Conflicts of Interest
Guidelines for Vendor Relationships
Answers to Frequently Asked Questions
Off-Campus Events and Activities
Q: When I attend professional conferences can I accept give-aways from exhibitors?
A: Only items with a clear educational value AND modest financial cost should be accepted. Accepting other items, even trinkets such as pens, mugs and calendars, is not permitted. Pens and pads distributed at a meeting for note-taking can be used at the conference but should not be brought back to Mount Sinai for use here.
Q: I have been invited to lecture in a non-CME course sponsored by the Acme Corporation, and will be paid an honorarium. Whose permission do I need?
A: You should only consider giving the lecture if there is a legitimate educational value to the course. If there is, your lecture must reflect your own work, and cannot be designed to sell Acme Corporation's products. If you will be paid for this speaking engagement, you must abide by Mount Sinai's Policy on Financial Relationships with Extramural Entities including obtaining pre-approval from your Chair. Further, if the event is held outside the tri-state area you will need to submit an electronic travel request form prior to departure, consistent with Mount Sinai's travel policy.
Q: A pharmaceutical company has offered to pay my travel and registration expenses for a conference it is hosting. Is this permissible?
A: Events hosted by commercial entities must have a clear educational value and should be held in a reasonable venue - your Chair or departmental designee should evaluate the invitation with you. If your attendance at the conference is approved, you (or your department) should pay the associated costs, e.g. food, transportation; only if you will present or will otherwise significantly participate in the event would it be permissible for the company to cover your expenses. If you will be paid to present, be sure to get prior approval from your Chair in accordance with Mount Sinai's Policy on Financial Arrangements with Extramural Entities. Note that if the event is outside the tri-state area you will need to submit an electronic travel request form prior to departure, consistent with Mount Sinai's travel policy.
Q: I have been invited to a dinner presentation that a biotech company is holding near Mount Sinai. Can I go?
A: Presentations and conferences must have a clear educational value that justifies your attendance. They must also be held in settings that are appropriate to the purpose; i.e., the setting should not be used as an inducement for your attendance; a four-star restaurant, for example, would be excessive. Meals sponsored by vendors tend to be product-specific and designed more as sales vehicles than as balanced educational events. Your Chair or departmental designee can help you to evaluate the invitation. Unless there is compelling evidence that this is an appropriate educational event, we recommend declining. If you do go, you (or your department) should pay for the meal, since if the company paid it would be considered a gift.
Q: Two other physicians and I have been invited to dinner at an upscale Manhattan restaurant by the vendor representative of a home infusion therapy company. Since our practice refers many patients for home care, we are interested in learning about his company's services. Can we go?
A: Such an invitation is problematic. If after the dinner you decide to give the company's services a try, the high cost of the meal could be construed as a "kickback" to you for referring patients to this company for home infusion services - it would be not only inappropriate but also illegal. If you are truly interested in learning about the company's services, you can invite the vendor to your office for a straightforward business meeting.
Q: As a manager, I am responsible for purchasing decisions for my unit. I have become so knowledgeable about the products we use that one of our vendors has offered to pay me to visit other institutions on my own time to help implement the vendor's program at those locations. Can I do this?
A: If your Mount Sinai job entails making decision about the purchase and use of a vendor's products, then receiving payment from the vendor for off-campus work would create a conflict of interest that is a violation of Mount Sinai policies. Any time you consider doing work outside the scope of your full-time employment, you are expected to notify your supervisor or Chair to ensure that the arrangement can be evaluated to avoid or manage any potential conflict of interest. Outside arrangements should also be noted on your annual conflict of interest disclosure report.
Q: I have been asked to serve on the scientific advisory board of a start-up company that doesn't currently do business with Mount Sinai. The company manufactures products similar to those used on our campus, but I don't have a role in the purchase or use of those particular products. I have been offered compensation and stock options. How do I make sure this arrangement complies with institutional policies?
A: Mount Sinai's Policy on Financial Arrangements with Outside Entities provides details for faculty on the review and approvals that must be obtained before the arrangement is finalized. Staff should work with their Department Heads to ensure that appropriate review and approval takes place. If your responsibilities at Mount Sinai include making purchasing decisions relating to the type of products made by the company - even if you don't currently purchase the specific items made by the company - the potential for a conflict of interest will likely mean that you either can't serve on the board or you must recuse yourself from any possible purchasing decisions involving products of the company or its competitors.