Conflicts of Interest for the College of Human Medicine
I. SCOPE OF POLICY
The University's Faculty Conflict of Interest Policy sets forth the process for reporting and managing faculty conflicts of interest. Pursuant to that process, each faculty member is responsible for disclosing his/her own conflicts of interest. All faculty and academic staff must annually complete the Michigan State University Conflict of Interest disclosure, even if no outside financial relationships exist.
The following College of Human Medicine (CHM) policy applies to individuals appointed through the academic personnel system for whom the CHM is their lead college, all CHM students, and all residents affiliated with CHM. Throughout this policy, the term "individual(s)" pertains to faculty (which includes fellows and residents), academic specialists, staff and students.
This policy is intended to complement existing University, College, and Affiliated Institution conflict of interest policies. If there is a conflict among those policies, the more stringent standard applies.
A conflict of interest exists when an individual's financial interests or other opportunities for tangible personal benefit may compromise, or reasonably appear to compromise, the independence of judgment with which the individual performs his/her responsibilities at the University.
The most current info can be found on the Conflict of Interest at MSU website https://coi.msu.edu/.
II. CLINICAL SERVICE
A conflict of interest in the clinical setting occurs whenever the physician or clinic has entered into a relationship that might reasonably be thought to threaten the capacity to make good judgments concerning a primary obligation of the health professions, such as the duty to protect the welfare and rights of patients. A conflict of interest can exist even if the physician's actual performance of their obligations has been exemplary. The conflict of interest still raises an ethical question that must be addressed because of the risk it creates to the physician's exercise of their best clinical or ethical judgment. The question is whether that risk is ethically warranted by some greater good that the relationship makes possible. When the risk is not outweighed by a greater good, then the relationship is not ethically permissible, and the conflict of interest must either be eliminated altogether or managed to reduce the risk to a level warranted by the benefits of the relationship. The conflicting interest need not be pecuniary; and its effect on the physician's judgment may be indirect, rather than the result of a conscious or deliberate calculation on the physician's part. Well-meaning physicians who would never deliberately act contrary to their obligations may nevertheless be involved in ethically troubling conflicts of interest.
1. Interactions with Industry (pharmaceutical representatives and device manufacturers)
1.1. Individuals may not use or display industry promotional materials (pens, penlights, paper or prescription pads, etc.) when seeing patients.
1.2. Individuals may not accept personal gifts of any nature from industry vendors or representatives, regardless of value.
1.3. Individuals may meet with industry (pharmaceutical and device manufacturer) representatives by invitation in non-clinical areas to discuss industry products, but must keep such visits to a minimum conducted in a way that does not interfere with the provision of patient care, and be for non- marketing purposes (e.g. training).
1.4. Individuals may not accept food or beverages supplied by industry representatives or vendors, unless part of ACCME accredited activity.
1.5. Individuals may not accept or dispense sample medications and/or devices except in accordance with written policy of the health care system or practice and in compliance with state and federal regulations.
2. Display of Industry Promotional Materials
2.1. Individuals and clinics under the control of CHM faculty may not display or distribute industry promotional materials of any kind.
3. Direct Sale of Health-Related Goods or Services
3.1. Individuals may sell health-related goods or services directly to patients only in accordance with an approved conflict of interest management plan.
4. Ownership or Financial Interests in Ancillary Services or Facilities
4.1. Individuals may have ownership or other financial interests in services or facilities to which their patients are referred only in accordance with an approved conflict of interest management plan.
III. RESEARCH AND SCHOLARSHIP
Private industry supports useful basic and clinical research. The participation of individuals is important for the optimal development, testing and evaluation of both new and established therapies created by industry. Nevertheless, there is evidence that some of these relationships can corrupt scientific judgment or academic integrity. Where this risk arises, steps should be taken to minimize or eliminate it.
5. Financial Interests in Externally Funded Research
5.1. Individuals must report any financial interests including those of his/her immediate family, of any amount, in externally funded research, whether clinical or nonclinical in nature.
