Non-cash gifts worth up to $50 per occurrence are permitted; however, residents and fellows may not accept any gifts or meals.

'Modest' meals are permitted if provided 'for educational or scientific exchange.' Such 'informational presentations' must coordinated in advance.

Participation in speakers bureaus is permitted but there is some regulation: 'Speakers should ensure that the terms of the arrangements are set in advance and set forth in writing and must be pre-approved by the Office of Integrity and Compliance.'

Educational grants provided through industry representatives should be addressed to the UMMC and specified for individual departments. They should not be provided directly not to an individual (or department). Educational grants should be coordinated thr

Attendance is allowed but attendees cannot accept industry reimbursement for travel or other remuneration in the absence of an FDA-mandated training need or a formal consulting agreement.

'Vendor sponsorship of GME educational activities should take place under the unrestricted grants and gifts only. An unrestricted grant or gift is one that is given to a UMMC department or program in which the donor(s) have specifically identified their i

No policy provided

Consulting arrangements must include fair market compensation for specific services where compensation reflects time and effort and where expected work products are defined in advance in a written contract.

Pharmaceutical representatives are allowed to meet with faculty and trainees but the meetings must take place only in non-patient care areas and the meetings must take place by appointment only.

Device reps must have an appointment and obtain a badge before entering patient care areas, and their roles are specified as being for 'assisting the patient care team for a specific clinical situation or ... repairing or servicing equipment.'

Annual disclosure of financial relationships that constitute a conflict of interest is required of all faculty researchers. However, disclosure to students or trainees is not required.

'Programs should provide training to residents and fellows on vendor relations and conflicts of interest, including reference to this policy and other relevant institutional policies.'

All faculty, including part-time and non-salaried, must comply with the COI disclosure policies.

There is a party responsible for general oversight to ensure compliance with COI policies and there are sanctions for noncompliance.