Conflict of Interest Policy FAQs
The payment of expenses to national conferences is prohibited by uOttawa, CMA and Rx+D (organization representing Pharma Industry) policy. While Rx+D policy allows Industry to send physicians to international conferences, this is not acceptable according to the uOttawa policy which considers all such funding as gifts to physicians. Reporting the highlights to colleagues is not considered an allowable consultative relationship with Industry for which physicians may receive compensation and expense remuneration. Therefore, faculty members should decline this offer from Industry.
It is common for Departments/Divisions to financially support their residents/fellows who attend meetings especially when they are presenting their research. Industry has often offered to help support this important aspect of resident/fellow training. While direct Industry sponsorship is not allowed, Industry may provide educational grants to departments/divisions in the same way that grants are provided for other educational events/activities. Resident/fellow expenses should be paid by the department/division. The department/division should acknowledge the funding which should ideally come from multiple Industries.
In general, Faculty members and trainees should attend only accredited programs which have been assessed for the content and process according to Royal College of Physicians and Surgeons of Canada or College of Family Physicians of Canada standards.
The policy defines a gift as anything of value that is received personally without any work being done in return. Essentially any gift can result in a sense of reciprocity to the giver and this result in a conflict of interest when dealing with Industry. Ideally, gifts should not be accepted and work done for Industry should be reasonably compensated preferably governed by some written agreement.
The off campus meetings referred to in the policy are those which are planned and funded solely by Industry and faculty members should not attend these – meals and consumables provided at these functions are considered gifts and the content is often biased in favour of the sponsor thereby presenting a conflict. Off campus meetings sponsored and planned by academic/physician's professional societies may be supported by Industry grants and can be attended by Faculty members and trainees because they are planned and controlled by the professional society or physician organization.
Many important developments for improving patient care have resulted from interactions between physicians/researchers and Industry. The policy is not meant to prevent this interaction but rather to provide guidance and protection for Faculty members from inappropriate conflicts of interest affecting judgement in administering patient care, conducting research and educating students. While funding independence is the ideal, research and education benefit from external funding since our current funding structure cannot support these activities alone. Funding from Industry can be accepted provided it is received institutionally (ie through a division, department or faculty office), is fully transparent and accountable and is at 'arms-length' (funding not dictating the research or educational activities or patient care).
Clearly, the intention of samples is for a specific brand of drug to go home with a patient along with a prescription which then tends to get refilled. While benefit to needy patients can justify continuing this practice, the presence of samples do likely bias the choice that physicians make in prescribing drugs. The policy does not suggest a ban on the use of samples; rather it requires there be a process in the documentation and dispensing of these drugs. Physicians are actually taking this responsibility on when they provide samples; so it is important to document pertinent drug information on patient charts. If used within a hospital, the pharmacy should be involved with regulation on the use of samples.
Education sessions should not be biased either during the planning cycle or during its delivery. Industry should not be helping with decisions regarding what topics are chosen and who presents the material. Similarly during the presentation, the presence of Industry reps can potentially bias what is being said either with the content or in its delivery. Therefore the participation of Industry reps should be avoided. Physicians/researchers do not have any direct Faculty responsibility to teach Industry reps but education can be provided in a consultative relationship with appropriate agreements and compensation outside of Faculty facilitie.
However, in specific cases where Industry reps may be invited by departments to attend a session for a variety of reasons, the speaker(s) and audience should be aware of their presence and ideally, the reps should sign an agreement of non-participation in the discussion/interactions.
The question should likely be rephrased as "why would Industry reps want to participate in a program that did not pertain to them directly" and "what benefit can they derive from interacting with physicians and trainees". The reality seems to be that the important social relationship developed at these events is advantageous to Industry reps and the marketing of their products.
In specific cases where a department may invite Industry reps to an event, the speaker and audience should be made aware of their participation.
The policy indicates that Industry funding can be accepted to support CME activities provided the funding comes as an education grant. These funds can be used by the division/department for education purposes for venues, speaker expenses and appropriate food and beverages. The benefit for Industry is that they can be recognized as a company that supports physician education. Most Industry understands the evolving standards for funding and relationships with physicians as indicated in Rx+D's "Code of Ethical Practices". Funding will likely continue but the reality is that physicians/researchers must adapt as well and take more financial responsibility for their own education.
A textbook provided by industry is a gift unless there is an evaluation component, ie. You are providing a critique/review about the book. Since decisions to use one textbook over another made by faculty members will affect students, a decision may be influenced by receiving a book as a gift from the publisher. APUO professors are provided a stipend to cover professional expenses which include textbooks required for their teaching so free textbooks are not necessary for faculty to teach. Some departments may also cover the cost of the text books. If a textbook is received, unsolicited, it is a good practice to place this in the departmental library as a resource for ALL faculty and students. Clinical professors should not receive textbooks as gifts from Industry.
Research grants are provided to a laboratory or division or faculty and not given for the personal use of the researcher. These are not gifts as defined by the Industry interactions policy. Research grants must be accepted under the terms of the granting policy of uOttawa which requires that grants be administered through faculty/division/department research accounts at arms length from the researcher. Legitimate research grants require deliverables unlike gifts which are provided to an individual for their own use without an explicit deliverable. The policy states that research grants can be accepted from Industry provided they are held in accounts that are governed by rules of either the Faculty, Research Institute or Hospital. Financial relationships with industry must be transparent and disclosed annually to the Office of Professional Affairs.
Residents and graduate students are expected to develop an understanding of university/laboratory/hospital policies with the guidance of their supervisors. As experience is gained with appropriate relationships with Industry, residents and graduate students may have increasingly independent interactions with Industry representatives just as they would be expected to perform their clinical/research responsibilities with progressively less direct supervision. The appropriate degree of interaction must be determined by the supervisor. Medical students should only interact with Industry representatives under the direct supervision by their supervisors.
With specific reference to the Industry Relations Policy, a gift is considered to be something that you receive from Industry for which you are not providing any service. These gifts may actually or potentially or be perceived to influence your delivery of patient care, instruction to students or interpretation of your research. Therefore gifts from Industry should not be accepted. Research grants, drugs, research materials are given to researchers for their research and not their personal use – these are not "gifts". Any items received from Industry for research use should be properly accounted for and documented. They should not be accepted if they might be result in any real or potential bias in the bahaviour of the researcher. Consultation stipends, honoraria for speaking, and related travel expenses are considered acceptable payments for services provided by faculty members and are not gifts.
If you have any question regarding the Industry Relations policy, it is probably relevant to other members, staff and student. Please send in your questions to the Office of Professional Affairs to be answered and posted on the website. Thank you.