Gift' is defined on 12a) pg 2, all-encompassing definition; gifts are prohibited

Food can be supplied at ACGME accredited programming within ACGME-guidelines; off-site participation in industry sponsored meals is 'discouraged' but not prohibited

Faculty participation in industry-sponsored speakers? bureaus is strongly discouraged', it goes on to say that these interactions should be transparent and that speakers should be paid a 'fair market' value. The description was not detailed enough to warr

Requires that CME meet ACGME criteria and the funding is overseen by a university office of CME (not stringent enough for a 3, but has the extra point to make a 2)

Strongly discouraged from attending, prohibited from accepting industry reimbursement.

Recipients may be selected for funds via a process coordinated by a centralized office

Strictly prohibited

Policy outlines that faculty members must comply with policies regarding fair market value and guidelines on COI.

Meetings must take place in non-patient care areas and by appointment only (not stringent enough for a 3)

permitted only when the representatives are appropriately credentialed ... and should take place only by appointment or invitation of the physician', can only present to provide in-service training or assistance

Requires internal disclosure; we cannot find required disclosure to audience

There are COI components of a larger curriculum called 'Physicians, Patients, and Society' course. Unclear how detailed the COI curriculum is

12z says that the COI policies apply to students and faculty at all sites, even students at sites outside the institution's system. 12a states that the 'Policy on Industry Relationships' applies to ALL faculty, students, and staff.

States that, 'Executive Vice President for Medical Affairs and Dean authorizes this policy' and that the dean's office should be contacted for 'interpretations and resolution of problems'. No explicit section for non-compliance/sanctions.