NB: The Institute on Medicine as a Profession has added the following to this document:

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1 Policy Health Care Industry Product Interactions Principles for Authorship on Scientific and Scholarly Publications Frequently Asked Questions about the Health Care Industry Interactions Policy Date Updated Page 10/1/ /13/ NB: The Institute on Medicine as a Profession has added the following to this document: 1. The page numbers in red for ease of navigation 2. The yellow highlighting to indicate the referenced policy language

2 About MCW Contact Employment Calendar Directions & Maps Staff Login Education Research Patient C are Search MCW All MCW C ommunity Health Graduate Medical Education Departments Give to MC W Graduate Medical Education mcw.edu > Graduate Medical Education > Institutional Policies > Health Care Industry Product Interactions About Us Residencies & Fellow ships Housestaff Orientation Housestaff Life Administrative Resources Institutional Policies Bookmark Risk Management RSS GME Forms Graduate Medical Education Institutional Policies Alcohol and Controlled Substance Abuse Appeal Process for Adverse Academic Decisions Medical College of Wisconsin Affiliated Hospitals, Inc. Institutional Policy Complaints and Grievances by Housestaff Regarding the Educational or Professional Environment Corporate Policies and Procedures Designated Institutional Official (DIO) Administrative Disasters, Support for GME Programs During Duty Hours for Housestaff HEALTH CARE INDUSTRY PRODUCT INTERACTIONS Educational Resources Committed to a Program Evaluation of Faculty by the Housestaff Category: C onduct, Integrity, C orporate Responsibilities (C R) Evaluation of Housestaff and Progressive Management of Substandard Performance Policy #: AD.C R.040 Applies To: All MC W Employees, Residents, Trainees Fatigue, Companion Document to Fatigue Policy Fatigue, Housestaff Fellow ships, New Fitness for Duty Evaluations FTEE Commitment to Direct and Coordinate GME Programs Goal and Institutional Commitment to GME Graduate Medical Education Committee (GMEC) Health Care Industry Product Interactions Housestaff Health and Welfare Committee (HHWC) Immunization and TB Testing Intellectual Property Internal Review s Leave of Absence Licensure Requirements for OMS Licensure, Temporary Educational Permit and DEA Number Requirements for Housestaff Moonlighting Multi-Specialty Fellow ship/residency Programs Oversight of Educational Sites and Site Directors Part-Time Housestaff Training Professional Behavior PURPOSE: This policy has been approved by the President and the Board of Trustees for the Medical C ollege of Wisconsin. The purpose of this policy is to establish standards for interactions with health care product industry representatives for MC W C overed Personnel. Interactions with industry occur in a variety of contexts through the promotion of the educational, clinical and research missions of the C ollege. However, at times these interactions may also create conflicts of interest, improper influence on decision-making, or the appearance of impropriety. Recent research indicates that industry activities such as the provision of gifts may affect health care provider behavior and decisions. MC W believes that this policy will enhance positive and constructive working relationships with industry and minimize questions about improper influence of sales and marketing activities at the C ollege. Our goal is to raise awareness among C overed Personnel of the challenges to professionalism and to help them build critical evaluation skills that reinforce high individual standards, norms and behaviors. DEFINITIONS: The following definitions are used for the purposes of this policy. Compensation provided by Industry: C ompensation shall mean remuneration or consideration provided directly to a C overed Person for services they provide to Industry. Covered Person or Personnel (also referred to as Person or Personnel): The scope of this policy includes all classes of individuals identified within this definition, unless specifically identified by category within the applicable provision. This policy is intended to include but is not limited to all paid Faculty, Staff Physicians, Residents, Students, Post-Doctoral Fellows, Executives and Officers, Exempt and Non-Exempt Staff. Gifts provided by Industry: Gifts shall be defined as any item(s) of value received by a C overed Person or made for the benefit of a C overed Person, for which the recipient has not paid fair market value or was not earned through the provision of services, and which are not Page 2 of 13 Print