5.2. Individuals must report the terms of any contract under which funding is being provided.
6. Gifts or Grants from Private Industry or Individuals
6.1. Individuals will report the source, the amount, and the terms and conditions of each gift or grant.
7. Consulting and Speakers' Bureau Relationships
7.1. Individuals will report the source, amount of money received, and terms and conditions of each consulting or speaker's bureau relationship.
8. Ghostwritten Publications and Plagiarism
8.1. Individuals shall not accept authorship credit for a publication that has been substantially written by someone else.
According to MSU's policy on Faculty Rights and Responsibilities, faculty in the College of Human Medicine have important rights with regard to course design and instruction.
These rights are, however, limited by responsibilities to students, as outlined in MSU policies.
To insure that these obligations are met, the College establishes the following expectations. These expectations apply to both undergraduate and graduate medical education programs conducted by CHM.
9. Gratuities or Inducements for Teaching and Training
9.1. Individuals with teaching responsibilities or evaluation responsibilities may not accept gifts of more than nominal value from individual students or relatives of students.
10. Gratuities or Inducements from Applicants
10.1. Individuals may not accept gifts of any value from applicants for admission or family members of applicants.
10.2. Individuals may not evaluate applicants for admission who are related by blood, marriage, adoption, domestic partnership or other personal relationship in which objectivity might be impaired.
11. Students Performing Services on Faculty Research Projects
11.1. Individuals with supervisory oversight on research projects may not require students to participate in a funded research endeavor as a formal part of a course or training program when the student's services are being provided for an entity in which the individual has a financial interest.
12. Amorous Relationships
12.1. Individuals with teaching or evaluation responsibilities must adhere to the University policy.
13. Personal Relationships
13.1. Individuals with teaching or evaluation responsibilities may not participate, either formally or informally, in the evaluation of a student who is related by blood, marriage, adoption, domestic partnership or other personal relationship in which objectivity might be impaired.
14. Assigning Texts or Learning Materials
14.1. In accordance with University policy, individuals may require texts or other materials that result in financial gain if the following conditions are met:
14.1.1. Both the appropriate disciplinary department and the CHM Curriculum Committee shall determine that the text or other required material is an appropriate choice for the course.
14.1.2. Enrolled students will be informed of the departmental and Curriculum Committee determination, and of the estimated amount of revenue returning to the individual.
14.1.3. In the case of materials developed using departmental or College funds, all such revenues will be returned to the department or College.
15. Gifts from Industry
15.1. CHM regards it as unprofessional conduct for individuals to directly accept or display gifts of any kind or value (including such things as pens, penlights, tokens, meals, travel, textbooks, reference books) from industry representatives.
15.2. Individuals may not accept cash or gifts in return for attending an industry-sponsored lecture or educational event.
15.3. At its discretion, the College, department or training program may accept textbooks or other educational materials, scholarships, and other funds that will advance the trainees medical education.
16. Attendance at Industry-Funded Courses or Educational Activities
16.1. Individuals will not be required to attend industry-funded or directed courses or other educational activities.
V. Training Regarding Conflicts of Interest
- All CHM students shall receive training regarding potential conflicts of interest in relationships with industry, and this policy.
- All CHM students will complete a required curriculum on evidence-based medical practice that trains them in the effective use of independent and reliable sources of information and recommendations regarding diagnosis and treatment.
- The College required all individuals involved in research to complete the MSU on-line training. https://vprgs.msu.edu/training
VI. Procedures for Addressing Conflicts of Interest and Management Plans
The College procedures for addressing conflicts of interest and developing management plans are under Management Plans and Procedures and Form available here.
CHM Procedures for Addressing Conflicts
Department chairs and unit directors can refer to these procedures for managing conflicts of interest.
For assistance and examples of management plans chairs/directors should contact CHM Faculty Affairs and Development at email@example.com or 517-432-8722.