Vendor Interaction with Graduate Staff

Effective Date: 2/15/08                                         
Next Review Date: 2/15/2011 

Number:  9200-218

PURPOSE

The purpose of this policy is to provide guidelines governing the support of GME activities by vendors and their interaction with graduate staff and training programs at NYHQ.

For the purposes of this policy “vendors” is defined as but is not limited to pharmaceutical and biomedical device companies and their marketing representatives.

This policy does not supersede other related Administrative Policies, “Pharmaceutical Marketing within the Medical Center” (#8020-013) and the Pharmacy and Therapeutics Committee’s policy, “Guidelines for Medical Services Representatives”; nor does this Policy supersede “The ACCME Standards for Commercial Support” governing the disclosure of vendor support by conference speakers at CME approved programs.

The policy aims to encourage programs to promote among graduate staff and teaching faculty an evidenced based approach to the evaluations of current and new therapies.

The policy also requires that both faculty members and graduate staff adhere to the relevant professional ethical standards (AMA “Code of Ethics”), NYHQ Human Resource policies and procedures, and applicable laws governing interactions between physicians and industry

PROCEDURE

As part of their curriculum all NYHQ sponsored programs should provide instruction concerning vendor marketing techniques, critical evaluation of vendor promotional material and ethical and legal constraints related to vendor interactions.

Vendor representatives must register and receive temporary ID when entering the Medical Center as per Pharmacy and Therapeutics Committee’s “Guidelines for Medical Services Representatives”.

Vendor representatives may sponsor educational conference guest speakers, and provide lunch for graduate staff conferences with the permission of the Program Director or faculty designee.  Prior to distribution to the graduate staff all promotional or educational material provided by a vendor must be

approved by the Program Director or faculty designee. While vendor representatives may attend conferences, they must not address attendees as speakers.

Promotional material distributed to the graduate staff must not be displayed in patient care areas of the Medical Center.

All reasonable funding provided by vendors for educational conferences, or for the support of other educational activities including financial support for attendance at professional conferences including registration, travel and lodging expenses must be given to the Program Director or NYHQ, used in accordance with applicable institutional policies, and never paid directly to a member of the graduate staff.

The Program Director or faculty and resident designees are solely responsible for the educational content of conferences.

A faculty member must be present at all vendor supported educational programs.

Members of the graduate staff may not engage in detailing activities, or participate in detailing activities off campus including those labeled as “peer group” or as “advisory group”.

In accordance with the AMA’s “Code of Medical Ethics” guidelines, members of the faculty and graduate staff may accept vendor gifts with patient benefit or gifts of educational value that are not of substantial value. Under no circumstances may the graduate staff accept cash or cash equivalent gifts. They may also accept gifts of minimal value related to their professional activities (pens, notepads, etc).

Under no circumstances may faculty or graduate staff enter into an explicit or implicit agreement with a vendor to prescribe a given medication or biomedical device in exchange for gifts.

Members of the graduate staff may receive competitive awards and scholarships funded by vendors if selection rests with NYHQ or an independent professional or academic organization.

Faculty and graduate staff may distribute specific branded medication samples when helpful to patients at NYHQ ambulatory care sites only in accordance with applicable pharmacy policy and only in instances when such prescribing does not compromise the quality or safety of patient care.

References

“Code of Medical Ethics”, AMA Council on Ethical and Judicial Affairs”

Anthony Somogyi, M.D.

Director of Graduate Medical Education and DIO

Approved by GMEC 2/15/08