VCOM Institutional Policy and Procedure Manual

VCOM Policy and Procedure

Policy #U015

Any educational material for VCOM employees supplied by industry representatives or vendors is permitted only when such material is deemed by the department as not tied to a specific product or device and not inducing the recipient to purchase, use or prescribe a product through these materials. Such materials are to be distributed directly to the chair and not to VCOM faculty, residents, staff and students. 5.10 Medical Device Representatives Medical device representatives are prohibited from promoting any products in patient care areas. Medical device representatives may access patient care areas only for reasons not related to marketing, specifically, providing training to medical personnel or providing technical assistance on equipment or devices currently present at the site. 6. CONFLICT OF INTEREST DISCLOSURE AND PROCEDURES Successful implementation of this policy assumes a shared responsibility by all employees and the administration of VCOM. VCOM personnel are expected to comply with all the disclosure requirements described below. Individuals are strongly urged to discuss proposed external activities with their deans and/or division chairs in making an initial judgment as to the appropriate category for that activity. All VCOM faculty are expected to consult with and seek authorization from their supervisor and the President prior to entering into a secondary employment or compensation arrangement including, but not limited to, teaching, professional services, consulting services, speaking engagements, board membership and writing services. All VCOM faculty engage in outside compensated professional activities must be able to document clearly these services. Please see the VCOM Faculty Handbook for procedures on outside consulting and academic work. VCOM board members, officers and designated employees shall internally disclose relationships with industry upon entering a new or revised relationship with industry. . Such disclosure shall be made to the President and campus Dean. Please see the VCOM Board Policy B001, VCOM Policy on Conflicts of Interest for disclosure form and procedure. Per policy B001, disclosures should be made to the President for review and approval. The President may choose to convene the Conflict of Interest Committee to evaluate the disclosure. As a medical school, VCOM requires that all VCOM faculty also externally disclose to students and fellows all relevant industry relationships they have. Such disclosure must occur as part of their faculty biography, a presentation or as a declaration during rounds. Transparency regarding industry relationships is an important mechanism for preserving public trust and professional integrity. Accordingly, the following information will be made publically available on the VCOM website for any VCOM personnel earning more than $5,000 per year or receiving equity from an industry relationship: a. Name and title of VCOM personnel, b. Names of companies with whom VCOM personnel has a financial relationship, c. Basis for payments (consulting, educational lectures, royalties, equity or stock options, etc), d. Range of reimbursement for most recent 12 month period.

VCOM Policy on Conflicts of Interest

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