ANSWER: The CPI committee felt strongly that whenever SoM faculty present at programs designed solely or predominantly for company promotional, sales or marketing purposes, the faculty participation, even though compliant with the fair market value standard, created a real and inappropriate conflict of interest situation. The CPI subcommittee also reviewed the policies of peer medical schools across the country and found that several institutions contain a similar prohibition.
ANSWER: Yes, the conflict of interest starts with the presence of your name in a company's list of individuals maintained by the company ("Speakers Bureau"). The implication to the public if your name appears in that list is that you directly or indirectly "work for the company'' or/and that your role is to advance the interests of the company.
ANSWER: Yes, it is in fact the willingness to participate in a Speakers Bureau - in a list maintained by a company that leads to the perception of promoting a company's product or service. This is present regardless of who is responsible for the content of the presentation.
ANSWER: Yes, the prohibition applies to participation as a speaker, panelist, presenter, or commentator in any activity or event funded, directly or indirectly, by a commercial entity, where the event is, or may be perceived to be, a promotional event for the sponsoring organization and/or its products or services.
The symposium has received the funding and I was asked by the symposium steering committee to participate and they will pay my travel, accommodations and an honorarium for my participation. I am not receiving money from the company. Is this allowed?
ANSWER: Under the current COl policy, as long as the symposium meets the standards for a CME activity (industry does not pick the speakers, control the content, etc.), participation in the symposium is permitted. The revisions to the policy do not prohibit or change this. However, you must still comply with the University's outside work policy.
ANSWER: So long as the Grand Rounds meets the standards for a CME activity, and neither is, nor is perceived to be, a promotional event for a company and/or its products or services, compensation directly by the company is not prohibited. However, please be aware that such direct payment is not considered best practice, may need to be disclosed under the University rules related to conflict of interest in research (GIM 10), and will be publicly disclosed by the company (pharmaceutical or device manufacturer) under the soon to be implemented Physician Payment Sunshine Act.
ANSWER: If you can end the arrangement without undue burden to yourself or the outside company that would be the best course. However, you are entitled to fulfill the terms of the existing a11'angement but it may not be renewed or extended.
ANSWER: You are free to give your opinion on the effectiveness of any product or device. You may not do it as part of any program put on by the manufacturer for the intention of promotion of the product or device.
ANSWER: In the context of your University employment, you may give your opinion if asked, for example by a UW Medicine purchasing committee, but you must disclose your financial interest in the product and recuse yourself from any purchasing decision. There may also be limited circumstances where you may appear on behalf of industry as indicated in the policy, including in situations where you have a financial interest in the product and are doing approved outside work involving that product.
ANSWER: The existing policy applies specifically to faculty employed by the University and its close affiliates. All faculty not otherwise covered are currently encouraged to follow the intent of the policy and its guidelines. However, the new prohibitions on speaker bureau participation and commercial product endorsement will apply to all (paid and unpaid) faculty.
Faculty can find additional information regarding the Outside Work policy on the SoM intranet.
Questions regarding the Outside Work Policy, approval process or the changes to the UW Medicine Policy on Potential Conflicts of Interest with Commercial or Nonprofit Entities should be directed to Jasmine Campbell, Director of Regulatory Guidance. Jasmine may be reached at 206.543.6047 or jlnc@uw.edu