Frequently Asked Questions Regarding
Policy on Faculty Disclosure of Industry Relationships
to Students and Trainees
Q. Why was this policy implemented?
A. We believe that the best way to promote an ethical and transparent culture in research, clinical care, and teaching is to ensure that students and trainees have this information. Medical students nationwide have requested information regarding the industry relationships of their clinical mentors. The values of medical professionalism, integrity of scholarship, and scientific integrity benefit from transparency to the extent possible.
Q. Is this policy meant to convey that the Medical School discourages faculty relationships with industry?
A. No. UMMS faculty members interact with pharmaceutical, device, and biotechnology companies to improve patient care and develop new therapies. We encourage these relationships when they align with the mission and goals of the Medical School.
Q. Does industry funding of research create a potential conflict of interest for a faculty investigator?
A. Not necessarily. However, please note that this policy does not speak to conflicts of interest; rather, the policy promotes transparency about industry/faculty relationships, which does help respond to societal concerns about conflicts of interest (COI). We believe that being clear and forthright about all industry/faculty relationships will alleviate worry and concerns that students and trainees may have about COI.
With regard to the small number of industry-funded studies where one or more of the investigators also have an outside interest in the funding company (such as a consulting contract or equity) and do present a conflict of interest, the Medical School Conflict of Interest Board (MEDCOI) manages those conflicts.
The disclosure to students and trainees called for in this policy mirror those currently made in the informed consent documents for research subjects. The consent form clearly states which party (e.g. NIH, Pfizer, GE) sponsors the research. In another section, the form conveys who could profit from the research.
Q. How did this policy come about?
Dean Woolliscroft charged the Medical School’s Clinical & Educational Conflict of Interest Committee with developing recommendations about how to protect patients, students, and faculty from allegations of impropriety in education and clinical care. This new faculty disclosure policy was recommended by the Clinical & Educational Conflict of Interest Committee and approved by the Executive Committee of the Medical School and the Dean.
Q. Do I have to make a statement in a lecture hall presentation if I don’t have any industry supported effort, research, or outside interests?
A. Yes. If you have no industry relationships, that is what you should disclose. Click here for a sample PowerPoint slide.
Q. Do I have to make a statement everytime I present in a lecture hall?
A. It depends; if you repeatedly speak to the same students and trainees, you need only make the disclosure once. If you were teaching a course over a semester or weeks, for example, you need only make the disclosure once; if it is a course, rather than a one time presenation, you also have the option of making the disclosure in the syllabus or via an email to your class. If you are speaking to a new group of students each time you are in the lecture hall, then you would make the disclosure each time.
Q. Do I have to make a disclosure if I have an industry relationship but it is not related to the topic of my talk?
A. Yes. The policy sets a universal standard for sharing information.
Q. Can I also disclose effort or research support that is not industry related such as NIH funding?
A. Yes, but it is not required. If you disclose both, list the industry-funded research first, then other funding in the same manner (e.g. same font size). Or you could list your research chronologically regardless of funding.
Q. Is there a sample disclosure?
A. Yes. Click here for a sample PowerPoint Slide sharing an industry relationship and here for a sample PowerPoint slide stating you have no industry relationships.
Q. How do I make my disclosure to students and trainees outside of the lecture hall?
A. You can make a verbal disclosure early in your relationship with the student/trainee(s). One method of making a disclosure without having to repeat yourself is to put the disclosure in an email to a group or build it into a syllabus.
Q. I interact with some students briefly or intermittingly. How do I handle those situations?
A. In these situations you may use your discretion in determining if, when, and how to make disclosures. You should balance the disruption created by making a disclosure, and the time it may take away from other learning, against the value of transparency.
Q. Do I have to submit documentation that I’ve made the required disclosures?
A. No.
Q. What does “industry” mean in this context?
A. “Industry” includes pharmaceutical or medical device manufacturers, biotechnology companies, other medical suppliers; or healthcare related service or equipment providers that do business with or seek to do business with UMHS. It does not include insurers such as Blue Cross Blue Shield.
Q. I receive funds from industry but not for any sponsored research projects. Do I have to disclose anything about these funds?
A. Yes. You must disclose “effort supported by Industry” which means gifts or grants from industry provided to the University or a Department to support a designated faculty member’s academic endeavors, laboratory, travel to attend a professional meeting, or other similar activities.
Q. Does that mean I have to disclose all the money my Department gets from industry?
A. No. You would only disclose these funds if you were the particular recipient designated to use the funds.
Further information:
- Regulatory Affairs Website: http://www.med.umich.edu/medschool-regulatory/index.htm
- UMHS Conflict of Interest Website: http://www.med.umich.edu/u/compliance/area/coi/index.htm
- Clinical & Educational Conflict of Interest (CECOI) Committee membership – http://www.med.umich.edu/medschool-regulatory/CECOIC.html
- Conflict of Interest Board (MEDCOI) – http://www.med.umich.edu/medschool-regulatory/medcoi.htm
- Prohibition of Industry Sponsorship of CME policy – http://www.med.umich.edu/medschool-regulatory/Policies/CME_Industry_Funding.pdf
- Ghostwriting/Guest Authorship policy – http://www.med.umich.edu/medschool-regulatory/Policies/Ghostwriting_Policy_1-13-11.pdf
- IOM report on Conflict of Interest in Medical Research, Education, and Practice –http://books.nap.edu/openbook.php?record_id=12598
Updated 8/15/11
