FAQs Regarding SOM Policies Supporting Professionalism and Education in Medicine Through Limitations on Gifts and Interactions with Industry
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Please return to this site regularly for updates and clarifications on these policies.
Policy Concerning Gifts to Individuals
Q: A device manufacturer has donated an anatomical teaching model for use in the clinic. May we accept and use it under the new policy?
A: Yes. This is not a gift to an individual. Be mindful of any commercial interest promotion (such as a corporate logo or promotional message) on the device, and use your judgment to determine whether it is appropriate for use.
Q. An industry publisher would like to donate books to our students. The same text is available for purchase in the bookstore. The text available for purchase and the text that the publisher wishes to donate are identical. May we accept these?
A. The Department may accept these texts as a gift to the Department and distribute them to students for their use. Students should not accept the gift of a textbook directly.
Q: Our fellowship program has a quarterly meeting for resident and fellow education that is held in an off-campus restaurant. The residents and fellows present cases and clinical vignettes. Company A has a representative attend this meeting and pay for the dinner. The faculty members present ensure that the discussion is balanced and that critical appraisal of any presentation occurs. May we continue to attend these evenings as we have been?
A: Not without making one important change. The new policy forbids having the industry representative pay directly for the meal. You may continue to host this event in its current format and to seek industry support for the catering in the form of an educational grant. If the faculty member course director has available funds and chooses to hold this meeting at an area restaurant they may do so. Please also see "Policy on Participation in Industry-Sponsored Programs" below.
Policy Concerning Pharmaceutical Samples
Questions to follow
Policy on Site Access by Pharmaceutical Representatives and Device Manufacturer Representatives
Questions to follow
Policy Concerning CME
Q: I am an expert on disease X and treatment Y and have been invited to give Grand Rounds at another medical school. They have offered me an honorarium of $500. I will write the talk. May I accept the honorarium?
A: Yes. You may accept the invitation and the honorarium as long as your Chair agrees to your time away to meet this professional commitment. If this is a CME-certified program you can be assured that the CME sponsor has taken steps to identify and disclose any potential conflicts of interests of planners or speakers to the audience, and has processes in place to manage any commercial support for the activity. The honorarium you indicate would be considered "fair market value" and is not at issue here.
Q: I have been invited to give Grand Rounds at a local hospital. They have offered me an honorarium of $1000. I will be giving a talk that I authored and have no industry relationships to disclose. Is that possible?
A: You may accept the invitation to speak and receive the honorarium, providing that your Chair approves of your plan to be away from any onsite responsibilities.
Policy on Participation in Industry-Sponsored Programs
Q: I have participated in a "Faculty Development" program and have learned how to teach other physicians about new treatments for X using a slide kit and other educational materials that they gave us at the program. The company will pay me $1500 per talk to give this lecture at Grand Rounds around the region. May I participate in this "Speaker's Bureau?"
A: No. If you have not developed the content you should not use slides that were prepared for you to give a talk that was written by another source. The honorarium amount would be considered "fair market value" and is not at issue here.
Q: I have been invited by Company X to serve on a panel to present and discuss my own research with colleagues. The Company has assured us that we (the panelists and moderator) are in charge of the evening's program. The audience will be researchers from industry and from medical schools. There is no meal associated with this activity. Any problem here?
A: This may be a permissible professional activity. You should present this to your Chair and discuss the details with him or her. I am concerned that the Industry sponsor has controlled the content by virtue of selecting the panelists, but it sounds as though you have control of your presentations and of the discussion. Since there is no CME sponsor oversight, the FDA will assume oversight of the program, and you must be careful to abide by their requirements and by applicable law. You did not mention honorarium. Be sure to review any agreement with your Chair. The amount of honorarium must be at "fair market value." Although dollar amounts vary considerably by specialty and region, this range might be $250 - $2500.
Q: I am attending my specialty society meeting next week and there is a satellite symposium that is described as "continuing education" for physicians in my specialty. It is not one of the sessions certified for CME, and it is sponsored by company X. Under our new policy, may I attend?
A: Faculty and students should not attend industry-sponsored non-CME symposia that are described as "continuing education" for physicians. If the activity is called "continuing education" and it is not certified for CME, the FDA considers this a promotional activity and will oversee it as such. A promotional event may be subject to unacceptable commercial influence which would undermine the integrity of the educational event. There may be well-planned industry-sponsored educational events that would be exceptions to this concern. If you believe that you have found one that you would like to attend, please discuss your participation with your Chair.
Policy on Industry-Sponsored Scholarships and Other Educational Funds for Trainees
Questions to follow
Policy on Ghostwriting
Q: A new journal has offered to create a monograph from my research, and would like to name me as the author even though most of the writing would be done by professional writers. They have offered me a sizeable honorarium which I would like to use for our fellows' educational fund. May I accept this offer?
A: No. You may not allow your name to be listed as an author unless you have participated substantially in the writing. You may only receive honoraria for work performed legitimately.
If you rethink the project and offer to take it on as a true author, you should seek permission from your Chair as you would any substantial external professional commitment. If you author the monograph and receive an honorarium that is "fair market value" for the time and complexity of the task, you are certainly free to donate this to your Departmental Fellow's fund, however you must report the honorarium as personal income and pay any applicable taxes.
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