3 Professional Personal Appearance Program Evaluation Committee(s) Program Reduction/Closure Qualifications and Performance of Program Director Records and Record Retention Research by Housestaff Rotations, Offsite Elective Rotations, Visiting Housestaff Selection of Residents and Fellow s Supervision of Housestaff Teaching of Medical Students by Housestaff Transfers to and from GME Programs fair market value or was not earned through the provision of services, and which are not otherwise available to the public at large on the same basis. Gifts shall also include free drug samples, meals, and equipment or other items which may be used in the course of the Covered Person s work if such items are provided to the individual. Gifts do not include: Competitive grants. Informational materials that have been produced under the Accreditation Council for Continuing Medical Education (ACCME) guidelines or published under a peer review process, Donations made directly to MCW which provide a benefit to the College. For further clarification on Gifts see MCW policy Conflicts of Interest, Outside Professional Activities and Consulting (AD.CR.030). Health Care Products Industry or Industry: Any organization or person that has an interest in selling clinical products or services related to the health care work being done at any MCW location. This shall include but not be limited to: pharmaceutical companies, device manufacturers, health care service or provider organizations, research sponsors, health care information system developers, etc. Industry shall not include any non-profit, professional society, where such organization takes appropriate measures to ensure that its organization and activities are free from commercial influence, or litigation firms seeking to retain an individual for litigation purposes. MCW Location: This shall be defined as premises which are owned, controlled or leased by MCW. POLICY: MCW has Covered Persons working at multiple locations throughout Wisconsin. This policy shall apply to all MCW Covered Persons regardless of where they work. In places which are not an MCW Location, it is expected that Covered Personnel will comply with the terms of this policy as the minimum standard of expected behavior. Additionally, if that site has rules which are more restrictive on the issues covered in this policy, it is expected the Covered Person will comply with those requirements as well. 1. Gifts to Individuals: Gifts from Industry may not be accepted by any Covered Person at any time. Examples of gifts include free drug samples, textbooks, equipment, meals, travel costs, or monetary payment. 2. Donations to the College: Under certain circumstances, donations of certain equipment or other items of value may be made to MCW by Industry. However, these gifts must be evaluated and approved on behalf of the institution before they may be accepted. Donations to MCW should be referred to the following locations for approval: A. CME Sponsorship: Under certain circumstances, MCW may accept financial support provided to a College-wide, departmental or divisional educational event or program. Donations of this nature must be reviewed and accepted as outlined under Section 4 below. B. Pharmaceutical Donations: MCW may accept samples of pharmaceuticals for use in MCW clinics or clinical research ventures provided the appropriate donation standards are met. Donations of this nature must be cataloged and tracked in a uniform manner across all MCW owned and operated locations. Donations may be accepted by any Medical Director on site. However, the tracking of both receipt and disbursement of such donations must be reported on a regular basis. The Compliance Office shall establish uniform guidelines for tracking and managing donations from various pharmaceutical providers and shall audit compliance with those standards across all sites. C. Equipment Donations: Research or clinical equipment may be donated to MCW at the request of the receiving department and with the approval of the Compliance Office. D. Educational training grants: Grants for the promotion of education among trainees, students, post-doctoral fellows, or residents may be provided by contacting the appropriate central educational office which may include: Academic Affairs, the Graduate School, Graduate Medical Education or the Office of Post-Doctoral Fellows. Grants funding the establishment of a permanent training position within a particular division must be reviewed by the Office of Faculty Affairs. The Corporate Compliance Office shall approve all unrestricted educational grants. E. Other donations: Other donations may be made by contacting the Corporate Compliance Office. 3. Site Access: The requirements of this section are intended to apply to Industry representatives coming to MCW for the purposes of selling or marketing clinical products. The restrictions below are not intended to limit individuals coming in to repair or maintain equipment already purchased by MCW or for some other legitimate business purpose. 