UCDHS Vendor Relations Policy Development & Implementation Teresa Porter, CHC - Chief Compliance Officer David Levine, JD - Legal Counsel Allan Siefkin, MD - Chief Medical Officer Timothy Albertson, MD,MHP, PhD - Professor/Division Chief Garen Wintemute, MD,MHP – Professor, Emergency Medicine 1 Our Goals for Sharing Vendor Policy Development Vendor Policy Implementation Bumps in the Road Where we are today Best Practices – Campus Sharing & Q/A 2 Starting Points JAMA Article, P&T Committee (sub), Pharma Code Systemwide start Medical Staff, P&T - whose decision was it to extend the definition of “vendor” to include all, rather then just health care vendors. Policy Rollout Industry Relations Committee (IRC) development 3 UCDHS Vendor Relations Background on Development JAMA Article Pharma Code Dr. Wintemute’s interest/guts to move forward His foresight for soliciting Dr. Albertson for assistance as the Chair of the P&T Committee P&T appoints a sub-committee for recommendations 4 P&T Sub-Committee Important acknowledgement that ownership of the recommendations being made were done through a Medical Staff Committee Vendor relations would apply to “all” vendors, not only health care related Recognizing existing policies that covered COI, financial interest, preceptorships and manufacturer relations Appointment of Dr. Albertson to the newly formed UCOP committee to develop systemwide vendor policy 5 UCOP Vendor Committee Early draft of the UCOP policy was used to initiate the UCDHS Vendor Policy. P&T subcommittee recommendation to the Dean who codified the policy. Presentation to Governing Body UCDHS Vendor Relations Policy approved Recognition that the success of this policy would require transparency and buy-in from the bottom-up. 6 Policy Implementation Rollout CMO/CCO, Allan Siefkin, MD committed to education Peer Pressure – Evolutionary change from the bottom Transparency and light on the subject 7 Rollout CMO/CCO Plan Six months prior to policy implementation the campaign began Periodic Email Notifications Education Focus Groups - Medical Staff - Department Managers, Department CAO’s, Nursing - Individual Department Faculty/Resident Meetings - Marketing & Fundraising personnel - Early version of FAQ’s developed and distributed 8 Important Notes Transparency Peer pressure – Evolutionary change Concerns about implications for clinical research and the need to maintain industry relationships to further science and funding 9 System Developments/Components P&T Committee Products and Standardization Committee Value Analysis Committee Medical Staff Committee Collaborative committee with the hospital Emphasis on supply purchasing for the OR 10 Concerns about the Vendor Relations Policy from Faculty, Residents and Staff Food - need to budget or obtain unrestricted funds Samples – Most had been removed due to stricter Joint Commission requirements Additional need for samples imposed a need for policy requiring Pharmacy to receive and distribute Recognized Pharma Patient Assistance Programs No distribution to any individual 11 Supporting Mission Care – Research Important reminder for faculty related to: speakers’ bureaus compensation plan consulting/outside professional activities 12 Recognized Need Based on the number of questions to various sources throughout the institution Need to coordinate Need to provide direct source Establish formal committee to address questions about Vendor Policy implementation Ability for physicians to “plug-in” 13 Dean’s Recommendation Industry Relations o o o o o Committee Charge: This committee is advisory to the Vice Chancellor of Human Health Sciences and reports to the UCDHS Executive Compliance Committee to draft directives and review health system policy; provide resources and direction to faculty and administration; review annual faculty conflict of interest disclosure statements; review teaching, and professional service arrangements or proposals; and field questions and inquiries related to conflict of commitment, conflict of interest and vendor relations for faculty and staff. Conduct substantive review of issues presented. Recommend changes or restrictions in the project and/or recommend changes to manage, reduce or eliminate potential conflicts of interest. Recommendation whether the grant, contract, or gift should be accepted. The committee will meet monthly and may conduct business outside of regularly scheduled meetings when the Chair of the Committee deems necessary. 14 Best for Last - Interactive Sharing Open Sharing 15