 28, 2012
Continuing Professional Development
Purpose of conflict of interest policy
• Ensure patients’ safety• Maintain the school’s reputation• Ensure the integrity of our educational
programs• Avoid litigation• Uphold professional reputation
Continuing Professional Development
What do you do?
• An equipment rep offers to take you out for lunch after a demonstration?
• A supplier wants to provide funds for an educational activity you are planning?
• You receive an invitation for an unaccredited dinner talk?
• You receive an offer for consulting?
Continuing Professional Development
Expectations
Faculty, students and staff must:- Avoid conflicts of interest- Avoid improper relationships - Avoid other interactions that may suggest the appearance of
• a conflict of interest, or• an improper relationship
Continuing Professional Development
Conflict of interest
• a divergence between an individual’s private interests and his or her general professional obligations such that an independent observer might reasonably question whether the individual’s professional actions or decision are determined by considerations of personal gain, financial or otherwise.
Continuing Professional Development
Statement of Policy
• Individuals must consciously and actively divorce clinical care decisions from actual/perceived benefits expected from industry.
• Unacceptable for patient care decisions to be influenced by the possibility of personal financial gain.
• Conflicts of interest must be addressed appropriately.
Continuing Professional Development
15 types of interactions
1. Gifts2. Pharmaceutical samples and medical/dental
supplies3. Site access by pharmaceutical representatives4. Site access by device manufacturers5. Continuing Professional Development6. Industry funding for educational programs7. Participation in industry-sponsored programs8. Scholarships and other educational funds
Continuing Professional Development
Types of interactions … continued
9. Food10.Professional Travel11.Ghostwriting12.Purchasing13.Consulting relationships14.Educational materials15.Philanthropic gifts
Continuing Professional Development
1. Gifts
• No personal gifts from industry
For purposes of this policy, “industry” defined as manufacturers or suppliers of:
• pharmaceuticals• biotechnology products• medical devices• dental supplies • research equipment
Continuing Professional Development
2. Pharmaceutical samples
• Don’t accept samples and supplies directly.• Samples should go directly to patients/test
subjects through a voucher system where available.
Continuing Professional Development
3. Site access by pharma/dental supply reps
• By appointment only• Away from patient-care
areas• Students must be
supervised
Continuing Professional Development
4. Site access by device manufacturers
• By appointment only• Away from patient-care
areas• Students must be
supervised
Continuing Professional Development
5. Continuing professional development
Industry may provide CPD funding to:• Schulich School of Medicine and Dentistry• To an individual Department or Division• To the CPD or CDE offices
NOT to individuals
Continuing Professional Development
6. Industry funding for educational programs
• Individuals may not accept or solicit funds for educational activities.
Continuing Professional Development
7. Participation in industry-sponsored programs
• Industry may sponsor journal clubs, according to guidelines
• Do not accept payment for attending an event.• Do not attend an un-accredited event which is
marketed as an accredited event • Do not participate in speakers bureaus
Continuing Professional Development
8. Industry-sponsored educational funds
Industry can make donations to:• The Schulich School of Medicine and Dentistry• An affiliated hospital• Western University
NOT to an individual
Continuing Professional Development
9. Food
• Do not accept free food• Industry can provide grants
to an organizing committee• Industry should not cater
events directly
Continuing Professional Development
10. Professional Travel
• Do not accept travel expenses for educational events
• Accept only work-based travel cost
Continuing Professional Development
11. Ghostwriting
• Maintain your authority as an author
• Do not put your name on ghostwritten material
Continuing Professional Development
12. Purchasing
• Disclose all relationships with industry
• Remove yourself from the decision-making process if there is a conflict of interest
Continuing Professional Development
13. Consulting relationships
• Discuss and disclose
Before signing a consulting agreement:
• Discuss it with dean, chair or administrator
• Ensure that it includes details on tasks and deliverables
• Ensure remuneration is reasonable
Continuing Professional Development
14. Educational materials
• Discuss and disclose• Begin by contacting your
division chair• Consider:
– If Western should be involved– How income would be
divided– If students can defend their
thesis
Continuing Professional Development
15. Philanthropic gifts
Donations welcome through:• Schulich School of Medicine
and Dentistry• Affiliated hospitals• Western University
NOT to individuals
Continuing Professional Development
Researchers must:
• Be free to disseminate results
• Be unbiased• Be clear about how (and
by whom) they are paid• Conduct research
ethically
Continuing Professional Development
Researchers must:
Be free to disseminate results- don’t limit your right to report
Be unbiased- don’t influence your participants
Be clear about how (and by whom) they are paid - responsible for tripartite agreement
Conducted ethically
Continuing Professional Development
Applying the guidelines
• When in affiliated institutions, abide by those guidelines
• Where none exist, abide by Schulich guidelines.
• Where two sets exist, abide by the more stringent of the two guidelines.
Continuing Professional Development
Enforcement
1. Counseling of the individual2. Written reprimand, entered into their record3. Banning the individual from any further outside
engagements for a period of time4. Requiring that the individual return any monies received
from the improper relationship with a third party in contravention of this policy
5. Requiring the individual to complete additional training on conflict of interest
6. Removing the individual from the supervision of trainees or students
7. Termination for cause
Continuing Professional Development
Reporting
• To your immediate supervisor• To department chair• To the dean
Continuing Professional Development
Discuss and disclose
• Discuss and potential conflict of interest situations with your department chair or dean.
• Disclose all relationships with industry on an annual basis.
Continuing Professional Development
Questions?