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4 A. Clinical Areas: Sales and marketing representatives from pharmaceutical Industry are not permitted in any clinical (patient care) areas. Device Industry representatives are not permitted in clinical areas except to provide in-service training on devices and other equipment already purchased, to provide demonstrations that may be of benefit to patients where no purchase is required, or to provide necessary technical advice involving the use of devices or equipment. These kinds of appointments may be scheduled in advance. If necessary due to an urgent patient care situation (or) to assist with the device insertion or use and consent has been obtained from the patient, then no appointment or additional permission is necessary. B. Non-Clinical Areas: Sales and marketing representatives from Industry are permitted in non-clinical areas by appointment only for the limited purpose of in-service training of personnel for equipment already purchased or for the evaluation of new equipment or pharmaceuticals for possible purchase or education. C. Scheduling Industry Representatives: When an Industry representative is scheduled to be on-site, the faculty member interested in the training or product evaluation or education is responsible for scheduling the representative and must ensure the following standards are met: i. The Industry Representative is supervised while in the designated location and leaves after the particular purpose has been completed. ii. The Industry Representative may not be allowed access to Covered Personnel or their mail boxes or other sources of information distribution outside of the scheduled meeting time. This prohibits the release of electronic addresses or other contact information as well. iii. It is the responsibility of the faculty member scheduling the Industry representative to ensure he/she has the appropriate credentials to perform the education or training requested. D. Food: With the exception of food provided in connection with ACCME-accredited programming and in compliance with ACCME guidelines, Industry may not provide food at any MCW Location. E. Students and Trainees: Students and trainees should only be involved in programs with Industry Representatives for educational purposes and when such program is conducted under the supervision of a faculty member. 4. Continuing Medical Education, Professional Meetings & Industry Events: A. ACCME Standards: All events that receive Industry support and that are sponsored by the College, a department or a division of MCW must be conducted in a manner compliant with the ACCME standards, whether or not CME credit is awarded. This includes not only educational events, but also other professional activities such as faculty meetings, regardless of where such events occur. B. Departmental Coordination: Industry sponsored donations to support educational programming may not be accepted or managed by an individual. Such contributions must be managed by the department or division. The Corporate Compliance Office shall approve all unrestricted educational grants. Non-approved or inappropriate funds will be returned to the Industry sponsor. Appropriate records of the use of such funds must be kept in accordance with Sponsored Programs procedures and meet the ACCME standards. C. Industry Prohibitions: With the exception of food provided during ACCME-accredited programs, Industry representatives may not provide meals, goods or monetary donations, or the direct or indirect funding of such, for attendance at any educational or professional activity at any MCW-affiliated location. Covered Persons are strongly encouraged not to accept food at any location under any circumstances (with the exception of food provided during ACCME-accredited programs). D. Industry Program Participation: Covered Persons should only participate in Industry sponsored programs, meetings or conferences if the following standards are met: i. The educational program is ACCME accredited. ACCME accreditation is limited to the United States of America. Therefore, this standard does not apply to events outside the country. ii. Covered Persons do not accept Compensation for attending an Industry-sponsored meeting. Page 4 of 13

5 iii. Covered Persons do not accept personal Gifts at such events, with the exception of food provided during ACCME-accredited programs. iv. Covered Persons receive fair market value for any services they provide related to such an event. Such services must then be disclosed under Section 6 below. v. Any presentation made by a Covered Person must be the result of his/her own work and is not allowed to be authored by Industry. E. Industry Sponsorship of Professional Societies: Covered Persons may be officers on professional Societies that receive Industry support as long as Industry does not have influence or control on the content of the meetings or lectures. Professional Society activities do not need to be compliant with ACCME standards in order for Covered Persons to attend these activities. F. Industry Sponsorship of Education of Trainees, Students, Residents or Post- Doctoral Fellows: Industry may provide financial support for the educational benefit of trainees, students, residents or post-doctoral fellows provided such funds comply with the following requirements: i. Such funds are held by a central authority within the department or division providing oversight to such trainee, student or resident; ii. The MCW department or division determines which individual receives the educational support and how such funds are to be expended. iii. There is no expectation of any quid pro quo or direct benefit being provided to the Industry sponsor in return for their funding. 