No industry-funded gifts of any nature or value allowed.

No industry-funded meals of any nature or value allowed except in the case of industry-funded ACCME-accredited CME.

Policy effectively prevents faculty from being paid by industry to do promotional speaking, or to be on industry-funded speakers bureaus.

The policy allows industry-support of CME with central management of the funding.

Faculty, staff, and trainees shall not directly accept funds from industry for travel to any event, including educational events.'

Industry may provide scholarships for meeting attendance, but it may not participate in the selection of attendees.

Ghostwriting and honorary authorship are strictly prohibited.

In reference to consulting agreements, Policy document 2 requires that honoraria not exceed the fair market value of the services provided. There is no additional discussion of consulting or advising relationships for purely commercial or marketing purpos

Pharmaceutical representatives are allowed to meet with faculty. The meetings must take place only in non-patient care areas and only by invitation or permission of department heads or their designees.

Access to device reps is allowed only for training staff on equipment already purchased.

Internal disclosure is required annually.

A limited COI curriculum is required by the institution.

All faculty, employees, and trainees are subject to the institution's COI policies, but the policy documents do not specify that the COI policies also cover them in all instances, locations, or whereabouts.

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