Conflict of Interest Policy with Commercial Entities
Society expects that health professionals and medical school personnel should act in ways that are unbiased, and in the best interests of individual patients and the wider community. Over the last decade, evidence has emerged that commercial interests, including pharmaceutical and medical device manufacturers, have at times exerted undue influence on physicians and other health professionals. This has led to the commitment by all Canadian medical schools to develop and implement a Conflict of Interest (COI) policy.
The Northern Ontario School of Medicine (NOSM) has a social accountability mandate to be responsive to the needs of the people and the communities of Northern Ontario with a focus on improving health care and health outcomes. The first new medical school in Canada for the 21st century, NOSM also has a commitment to innovation. The success of distributed, community-engaged learning, NOSM’s distinctive model of education and research, depends on close collaboration with hospitals and health services, physicians and other health professionals, and the communities of Northern Ontario. In this context, this COI policy has been developed through an extensive collaborative process and is anticipated to be consistent with the COI policies of partner clinical sites.
It is important to recognize that almost all NOSM clinical faculty members are stipendiary faculty who are primarily clinical service providers. Very few clinical faculty members have protected time away from clinical responsibilities to undertake education, research, or other academic activities. In this context, there will be a staged implementation of this policy to allow time for changes to occur in existing practices.
The intent of the COI policy is to enhance the professionalism of all NOSM faculty members, learners (including medical students and residents), and staff members in undertaking educational, research, clinical and other activities, while at the same time acknowledging and avoiding perceived, potential, and actual conflicts of interest. This policy provides a framework, which is designed to assist individuals and groups within and associated with NOSM to achieve success while ensuring the highest ethical and academic standards. Every individual, group, and organization has interests that affect decision-making, behaviours, and interactions with others. An “interest” is defined as the advantage or benefit of a person or group or having a stake or involvement in an undertaking, especially a financial one (Oxford English Dictionary). There are many types of interests, including personal, professional, social, and financial interests, for example, and these interests can combine and intersect. A conflict of interest exists in any situation where there is a potential divergence between an individual’s personal (or combined) interests and his or her obligations to the School such that an independent observer would reasonably question whether the individual’s behaviour or decisions are in any way motivated by considerations of personal interest, financial, or otherwise. A conflict of interest may be actual, perceived, or potential.
Conflicts that are thought to exist (e.g., perceived or potential) may be equally as damaging to NOSM as real or actual COIs. When a conflict of interest does occur, others should take care not to infer intent or guilt. Conflicts of interest may arise based on past practices and/or relationships. Dealing with COI should err on the side of transparency and disclosure.
A complete copy of the NOSM Board of Directors approved COI with Commercial Entities is available for viewing.
For further information, please email firstname.lastname@example.org.
When do I need to disclose?
- When preparing a talk or presentation, a verbal and in-writing disclosure statement is required regardless of whether or not research or speaker funding was received
- When there is a financial relationship to a medical device or pharmaceutical company or any other commercial organization may directly benefit from the talk or presentation.
What are examples of financial relationships that I may need to disclose?
- Acting as a paid consultant with a pharmaceutical company or medical device company
- Paid membership on an Advisory Board that has an affiliation with your presentation topic or research
- Investment in a commercial interest.
- Holding a patent on a drug, product, or device.
- Membership on a speaker’s bureau.
- Receiving research grants from a commercial organization
- Receiving travel grants from a commercial organization.
Can I accept an honorarium for a slide deck that is an evidence-based presentation developed by pharma?
- You could accept the honorarium as a speaker delivering a presentation as reimbursement of your time; however, participating in this context of education when you have not developed the content of the presentation is considered ghostwriting, and not considered an acceptable practice.
How do I eliminate COI?
- Refuse individual gifts (meals) when you have provided no service in receipt of the gift.
- Plan education that involves pooled funding (unrestricted educational grants) for educational events
- Do not allow the use of your name when you have not created the presentation content. This is considered ghostwriting.
- Disclose any financial relationships that you have with commercial entities at the beginning of a presentation. Being transparent allows the audience to consider any undue external influence while listening to the presentation. Additionally, one may want to consider including in their presentation evidence of multiple drug interventions options to alleviate any bias towards one pharmaceutical company.
What does the COI with commercial entities policy not allow?
- Clinical teachers inviting learners to attend a non-accredited pharma dinner sponsored event or any pharma-sponsored social events.
- Faculty or staff arranging non-curricular educational events with commercial entities for students and residents.
- Pharma representatives and medical equipment representatives approaching and interacting with students and residents directly without a clinical faculty member present. Having a clinical faculty member present allows for teachable moments with the students and residents about the ethical and professional issues of physician– commercial entity relationships and interactions.
- Pharma representatives actively participating in educational presentation discussions. Pharma reps can attend but cannot participate in or contribute to the discussion, and must be free of any visible identity of drug promotion.
What difference does it make if events use unrestricted grants or educational pooling of funds?
Can educational programs use industry educational material?
As a practising physician/health professional and a NOSM clinical faculty member, if I wish to assist with recruiting sponsorships or assisting in fundraising for my community hospital, do I need to seek approval from the NOSM Advancement Office?
No, is the simple answer. For fundraising or events seeking sponsorship that are not related to NOSM, you do not need to seek approval from the NOSM Advancement Office. You should, however, note the importance of abiding by the conflict of interest policy of the organization or institution that you are working within soliciting those funds.
As a practising physician/health professional and a NOSM clinical faculty member, if I wish to assist with recruiting sponsorships or assisting in fundraising for an event or purpose that is a collaborative effort between my organization and NOSM, do I need to seek approval from the NOSM Advancement Office?
In submitting a research ethics application, why do I need to disclose all financial relationships, and for how long back do I need to report?
How many years back do I need to disclose my financial relationships?
Can I accept samples from pharmaceutical companies?
Does conflict of interest with the pharmaceutical industry only apply to physicians?
As a health professional and clinical teacher holding a NOSM faculty appointment, to whom do I annually disclose my financial relationship of over $5,000.00?