5. Travel: Covered Persons are prohibited from accepting direct reimbursement of travel funds from industry, other than for legitimate reimbursement for contractual services and associated expenses, including required training and educational events specific to a current clinical trial. 6. Disclosure: Covered Persons are expected to make full disclosure concerning any Industry relationships pursuant to the procedure outlined below. PROCEDURE: REPORTING: The procedure below is set forth to explain the process by which Covered Personnel must report participation in Industry sponsored events or interactions. The goal of reporting is to create transparency in an individual s activities, as they may relate to the work performed in the course of their employment. 1. Publications: Covered Persons must disclose their financial interests associated with Industry in relation to scholarly publications. 2. Conflict of Interest: Covered Persons must file all appropriate disclosures as required under MCW policy Conflicts of Interest, Outside Professional Activities and Consulting (AD.CR.030) and pursuant to the Financial Conflicts of Interest in Research Policy (RS.GN.020). 3. All Covered Persons shall provide concurrent or prospective reporting concerning the activities governed under this policy. These reports will be made available to the Department Chair for review and oversight. In the event a conflict arises, they will be immediately reported to the appropriate senior leader along with the Department Chair. For issues involving Faculty, residents, students or fellows the senior leader shall be the Dean and for staff it shall be the Senior Vice President. Following a review of the matter, the senior leader may refer the matter to the MCW Conflict Review Board. The manner and form of the Health Care Industry Product reporting shall be determined by the Corporate Compliance Office. 4. Failure to comply with this policy, to make complete disclosure, or to comply with timely filing of the required reporting requirements may constitute grounds for termination or any other penalties which may be assessed under other College policies, procedures or the faculty handbook. For any questions concerning the content of this policy or the reporting requirements please contact the Corporate Compliance Office for clarification. REFERENCES: Conflicts of Interest, Outside Professional Activities and Consulting (AD.CR.030) Financial Conflicts of Interest in Research Policy (RS.GN.020) ACCME Standards for Commercial Support ATTACHMENTS: Page 5 of 13

6 ATTACHMENTS: Health Care Industry Product Interactions Policy - Frequently Asked Questions Health Care Industry Product Interactions Policy - Summary Document Health Care Industry Product Interactions - Reporting Form Annual Certificate Disclosure Form Effective Date: 03/01/2009 Revision History: 04/01/2009, 10/01/2009 Supersedes Policy: N/A Review Date: N/A Approved By: /S/ T. Michael Bolger, President and CEO Medical College of Wisconsin The Graduate Medical Education Council approved the MCW policy 'Health Care Industry Product Interactions'. This policy is adopted and incorporated in its entirely. This policy replaces MCWAH's Institutional Policy 'Gifts by Pharmaceutical and Medical Equipment Companies'. This policy was approved by the MCWAH Graduate Medical Education Council on July 20, webmaster@mcw.edu 2011 Medical College of Wisconsin Education Research Patient Care Community Health Departments Staff Login MCW Home Contact Calendar Directions/Maps Terms & Privacy About this Web Site Site Map Page Updated 08/04/2011 Page 6 of 13

7 The Medical College of Wisconsin Principles for Authorship on Scientific and Scholarly Publications Introduction/Purpose This policy sets forth principles of authorship to provide clear guidelines for responsible conduct relating to authorship of scholarly publications. Scholarly publications include articles, abstracts, and other dissemination of written findings, thoughts, and analyses. These principles of authorship emphasize intellectual and academic contributions. Implicit is that attribution of credit should be given to individuals whom credit is due and concurrently to identify those individuals responsible for the integrity of the scientific contributions. Policy 1. The Medical College of Wisconsin adopts the ethical principles embodied in the Uniform Requirements for Manuscripts, composed by the International Committee of Medical Journal Editors, as revised in 2003 ( These principles, which are compatible with ethical and editorial policies of highly reputable biomedical journals, are as follows: a. The qualifications for authorship are the following: (1) substantial contributions to conception and design, or acquisition of data, or analysis and interpretation of data; (2) drafting the article or revising it critically for important intellectual content: and (3) final approval of the version to be published. Authors should meet qualifications 1, 2 and 3. b. All individuals who qualify for authorship should be listed. However, any person can refuse to be an author if (s) he elects to do so. c. Each author should have participated sufficiently in the work to take public responsibility for appropriate portions of the content. d. Multi-center projects should identify the individuals who accept direct responsibility for the manuscript. These individuals should each meet all three conditions for authorship given above. When submitting a group authored manuscript, the corresponding author should clearly indicate the preferred citation and should clearly identify all individual authors as well as the group name. Other members of the group may be named in the acknowledgements. 