The University of Florida (UF) recently began implementing a new Conflict of Interest Program to address physician-industry interactions. The conflict of interest (COI) Program is focused on structuring appropriate, principled, transparent relationships with the university’s “valued Industry collaborators.”
According to the policy, industry “relationships are critical to the success of the University’s effort to teach medical students, train residents and fellows, and to provide the best care for our patients.”
However, the University of Florida recognized the changing direction of academic medical centers across the country that are introducing specific measures to maintain the public’s trust in academic medicine. Many of these policies have been enacted or changed largely because of extensive media coverage and intensifying government scrutiny about physician-industry collaboration.
Accordingly, the University of Florida introduced its new Conflict of Interest policy, and recognized that the determination that an individual has a conflict of interest “is a judgment about the situation and not about the professional who happens to be in that situation.”
The policy applies to a broad array of individuals employed by UF, including Faculty, Residents, Fellows, AP, and TEAMS, USPS & OPS (College of Medicine or “COM”).
Under the policy, “Industry” includes, but is not limited to, pharmaceutical, medical device, equipment, biotechnology, service, software, supplies, biomedical investment, and for profit educational companies and foundations sponsored by companies such as drug and device companies
Gifts and Food
- The policy prohibits accepting gifts of any kind and does not permit industry-purchased food at the College of Medicine.
Samples
- Generally, the policy prohibits samples, but UF faculty may petition the University of Florida Physicians Clinical Safety Committee for a waiver, and demonstrate clear and compelling benefit to patients in need and must provide safeguards for appropriate distribution and control.
Teaching Materials
- Generally not permitted to directly accept books, instruments, equipment, or teaching aids from Industry
- Want to encourage Industry and faculty to use the UF Foundation, which is designed to accept grants from Industry
- Dean’s Office will have oversight and audit function
- Materials/equipment may be donated to Foundation if properly transferred via a written agreement
CME and Non-CME
- If CME, must comport to ACCME standards and be processed through the CME office
- Non-CME educational activities are monitored, evaluated and subject to full disclosure
On-Site Training
- Industry may provide on‐site training with preapproval from the COM’s CME office or the Industry Academic Relations Committee if non-CME. Industry may also receive on-site training from COM personnel in the safe and proper use of certain medical devices and/or equipment.
Off-Site Events
- UF faculty may participate in or attend Industry-sponsored conferences and meetings and/or conferences and meetings of tax-exempt organizations funded or sponsored by more than one entity, which may include Industry under certain circumstances.
- Food/ beverages made available to the entire group are allowed. However, some companies report the provision of food/beverages and your name may appear in an Industry database.
- Travel expenses may not be paid by Industry unless you are speaking/presenting based on a written agreement.
Speaker’s Bureaus
UF’s College of Medicine defines a “speakers bureau” as any engagement in which you are speaking on behalf of Industry, where the content of the talk is not completely original to you; or the talk is subject to Industry approval; or the attendees of the event are selected by Industry or provided a gift or stipend to attend.
- Speakers Bureau activities are prohibited.
- Violations of this prohibition against Speakers Bureau activities will result in disciplinary action.
- As of January 1, 2011, faculty should not have any active Speakers Bureau relationships with Industry.
Ghostwriting
- The professional presentations, books, articles, reports, or other materials, oral or written, of COM personnel must have appropriate authorship attribution.
- Collaboration with Industry during any phase of manuscript preparation should be appropriately disclosed.
Scholarships/Fellowships
- Cannot be accepted directly from Industry
- However, Scholarship and fellowship funds may be provided to the Foundation for education, travel to educational programs, and for other educational purposes.
Disclosure
All faculty and members that fall under this policy must disclose outside activities and financial interests, which is to be reviewed by the department chair or immediate supervisor and forwarded as necessary for authorization. The form must be completed and filed prior to such time as the outside activity or financial interest begins and at the beginning of each fiscal year. They must first be approved by the Chair, the Dean’s Office, and, if applicable, the Office of Research before participating in the outside activity. If a material change in the information presented occurs during the year, a new form must be submitted. All paperwork associated with continuing outside employment/activity must be renewed on a fiscal‐year basis.
- Outside agreements must reference the individual’s home address and compensation must be paid to them acting in a private capacity.
- Compensation must reflect Fair Market Value.
- Reasonable travel expenses may be reimbursed by Industry or other entity.
Discussion
Many of the rules are fair and balanced. The prohibition of samples and speakers bureaus is an unfortunate side effect of the endless barrage on freedom of association by the Association American Medical Colleges (AAMC). It is unfortunate that universities adopt these policies. Perhaps in several years from now we may see a shift back to allowing samples and physicians to speak on products to other physicians in their community.