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

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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?

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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

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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.

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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.

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15 types of interactions

1. Gifts2. Pharmaceutical samples and medical/dental

supplies3. Site access by pharmaceutical representatives4. Site access by device manufacturers5. Continuing Professional Development6. Industry funding for educational programs7. Participation in industry-sponsored programs8. Scholarships and other educational funds

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Types of interactions … continued

9. Food10.Professional Travel11.Ghostwriting12.Purchasing13.Consulting relationships14.Educational materials15.Philanthropic gifts

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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

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2. Pharmaceutical samples

• Don’t accept samples and supplies directly.• Samples should go directly to patients/test

subjects through a voucher system where available.

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3. Site access by pharma/dental supply reps

• By appointment only• Away from patient-care

areas• Students must be

supervised

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4. Site access by device manufacturers

• By appointment only• Away from patient-care

areas• Students must be

supervised

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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

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6. Industry funding for educational programs

• Individuals may not accept or solicit funds for educational activities.

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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

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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

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9. Food

• Do not accept free food• Industry can provide grants

to an organizing committee• Industry should not cater

events directly

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10. Professional Travel

• Do not accept travel expenses for educational events

• Accept only work-based travel cost

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11. Ghostwriting

• Maintain your authority as an author

• Do not put your name on ghostwritten material

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12. Purchasing

• Disclose all relationships with industry

• Remove yourself from the decision-making process if there is a conflict of interest

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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

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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

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15. Philanthropic gifts

Donations welcome through:• Schulich School of Medicine

and Dentistry• Affiliated hospitals• Western University

NOT to individuals

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Researchers must:

• Be free to disseminate results

• Be unbiased• Be clear about how (and

by whom) they are paid• Conduct research

ethically

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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

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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.

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Enforcement

1. Counseling of the individual2. Written reprimand, entered into their record3. Banning the individual from any further outside

engagements for a period of time4. 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

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Reporting

• To your immediate supervisor• To department chair• To the dean

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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.

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Questions?