2. Honorary or courtesy authorships are inconsistent with the principles above and are considered unacceptable. The following activities do not justify authorship: acquisition of funding, collection of data, general supervision of the research group, donation of materials, writing assistance and general support (e.g., provided by the departmental chair or laboratory head). 3. Contributors should be listed either in a byline for contributors, as requested by some journals, or in an acknowledgements section. Under either declaration, groups of persons who have contributed may be listed under a heading, such as clinical investigators or participating investigators. Further details of function or contribution may be described as in these examples: critically reviewed the study proposal, collected data, or provided and cared for study patients. Endorsement of the data and conclusions may Page 7 of 13

8 be inferred by acknowledgement and, therefore, all persons so listed must given permission to be acknowledged. Procedure to resolve disputes about authorship qualifications 1. When an individual believes that there will be or may have been a violation of the principles set forth in the policy section above, (s) he shall discuss such concern with the appropriate departmental chair. The departmental chair will investigate and attempt to resolve the concern appropriately and in a timely manner. 2. If consultation with the departmental chair does not resolve the individuals concern or if the concern involves the departmental chair, the individual and/or the departmental chair may raise the concern with the Research Affairs Committee (RAC) by submitting a written description of the concern and requesting consultation. The RAC will investigate and attempt to resolve the matter, which may include meetings with the individual who submitted the concern and/or with other individuals who may be involved. 3. If consultation with RAC does not resolve the individual s concern, the individual and/or the RAC may bring such a concern to the Dean of the Medical College of Wisconsin for resolution. In all cases, individuals who submit concerns in good faith will be protected from retribution of any kind. Subjects of allegations will not be subject to disciplinary or adverse actions until, and unless, it is determined that such action is indicated following thorough investigation and deliberation. In addition, to the extent possible with conducting fact investigations and as allowed by law, disclosure of information about the identity of subjects and informants will be limited to those who need to know. Submitted by The Research Affairs Committee For Consideration by the Faculty and Administration With eventual adoption as policy for The Medical College of Wisconsin April, 2005 Approved by the Faculty Council 5/18/2005 Voted for 25 and those voted against 3. Approved by the Executive Committee of the Faculty 12/13/05 Page 8 of 13

9 Frequently Asked Questions about the Health Care Industry Interactions Policy 1. Does this policy mean I can no longer conduct industry sponsored research? No. This policy does not limit an individual s ability to conduct industry sponsored research. 2. Does this policy prevent me from accepting Brewer tickets from a pharmaceutical company as part of an educational program I attend? Yes. Under the terms of this policy the Brewer tickets would be considered a gift. If you want to go to the event, you will need to pay for the ticket. 3. Does this mean I can no longer accept money from a device manufacturer to speak at an educational program? It depends. MCW covered persons may accept fair market value honorariums for speaking engagements provided the educational activity meets the ACCME standards. 4. Does this mean I can no longer accept money from a pharmaceutical vendor to give several of their canned presentations at dinner symposiums? Yes. The new policy follows the AAMC model which specifically prohibits Covered Persons from providing talks or presentations which were authored by someone else. Additionally, the new policy states that faculty should refrain from providing educational programming at events which do not meet the ACCME standards. 5. Does this policy prevent me from having a device representative set up the equipment prior to a surgical procedure? No. Device representatives may come into clinical areas for the purposes of assisting in set up or training around equipment which MCW has already purchased. If the representative will have patient contact in such an interaction the representative s presence must be disclosed to the patient and consent must be obtained. 