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. 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 Continuing Professional Development Types of interactions … continued 9. Food 10.Professional Travel 11.Ghostwriting 12.Purchasing 13.Consulting relationships 14.Educational materials 15.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 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 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?