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Policies, Procedures & Forms

Resident Employee Benefits and Administration

NOSM Conflict of Interest: Managing Learner Interactions with Commercial Entity Representatives

As outlined in the NOSM Conflict of Interest (COI) with Commercial Entities Policy, as a general rule, commercial entity representatives should not interact independently with learners, either on campus, or in clinical teaching environments. However, from time to time, there may be the opportunity for the expertise of a representative required for instructional teaching of a device. In these situations, the student or resident learning experience must be in the presence of a faculty member to supervise the interaction.

Faculty members have a teaching responsibility to ensure that commercial entity discussions with learners and residents are about the products, and that information presented is evidence informed, and demonstrates a balanced approach inclusive of any discussion of appropriate alternatives. Faculty members need to recognize that in doing so, they role model the professionalism of engaging in interactions for the health professional and medical learners. Regardless of the locale, meetings should be by invitation or appointment only.

An example of acceptable interaction and involvement of an industry representative in an educational environment with learners may be the demonstration of only the technical use of the equipment/implants. Pharmaceutical sales representatives will not have direct contact with students and residents.

Faculty members, staff members, and learners in the clinical learning environments as part of their professional responsibilities are expected to abide by the policies and procedures of the teaching facility with regard to meeting with commercial entities such as industry representatives.

The following situations may lead to a conflict of interest, if not managed appropriately. The following guidelines outline the policy adherence for faculty members, staff members, and learners when, and if, interactions occur with commercial entities and industry representatives:

  • Health professional, medical learner, and medical resident contact information must not be shared with commercial entities and industry representatives.
  • Industry representatives in clinical teaching facilities are only permitted in non- patient care areas, and by appointment only.
  • Permission is required by the clinical teaching facility for representatives to attend an event. If they do attend, representatives can only be there as listeners, or observers, not as participants. In addition, industry or commercial representatives are not permitted to participate or attend scientific and content planning meetings, nor play a role in content development.
  • Industry or commercial representatives cannot assume a role of a speaker or educator.
  • Faculty members, staff members, and learners are not to solicit financial or non- financial support for any NOSM-specific educational events or other activities with an individual commercial representative before advising the NOSM Advancement Office of the application.