New conflict of interest policy goes live July 1
On July 1, a comprehensive conflict of interest (COI) policy goes into effect for everyone at Vanderbilt Medical Center.
After a development process involving stakeholders from across the Medical Center, the policy was approved last September, and an implementation team was assembled to oversee its rollout.
To see details of the policy and other important information, go to www.mc.vanderbilt.edu/compliance.
The Medical Center policy was developed in concert with revisions to the overarching Vanderbilt University COI policy to assure consistency. These policies were reviewed by the Audit Committee of the Vanderbilt Board of Trust at its meeting earlier this month. Once implemented, the policy will apply to staff, faculty and students within the Medical Center.
“This new policy assures we are at the forefront of academic medical centers across the country in protecting the best interests of our patients, students, faculty and staff,” said Jeff Balser, M.D., Ph.D.,vice chancellor for Health Affairs and dean of the School of Medicine.
Balser recently served as a co-chair of the American Association of Medical Colleges task force that evaluated and made new recommendations for industry interactions with academic medical centers.
“Much of this is common sense if one thinks about it, but our culture has been less explicit on these issues, largely because of our community's strong traditions of trust, integrity and service to patients and students,” said David Raiford, M.D., associate vice Chancellor for Health Affairs and Chief Compliance Officer of VMC. “While one can't legislate ethical behavior, we wish to provide a roadmap to enhance awareness and guide Vanderbilt personnel as they pursue their missions while minimizing the perception or presence of conflicts of interest.”
Spurred by national questions about links between large biomedical/pharmaceutical companies and medical providers, and the potential of state and federal legislation on the matter, Vanderbilt decided to take a forward-thinking approach. The revised COI policy is intended to promote continuation of mutually beneficial partnerships between VMC and the health care industry while promoting patient, student, and public confidence in Vanderbilt.
Over the past two years, senior Medical Center leadership reviewed pertinent federal guidelines, requirements of accrediting organizations, and regulations governing the relationship between VMC and the National Institutes of Health, Medicare and other important external entities. Several peer academic medical center policies were reviewed as well.
Key features of the new policy include:
• VMC personnel cannot accept personal gifts of any value from health care industry representatives. The health care industry includes any pharmaceutical or medical device company and medical supply vendors and their agents, including — but not restricted to — current Vanderbilt vendors. To see the current list of vendors, go to www.vanderbilt.edu/compliance.
• Display or use of industry-provided promotional items on campus is prohibited, with specific exceptions (see policy for details).
• VMC personnel may not accept compensation of any sort, including a meal, whether on or off campus, for attending marketing-related functions sponsored by the health care industry or its representatives. Meals at national meetings may be received so long as the related presentation is educational, scientific or consultative and not solely marketing-related (see full policy for details).
• Compensated speaking or attendance at events supported by the health care industry or its agents is permissible so long as VMC personnel are compliant with the specific criteria included in the policy. For example, compensation in the form of travel expenses and meals provided by the health care industry or its agents may be accepted in cases where VMC personnel are receiving in-service training on medical equipment, products or devices already purchased by VMC.
• The COI policy is not intended to discourage constructive scholarly exchange. Speaking, consulting and teaching arrangements are permissible but must follow University and VMC COI policy guidelines relating to consulting (see the policy for details).
To assist VMC personnel in understanding and complying with the policy, town hall meetings were held last week and recordings from those sessions are available online at www.mc.vanderbilt.edu/compliance. Also at that site, VMC personnel can review and download documents regarding the COI Policy as well as read a comprehensive frequently asked questions section.
“This is a statement of our values as an institution,” Balser said. “Our reputation as a world leader in biomedical science and health care is on a rapid ascent, and our faculty and staff are increasingly recognized as thought leaders. This policy will help to assure the public that our opinions and practices are our own, free of influence from marketing practices which are so prevalent in the health care industry.”