Conflicts of Interest
Guidelines for Vendor Relationships
Answers to Frequently Asked Questions
Vendor Sponsorship of Mount Sinai Events and Activities
Q: Under what circumstances is it permissible to seek or accept commercial support for Mount Sinai events?
A: Corporate support should only be sought and/or accepted for educational activities - vendor support cannot be solicited/used for holiday parties or other activities whose primary purpose is not educational.
The Postgraduate School has comprehensive guidelines for commercial support of educational activities that fall under the umbrella of Continuing Medical Education (CME).
For non-CME events, when the target audience for educational activities includes Mount Sinai trainees, faculty or staff, vendor donations must be deposited into a general education account within the department and the Chair or designee will determine how the money is spent. Checks should be made payable to Mount Sinai.
For community-focused educational events, e.g. health fairs or school programs, a Department may seek support for specific activities; the Vendor Policy does not prohibit collaboration with industry for such programs.
Q: What are the guidelines for preparing and submitting proposals for commercial support for educational events for patients or the community?
A: Proposals for commercial support of educational events for patients or the community, e.g. health fairs or school education projects, should be developed in accordance with the following guidelines:
- The proposal must be written, not verbal. It should include:
- Description of the planned educational event
- Amount of support that you are seeking
- Description of the ways in which support will be used, e.g. production of educational materials, honoraria for guest speakers
- Standard language that must be included in the proposal:
- "This request for support does not in any way represent a commitment on the part of Mount Sinai to purchase any goods or services offered by your company."
- "Mount Sinai will acknowledge your company as a supporter of the event but will not identify any of the specific products or services offered by your company."
The proposal and the list of targeted vendors must be approved by the Department Chair or his designee.
- The proposals must be distributed to a broad base of potential funders - ideally, you will reach out to at least ten companies.
- If the target company has a philanthropic branch, the proposal should be submitted to that group rather than to the marketing branch or to a sales representative.
Q: The Acme Corporation, which supplies numerous products to our department, wants to give the department an unsolicited, unrestricted $50,000 grant to support our activities. Is this allowed?
A: Corporate support should be earmarked for research or educational activities, and within these categories should be specific; for example, support for research should specify the scope of work, with a financial commitment consistent with that work. More generalized support could be construed as a kickback. Funds secured for research and education must be utilized for and accounted for those purposes. If your department wishes to seek and accept external support for its research and educational activities, we strongly recommend working with the Development Office to pursue a broad-based solicitation to as many companies as possible. If the target company has a philanthropic branch, efforts should be directed to that group rather than to the marketing branch or to a sales representative.
Q: Can a sales rep pay for food or provide food for our journal club if he uses his own credit card?
A: Vendors cannot give money for a specific educational event for faculty, staff or trainees, nor can they pay for or provide food/beverages for the event. All vendor donations should be in the form of checks made payable to Mount Sinai, and should be deposited into a general educational or research account in the department; ideally, such donations will be made by the corporate giving branch of the company rather than through an individual sales rep.
Q: The Acme Corporation has been sponsoring a monthly seminar series in our department for years. Is this a problem?
A: Vendors may no longer donate money for a specific educational event for Mount Sinai faculty, staff or trainees. They can donate to a general educational fund within your department, and your Chair will decide how to use the money. This arms-length relationship will ensure that the department retains control over the types and content of educational activities held in your department.
Q: Can a company arrange for a speaker to present at an event in our department?
A: No, a vendor should not arrange for or pay for speakers at departmental events. Vendors may not be involved in the selection of speakers, materials, venue or content of our educational activities.
Q: Can a sales rep attend our journal club as a silent observer?
A: Sales reps should be discouraged from attending department events, especially educational events. Their attendance would create a vendor presence that could be influential, particularly for events targeting trainees, the group perhaps most vulnerable to influence.