Conflict of Interest - Schulich School of Medicine & Dentistry

Report
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
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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?
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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
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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.
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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.
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15 types of interactions
1. Gifts
2. Pharmaceutical samples and medical/dental
supplies
3. Site access by pharmaceutical representatives
4. Site access by device manufacturers
5. Continuing Professional Development
6. Industry funding for educational programs
7. Participation in industry-sponsored programs
8. Scholarships and other educational funds
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Types of interactions … continued
9. Food
10.Professional Travel
11.Ghostwriting
12.Purchasing
13.Consulting relationships
14.Educational materials
15.Philanthropic gifts
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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
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2. Pharmaceutical samples
• Don’t accept samples and supplies directly.
• Samples should go directly to patients/test
subjects through a voucher system where
available.
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3. Site access by pharma/dental
supply reps
• By appointment only
• Away from patient-care
areas
• Students must be
supervised
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4. Site access by device manufacturers
• By appointment only
• Away from patient-care
areas
• Students must be
supervised
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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
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6. Industry funding for educational programs
• Individuals may not accept or solicit funds for
educational activities.
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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
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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
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9. Food
• Do not accept free food
• Industry can provide grants
to an organizing committee
• Industry should not cater
events directly
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10. Professional Travel
• Do not accept travel expenses for educational
events
• Accept only work-based travel cost
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11. Ghostwriting
• Maintain your authority
as an author
• Do not put your name
on ghostwritten
material
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12. Purchasing
• Disclose all
relationships with
industry
• Remove yourself from
the decision-making
process if there is a
conflict of interest
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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
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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
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15. Philanthropic gifts
Donations welcome through:
• Schulich School of Medicine
and Dentistry
• Affiliated hospitals
• Western University
NOT to individuals
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Researchers must:
• Be free to disseminate
results
• Be unbiased
• Be clear about how (and
by whom) they are paid
• Conduct research
ethically
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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
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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.
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Enforcement
1. Counseling of the individual
2. Written reprimand, entered into their record
3. Banning the individual from any further outside
engagements for a period of time
4. 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
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Reporting
• To your immediate supervisor
• To department chair
• To the dean
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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.
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Questions?

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