All gifts are prohibited.

All meals directly provided by industry are prohibited, but there is no explicit ban on meals at CME events.

Industry-paid speakers must disclose all financial interests to the audience.

ACCME accreditation and funding must go through the institution's CME office.

Attendance is allowed, but attendees cannot accept compensation for attending or for travel.

Industry support is allowed, but there are safeguards in place, such as selection of recipients by the institution and funds are provided to the institution, not the recipient.

The language is too vague to warrant a '3'; it states that covered persons are prohibited from publishing articles written or funded by industry, but then provides an allowance as long as industry participation is fully disclosed.

The policy specifies instances when consultation would require prior disclosure and approval, and most consulting arrangements with industry would appear to fall in that category.

The policy does not substantially limit access. While pharmaceutical sales representatives may not 'enter clinical areas of the institution' they are allowed to meet with a covered person if they are registered with the institution's purchasing department

Medical device representatives are permitted access to patient care areas to provide in-service training or assistance on already purchased projects or to assist covered persons to evaluate new industry products before purchasing them. This must take plac

Disclosure of financial relationships that constitute a COI is required internally and during industry funded continuing medical education presentations, but there is no requirement of disclosure to trainees.

A limited COI curriculum in the form of required training about COI for faculty and students is required by the institution. The curriculum is presented to students through PowerPoint slides, syllabus, small group discussions, large group didactic discuss

The policy applies to all faculty, employees and trainees when they are 'present at property or facilities owned, leased or operated by the institution or at activities primarily sponsored by the institution.'

There is a party responsible for general oversight (via a compliance concern call line that goes to a specific person) to ensure compliance with COI policies and there are sanctions for noncompliance.