6. I have been invited by XYZ device company to go to dinner with them to discuss a future consulting relationship. Can I let them buy me dinner and can I accept the consulting work? No and Yes. The new policy prohibits any MCW employee from accepting gifts from industry. A meal is considered a gift under this policy. So you can go to dinner but you need to pay for yourself. However, MCW does allow faculty to enter into certain consulting arrangements provided those arrangements are fully disclosed and managed under the MCW Conflict of Interest policy and Financial Conflicts in Research policies. Further, any external engagements should be approved by your department chair prior to commencing. Page 9 of 13

10 7. I am a researcher who works in the basic science building. Can I have an equipment vendor in the lab to show me their new line of products? Yes. The new policy only limits sales and marketing representatives soliciting products with direct clinical applications. Faculty members conducting basic science research which does not involve human subjects may invite vendors soliciting non-clinical products to the premises if they wish. Page 10 of 13

11 8. For the last three years pharmaceutical company ABC has given me $5,000 to host educational programming. Can I continue to accept their donations? It depends. The new policy specifically prohibits gifts to individuals. So you may not individually accept this donation for any reason. However, if ABC company makes their donation to MCW and their contribution is reviewed by the CME office and goes to support educational programming which meets ACCME standards, then we may accept the contribution. 9. I have been asked to speak at a seminar sponsored by the Bone Marrow Foundation, but I know they are accepting funding from many Industry Sponsors. Can I accept the speaking engagement? Probably. You need to confirm that the Bone Marrow Foundation is following ACCME educational standards for their program and if they are, you may accept the engagement and received fair market value for your services. 10. A local drug rep stopped by the clinic today with a tray full of doughnuts and bagels for the staff. Can I accept them? No. The new policy specifically prohibits food at any MCW Location, unless provided in connection with an ACCME accredited program. 11. The same drug rep also dropped off a box of free drug samples. Can I accept them? It depends. You may not personally accept free pharmaceutical samples. They are considered gifts under the policy. However, the Medical Director may accept the samples on behalf of the clinic, provided those samples are logged into the central tracking system. 12. Who do I contact if I have a question about a current or future activity? Contact the Office of Compliance at What happens if I accept a speaking engagement for a non-accredited program sponsored by Industry? You will need to report this action on your disclosure form. This form will be reviewed by your Department Chair and the Office of Compliance. Any concerns with your activity will be reported to the Department Chair and the senior leader. For Faculty, resident, student or fellow issues the senior leader shall be the Dean and for staff issues it shall be the Senior Vice President. Following a review of the matter, the senior leader may then refer the matter to an MCW Conflict Review Board. A Conflict Review Board is a panel of MCW faculty and/or staff who will review the reported activities and determine the appropriate course of action in consideration of what is in the best interests of the College. 14. What will happen to me if I fail to report my activities? Failing to report is a terminable offense. If you are faculty, your Department Chair will be monitoring your activities and if you fail to report as required under the policy they may seek your termination from the College. For students this responsibility will fall with the Dean of Academic Affairs, for residents and Page 11 of 13

12 fellows the responsibility belongs to the Executive Director of MCWAH, and for administration the responsibility resides with the Senior Vice President. If the governing individual seeks termination on this basis, they must still comply with the applicable MCW procedures in place for effecting a termination. In the case of Faculty, a for-cause termination would require the faculty member be provided written notice and the opportunity to appeal the decision before a panel of their peers. Further information may be found in the faculty handbook. 