Conflicts of Interest
Interactions with Vendors and Other Commercial Entities
Some pharmaceutical companies, device companies or other commercial entities maintain Speakers Bureaus and/or sponsor events designed to disseminate information relating to their products and services. These companies often seek to hire medical school faculty as lecturers because they are experts in particular disease entities and can add credibility to an event. Because events sponsored by commercial entities may be perceived as venues to influence participants in their relationship with the company, it is essential that faculty and staff participate in such events only when there is a legitimate educational purpose, the individual's role is meaningful and substantive, and the content is within the individual’s field of expertise. For full-time faculty, all paid speaking engagements are subject to prior approval as described in the MSSM Policy on Relationships with Outside Entities (scroll down to section E) and must be disclosed on their on-line Annual Report of Outside Relationships.
Continuing Medical Education (CME) events are subject to strict guidelines issued by the Accreditation Council for Continuing Medical Education, so you can be confident of the educational value of the activity. Sometimes CME events are coordinated by “medical education and communication” companies which must uphold the standards required of all CME courses.
If the proposed event does not offer CME credits, then you will be expected to provide alternative evidence to your Chair or supervisor that there is a legitimate educational value to the event. Key considerations in evaluating a corporate invitation to give a presentation that is not part of a CME event include:
- Is there a marketing message in the talk that you are being asked to give and/or in the overall event? A fair and balanced presentation can typically be distinguished from one that resembles a marketing tool for the company. MSSM faculty and staff are prohibited from performing product or company endorsements. Although legitimate presentations sometimes involve reporting research project results and mentioning a particular product or technology, this is quite different from talks and events that are marketing in nature.
- As a speaker would you be able to use your own materials without control of the content by the sponsor? Talks in which sponsors exert significant control over the content are prohibited. Use of materials that are not your own is strongly discouraged; occasionally an illustrative slide prepared by the vendor might be acceptable if it has an educational and not a marketing value, but the majority of the presentation should be your own. The use of ghostwritten materials is strictly prohibited.
- Is the proposed payment to you fair and reasonable? Faculty and staff are expected to accept compensation only if it reflects fair market value, i.e., the payment is reasonable in relation to the services rendered, and resembles what others with similar expertise might be paid for a similar work effort. The “fair and reasonable” test also applies to coverage of travel expenses such as airfare and hotel Your Chair can help to assess whether the proposed payment seems appropriate.
- Will the payment for your services come directly from a commercial entity, or will it be paid by an academic medical center? Direct payments from vendors may indicate that the event is designed to promote the goals and objectives of that vendor and are discouraged. Clear disclosure of the source of payment for your presentation must be made to your Chair/supervisor and to your audience in order to promote transparency.
- Is the program venue appropriate to the purpose? Typically events that are truly educational take place in settings that are appropriate to the learning experience. If the proposed event will be in an extravagant or exotic location, it is less likely that education is the primary purpose of the event, and it should be avoided.