UF Conflict of Interest (COI) Policy and Graduate Medical Education – FAQ
This page will address commonly asked questions regarding the impact of the COM COI Policies on the conduct of GME programs. Additional questions / topics may be added by the COI Program Director, Mr. Gary Wimsett. In addition, if you have any questions you would like addressed in this forum, please email Mr. Wimsett (firstname.lastname@example.org) or the DIO (email@example.com). This page will focus on how you, as program directors, can legitimately utilize industry support for your training program in a manner consistent with UF policies. Please note, that with appropriate planning and guidance, most important activities for your program that were supported by industry in the past may still be supported. Planning is the key word!
1. May companies fund visiting professors lecturing in a residency training program – if so, how? If the speaker and the topic of the lecture are chosen by the training program AND no company provided educational material is presented at the lecture, then the speaker may have his / her expenses reimbursed by a company. However, company speakers bureau activities MAY NOT be sponsored by any training program (i.e. – no company reimbursed speaker may come to your program to give a lecture on a new product sold by the company). A better procedure is to invite companies to contribute to a restricted grant to a training program, managed by the University of Florida Foundation, which will provide travel / honorarium funding for speakers chosen by an individual training program (see FAQ #6 below).
2. May companies provide expense money or directly provide refreshments for conferences given in a residency training program? If so, how? Such funding may be done ONLY through a restricted grant process. Companies MAY NOT directly provide food or drinks for educational activities. Companies may contribute to a restricted grant as described in #1 above specifically designated for an individual GME program. Reasonable expenses for food / drink (consistent with UF Policy) may be reimbursed from this fund.
3. May companies provide gifts – even such trivial items as pens, coffee mugs, etc – to housestaff. May companies provide educational materials such as textbooks to housestaff? Companies may never provide items such as pens, coffee mugs, etc to housestaff or to any support staff / faculty in a GME program. However, should a company wish to provide non-company related educational materials such as textbooks, DVDs, support for simulation education or any other educational support, they may do so once again through the restricted grant process administered by the University of Florida Foundation (see FAQ #6 below).
4. May industry fund residency or fellowship training positions in established GME programs? If so, how? Yes, industry may fund residency and fellowship training positions, provided that funding is provided through a restricted grant process (see FAQ #6 below) and not tied in any way to the use of the company’s product(s).
5. May industry fund travel / lodging for residents and fellows going to meetings? If so, how? Industry may only provide funding for residents / fellows attending meetings by contributing to a restricted grant to a fund set up by a training program for that purpose (see FAQ #6 below).
6. How are restricted grants established for all these purposes? Please work directly with Mr. Wimsett’s COI organization to establish the fund for the purpose that your training program desires. There may be more than one fund – for example – resident travel fund; resident book fund; resident research fund; resident didactic program fund; residency visiting professor program; and many others. Mr. Wimsett’s group will help you establish and monitor the fund in the University of Florida Foundation. An individual in your department will be appointed to administer the fund in a fashion consistent with the COI policy and will work together with the COI group to be certain that all regulations are followed.
7. May a company sponsor a visiting professor (inventor or advanced user) to provide inservice training regarding the indications and proper use of a newly purchased product and provide educational material / psychomotor skills training, etc relevant to the use of this product? While on-site training is certainly appropriate under certain circumstances, the parties (UF and the company) should submit a brief description of the training for review and approval by the Industry Academic Relations Committee. This helps us ensure that Shands and/or UF policies as to the presence of reps in certain areas are understood and followed. So, in short, in-service training is permitted (and often necessary and/or mandated by the FDA) but we’d like to know about it and help the parties arrange the training to comport with relevant UF and Shands policies.