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Health Care Vendor Interactions: Difference between revisions
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Policy No.: '''8015'''<br /> | Policy No.: '''8015'''<br /> | ||
Effective Date: '''08/31/15'''<br /> | Effective Date: '''08/31/15'''<br /> | ||
Revised Date:<br /> | Revised Date:<br /> ''' DRAFT 07/17/18''' | ||
Reviewed Date:<br /><br /> | Reviewed Date:<br /><br /> '''07/17/18''' | ||
<big>'''Health Care Vendor Interactions Policy'''</big> | <big>'''Health Care Vendor Interactions Policy'''</big> | ||
== Policy == | == Policy == | ||
Health care vendors provide UNMC with information, products, services, and funding to further UNMC’s mission. Health care vendors’ promotional practices may influence health care providers’ treatment choices and the future practice of health care trainees. UNMC faculty, staff, students and trainees (“UNMC Personnel”) shall abide by this policy to minimize potential conflicts of interest that may result from interactions with health care vendors that could compromise patient safety, academic and research integrity, and the reputation of UNMC. This policy is intended to be consistent | Health care vendors provide UNMC with information, products, services, and funding to further UNMC’s mission. Health care vendors’ promotional practices may influence health care providers’ treatment choices and the future practice of health care trainees. UNMC faculty, staff, students and trainees (“UNMC Personnel”) shall abide by this policy to minimize potential conflicts of interest that may result from interactions with health care vendors that could compromise patient safety, academic and research integrity, and the reputation of UNMC. This policy is intended to be consistent within Nebraska Medicine policies, including MS40, [http://www.unmc.edu/hipaa/_documents/MS-40-NMC-Vendor-Policy-081315.pdf Pharmaceutical, Biotechnology, Nutritional Company, Pharmacy and Healthcare Service Vendors]. | ||
==Scope== | ==Scope== | ||
This policy applies to interactions between UNMC Personnel and health care vendors, both on-campus and off-campus, and includes interactions in support of clinical care, education, training and research. | This policy applies to interactions between UNMC Personnel and health care vendors, both on-campus and off-campus, and includes interactions in support of clinical care, education, training and research. | ||
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===Vendor Gifts and Donations=== | ===Vendor Gifts and Donations=== | ||
====Food==== | ====Food==== | ||
UNMC Personnel are prohibited from accepting food from health care vendors at activities held on-campus, including but not limited to meetings, grand rounds, educational events and vendor exhibits. | UNMC Personnel and students are prohibited from accepting food or monetary donations to purchase food from health care vendors at activities held on-campus, including but not limited to meetings, grand rounds, educational events and vendor exhibits. | ||
====Vendor Marketing Items==== | ====Vendor Marketing Items==== | ||
UNMC Personnel shall not accept either (i) gifts (e.g., gift baskets or event tickets) or (ii) marketing or other promotional materials (e.g., pens or paper pads) of any description from health care vendors. UNMC Personnel shall not permit health care vendors to leave any marketing items in any UNMC facility and shall promptly remove any such items. | UNMC Personnel shall not accept either (i) gifts (e.g., gift baskets or event tickets) or (ii) marketing or other promotional materials (e.g., pens or paper pads) of any description from health care vendors. UNMC Personnel shall not permit health care vendors to leave any marketing items in any UNMC facility and shall promptly remove any such items. | ||
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Unrestricted educational grants may be used to support UNMC-sponsored accredited continuing education. Such support for UNMC accredited continuing education must be initiated through the appropriate UNMC accredited provider who will then submit the application for support. Once a grant is approved by a vendor, the letter of agreement must be signed or electronically accepted by Business & Finance authorized personnel. Any health care vendor funding for UNMC accredited continuing education programs shall be transferred directly to the UNMC accredited provider which then has the responsibility for disbursement and reconciliation of the funds. All vendor support for accredited continuing activities shall be recognized in materials distributed to participants. | Unrestricted educational grants may be used to support UNMC-sponsored accredited continuing education. Such support for UNMC accredited continuing education must be initiated through the appropriate UNMC accredited provider who will then submit the application for support. Once a grant is approved by a vendor, the letter of agreement must be signed or electronically accepted by Business & Finance authorized personnel. Any health care vendor funding for UNMC accredited continuing education programs shall be transferred directly to the UNMC accredited provider which then has the responsibility for disbursement and reconciliation of the funds. All vendor support for accredited continuing activities shall be recognized in materials distributed to participants. | ||
====Paid Attendance at Conferences==== | ====Paid Attendance at Conferences==== | ||
UNMC Personnel may not accept payment or reimbursement of expenses or other funding from health care vendors in compensation for attending vendor-specified conferences or meetings if such attendance is solely in a passive capacity (e.g., not | UNMC Personnel may not accept payment or reimbursement of expenses or other funding from health care vendors in compensation for attending vendor-specified conferences or meetings if such attendance is solely in a passive capacity (e.g., not engaging in permitted presentations or otherwise providing conference services). UNMC Personnel are reminded that the Federal Anti-Kickback statute prohibits acceptance of in-cash or in-kind remuneration from a health care vendor that may intend to induce the purchase or prescribing of the vendor’s products | ||
====Equipment Loans and Donations for Education Training and Research==== | ====Equipment Loans and Donations for Education Training and Research==== | ||
Departments may not accept equipment and other training materials for educational and research purposes, whether donated or loaned, from health care vendors, unless such acceptance is in compliance with this paragraph and consistent with this policy. Any such donations or loans shall be made to the department and not to individual UNMC Personnel. Receipt or acceptance of the same shall only be upon execution of appropriate agreement which shall include any agreements for any certified/accredited continuing education provider. Agreements shall be signed by the appropriate signatory in accordance with [http://nebraska.edu/docs/president/14%20Authority%20to%20Approve%20Contracts.pdf Executive Memoranda 14]. | Departments may not accept equipment and other training materials for educational and research purposes, whether donated or loaned, from health care vendors, unless such acceptance is in compliance with this paragraph and consistent with this policy. Any such donations or loans shall be made to the department and not to individual UNMC Personnel. Receipt or acceptance of the same shall only be upon execution of appropriate agreement which shall include any agreements for any certified/accredited continuing education provider. Agreements shall be signed by the appropriate signatory in accordance with [http://nebraska.edu/docs/president/14%20Authority%20to%20Approve%20Contracts.pdf Executive Memoranda 14]. | ||