How will our faculty members react to the introduction of new or strengthened policies?
Most institutions with strong policies report that their faculty members accept and support limits on industry relationships. While some restrictions may initially meet with resistance or complaints, faculty members generally adjust quickly to these new expectations for conduct. In the past few years, policies have been improving nationwide. It is very rare for a faculty member to depart an institution because of its CCOI policies.
How can we develop a strong policy pertaining to clinical conflicts of interest?
A strong policy must originate with the administration: the support of institutional leaders is fundamental to a policy’s success. The administration should establish a clear timeline for policy development and introduction, in order to prevent the policy from languishing in the development stage. Most institutions establish committees dedicated to policy development. The members of these committees should be appointed based on their qualifications and expertise. Institutions should avoid soliciting volunteers, as committees formed via self-selection may be biased or unrepresentative.
How can we effectively enforce our policies?
Most policy violations are inadvertent, emerging out of ignorance or misunderstanding. Therefore, it is important for institutions to educate their faculty on any new or changing policies. The compliance office should establish avenues of communication with faculty in order to preempt violations and resolve confusion; however, repercussions for violations should be clearly outlined and evenly applied. The function of the compliance office is to aid faculty in navigating industry relationships. The office should serve as an ally rather than an adversary. Many institutions have found that stringent policies are easier to implement and enforce than lax policies because they are less likely to be misinterpreted.
How will a stringent conflict of interest policy affect our faculty members’ ability to collaborate with industry?
The purpose of a conflict of interest policy is not to reduce collaboration with industry, but rather to establish clear standards for its conduct. A strong CCOI policy will protect the interests of patients and prevent the appearance or reality of impropriety. Appropriate relationships with industry should continue to be permitted and encouraged. In order to facilitate collaboration, the administration should establish channels for the prompt review and evaluation of consulting arrangements between faculty and industry.
How can we compensate for reduced CME funding/limits on meals/restrictions on sample medications?
Please refer to our Best Practice Guides for information on individual policy areas. The guides contain background, model policy language, and suggestions for implementation.