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Health Care Vendor Interactions: Difference between revisions
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<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 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 with similar provisions in Nebraska Medicine policies, including MS.40, “Pharmaceutical, Biotechnology, Nutritional Company, Pharmacy and Healthcare Service Vendors” policy (MS40). | ||
==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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Health care vendors are not permitted to visit UNMC Personnel on campus without proper identification and prior approval from a faculty member or non-faculty manager. Health care vendors visiting Clinical Enterprise departments shall register in REPtrax and follow MS40. Health care vendors attending UNMC vendor fairs are required to register with the UNMC Procurement Department. | Health care vendors are not permitted to visit UNMC Personnel on campus without proper identification and prior approval from a faculty member or non-faculty manager. Health care vendors visiting Clinical Enterprise departments shall register in REPtrax and follow MS40. Health care vendors attending UNMC vendor fairs are required to register with the UNMC Procurement Department. | ||
====Trainees==== | ====Trainees==== | ||
===Vendor Gifts and Donations | Health care vendors shall not contact UNMC Personnel who are residents, students or trainees, except where such contact is incidental to (i) invited attendance at either (a) departmental educational events or (b) in-service training scheduled by UNMC faculty or managers, (ii) attendance at UNMC-sponsored vendor fairs, or (iii) attendance related to clinical care if and only if the health care vendor is part of the health care team related to that clinical care (e.g. implant vendors). | ||
===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 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. | ||
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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 presenting 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. | 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 presenting 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 Executive | 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]. | ||
====Drug and Nutritional Samples==== | ====Drug and Nutritional Samples==== | ||
UNMC Personnel shall follow The Nebraska Medical Center “Drug and Nutritional Samples” policy (MS.02). | UNMC Personnel shall follow The Nebraska Medical Center “Drug and Nutritional Samples” policy (MS.02). | ||
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*Contact the [mailto:tscrogin@unmc.edu Compliance Officer]. | *Contact the [mailto:tscrogin@unmc.edu Compliance Officer]. | ||
*UNMC Policy No. 8010, [[Conflict of Interest]] | *UNMC Policy No. 8010, [[Conflict of Interest]] | ||
*UNMC Policy No. 1049, | *UNMC Policy No. 1049, [[Outside Employment]] | ||
*University of Nebraska [http://nebraska.edu/docs/president/14%20Authority%20to%20Approve%20Contracts.pdf Executive Memoranda 14] | *University of Nebraska [http://nebraska.edu/docs/president/14%20Authority%20to%20Approve%20Contracts.pdf Executive Memoranda 14] | ||
*Board of Regents Policy 3.3.9, “Endorsement of Commercial Goods and Services by the University and University Staff | *Board of Regents Policy 3.3.9, “Endorsement of Commercial Goods and Services by the University and University Staff | ||