Faculty participation in industry-sponsored Speaker’s Bureaus or similar industry-funded groups is not allowed. Faculty participation in industry-sponsored events whose primary purpose is marketing is not allowed. Any industry-sponsored speaking engagements must have a legitimate educational purpose and be non-promotional in nature. Speaker presentations must be within an individual’s field of expertise, be fair and balanced, and focused primarily on disease-state material. Speakers must develop their own speaking material and have control over the content of the presentation.
For full-time faculty, all non-CME paid speaking engagements require a written agreement with the sponsor and are subject to prior approval as described in the ISMMS Policy on Financial Relationships with Outside Entities (“Consulting Policy”) and must be disclosed on their Disclosure Profiles via the Electronic Disclosure Management System (“eDMS” - https://edms.mssm.edu).
Continuing Medical Education (CME) events are subject to strict guidelines issued by the Accreditation Council for Continuing Medical Education to ensure 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.
Important considerations for faculty engaged in non-CME paid speaking:
- Is the proposed speaking activity approved by your Department Chair or Institute Director?
- All proposed speaking engagements for industry must be approved by your Department Chair or Institute Director and a signed Attestation of Compliance (“Attestation Form”) must be submitted to the COI Office as part of the review process.
- 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. Talks that endorse the use of a specific drug, diagnostic, or device are not allowed. Although disease state talks can involve reporting specific research results, all research findings must be discussed in the context of the competing drugs/devices/ products currently approved as well as those in development.
- Do you have control over the content of the talk?
- Talks in which sponsors exert significant control over the content are prohibited. Occasionally an illustrative slide prepared by the company might be acceptable if it has a clear educational value, but the overwhelming majority of the presentation should be content that you have personally developed. In addition, you must have final control over the content of the presentation. The vendor/company may review and have the right to approve the presentation solely for purposes of compliance with FDA regulations or the regulations of other applicable oversight/regulatory bodies. 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 require a written signed consulting agreement that includes the Mount Sinai Uniform Provisions for Consulting (Addendum) that has been reviewed and approved by the COI Office. Clear disclosure of the source of payment for your presentation must be made to your audience in accordance with Mount Sinai policies that 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. All consulting agreements should explicitly state the venue and any travel related reimbursement.