15. Currently, I have a contract to provide consulting services for a pharmaceutical company as a scientific advisor. Can I continue to perform these services under the new policy? Yes. However, you will need to report this arrangement on your disclosure form. 16. The new policy says I must receive fair market value for any services I perform for industry. What does that mean? Fair market value is considered the reasonable amount of compensation that should be provided for rendering a particular service. Therefore, in determining what the fair market value is for your service, an individual should consider what the standard hourly rate is for rendering this kind of service or what others in a similar situation would reasonably charge for the service. There is no exact formula that we are requiring individuals to undertake in determining this issue. Rather, it is a reasonableness test. Is the fee being proposed in reasonable relation to the service being performed compared to what the market would pay for that service. For example, charging $1500 for a speaking engagement would likely be considered reasonable, whereas charging $50,000 for a speaking engagement is probably not. 17. Can I have my travel costs reimbursed by a company I am consulting for as part of my work for them? Yes. If you have been retained privately by a company to consult for them, part of the agreement may be to provide for reasonable travel expenses incurred by you in performing those services. However, this would not include travel costs for your spouse or other members of your family. 18. How do I know if a contract for my services should be with MCW or one that I should make independently between the company and myself? You should start by discussing the matter with your Department Chair. If the service the company wants you to perform is substantially related to the work performed by MCW and it aligns with our organizational missions in furthering either clinical care, research, education or community service it may be appropriate to contract with MCW for the services you will provide. If the services to be performed are simply marketing related, or such that any expert in the field could perform the task and it does not assist in furthering the missions of the College than you should contract individually to perform the work. If you are uncertain of how a potential arrangement should be set up please contact the Office of General Counsel for assistance at What standards are we holding visiting professors or outside speakers to that come to MCW with regard to their promotion or sponsorship by industry? Visiting faculty should be expected to comport with any MCW standards of practice and policies while they are visiting our campus. Whether they are following good laboratory practices or providing an Page 12 of 13

13 educational lecture, they should not be providing a canned speech written by industry and they must follow the rest of the MCW policy requirements concerning food, gifts and industry representatives on our premises. 20. If our department has previously received funds from industry as unrestricted educational funds, can we still accept those funds? Yes. However, those funds must be reviewed and approved by the CME office and ultimately can only be provided to your department for educational content that complies with the ACCME standards, whether or not credit is awarded. 21. Currently, I am employed as a scientific advisor from a device manufacturer in addition to my employment at MCW as a full-time faculty member. Does this policy prevent me from continuing this arrangement? No. This policy does not address employment relationships with outside companies. However, the MCW Conflict of Interest policy specifically states no full-time or full professional effort faculty or staff members can accept employment from an outside employer without obtaining prior approval from MCW. Further, you will need to disclose this relationship on the reporting form as well. 22. I have had a long term relationship with a large device manufacturer for many years. Over time I have become very familiar with their products. Once a year they want to hire me to go and speak about my experience with their products to potential buyers abroad. Does the new policy prevent me from doing this? No. However, there are a number of things that you will need to be careful of in setting up this arrangement. Disclosure: First, you will need to disclose this engagement before you actually begin under the new policy. ACCME Standards: Additionally, the policy requires that any Industry sponsored events, meetings or conferences must be coordinated in a manner that complies with ACCME accreditation. So, you will need to examine how the program is being set up and ensure that it follows these standards. Separate Contract: Next, since helping a device manufacturer sell its products has no relationship to furthering the mission vision and values of MCW, it is probably not appropriate for a contract between the vendor and MCW. Rather, you will need to have your own private contract with them for services and receive fair market value for your time. No Endorsements: Finally, you need to be careful that your explanation of these products does not create a professional endorsement of the product. Pursuant to the MCW Conflict of Interest policy, MCW faculty and staff may not lend their name or provide a professional endorsement to products without first obtaining MCW approval to do so. Page 13 of 13