Gifts from industry are prohibited with the exception of educational items meant primarily for patient use (such as patient-friendly booklets describing organ systems). Institutional gifts from donors are separate and should be directed to the Development

Food and beverages, or subsidies for food and beverages, from industry is prohibited for both on and off-site activities.

While promotional speaking is strongly discouraged, the policy is not restrictive enough to qualify as a model policy on speaker's bureaus. Paid speaking engagements are subject to approval. The policy lays out a list of questions that speakers should con

ACCME accreditation is required.

Even though the policy does not prohibit attendance, employees and trainees are encouraged to attend off-campus events sponsored by industry only when CME-credit is offered, or those events with 'legitimate educational value'. Moreover, it does not allow

Scholarship/awards to attend events or trainees is allowed; however, funds must go through a general departmental education fund with assigned criteria to select recipients. Moreover, vendor support for trainee education must be in the form of educational

Ghostwriting is strictly prohibited and an author's role in content and contributions must be verifiable.

Consulting by full-time faculty must be reviewed and approved by department chair. Remuneration must be fair market value.

Pharmaceutical sales representatives are allowed access to health care staff as long as they have an appointment and meet in non-patient care areas.

Access by medical device representatives to patient care areas is permitted by appointment to train physicians, researchers and others in device use or new technologies. These visits specify talking about and demonstrating new products, and states that pr

Internal disclosure is required annually. Faculty must disclose any business conflict of interest at the time that conflict arises. Research faculty are required to submit annual disclosure forms to institution (per federal regulations) and externally whe

Although the policy does not state anything related to curriculum, the institution noted during its policy submission a COI curriculum is required for all medical students. The information is presented through a syllabus, slides and learning objectives. F

This policy applies to all employees of the institution, whether full/part-time or volunteer faculty, and it applies to them regardless of the site where they are working.

There is an oversight authority for policies and sanctions in place for non compliance.