The purpose of this policy is to present guidelines for resident physicians, faculty
and staff to follow in their interactions with industry representatives. Full and
appropriate disclosure of sponsorship and financial interests is required at all program
and institution sponsored events.
It is the responsibility of the program director to determine which contacts between
resident physicians and industry representatives may be suitable, and exclude occasions
in which involvement by industry representatives or promotion of industry products
- PCOM expects all vendors, contractors, and other agents to comply with applicable
laws and regulations when providing their services to and/or for us.
- Resident Physician, faculty and staff will not accept nor offer money or gifts to
patients or their families in exchange for furnishing health care services. Holiday
gifts of cookies, cakes, pies, candies, fruit, popcorn and other similar food items
offered by patients, physicians, contractors, subcontractors, suppliers and vendors
are permitted as long as such gifts are motivated by personal relationships, not business
considerations, and are shared with the entire department.
Resident Physicians, faculty and staff should be aware of and follow the AMA Council
on Ethical and Judicial Affairs (CEJA) opinion for assistance in identifying appropriate
- CEJA Guideline 1- Any gifts accepted by physicians individually should primarily entail
a benefit to patients and should not be of substantial value. Sample medications,
textbooks are appropriate if they serve a genuine educational function. Cash payments
are never acceptable and should not be accepted.
- CEJA Guideline 2- Individual gifts of minimal value are permissible as long as the
gifts are related to the physician’s work. Educational materials, pens and notepads
are acceptable examples. Consistent with GMC Standards of Conduct and Corporate Compliance
Program, solicitation or acceptance of personal gifts, favors, loans, cash, uncompensated
services or other types of gratuities or hospitalities from organizations doing business
with GMC is inappropriate.
- CEJA Guideline 3- Defines a legitimate “conference” or “meeting” as an activity held
at an appropriate location dedicated to promoting objective scientific and educational
activities when the main incentive is to further knowledge on the topics being presented.
Disclosure of financial support and the potential for conflict of interest must be
reported by the presenters and meeting provider. If oral disclosure only is made,
an appropriate individual (e.g., course director, resident faculty, meeting coordinator)
must document full disclosure was made.
- CEJA Guideline 4- Allows industry subsidies to underwrite the costs of continuing
medical education (CME) conferences or professional meetings that contribute to the
improvement of patient care. Payments to defray the costs of conference production
or attendance should not be accepted directly from the company by the physician(s).
Any subsidy should be paid to GMC consistent with CME accreditation standards.
- CEJA Guideline 5- Subsidies from industry should not be accepted directly or indirectly
to pay for the costs of travel, lodging, or other personal expenses of physicians
or relatives attending conferences or meetings. Subsidies for hospitality should not
be accepted outside of modest meals or social events held as a part of a conference
or meeting. It is appropriate for faculty at conferences or meetings to accept reasonable
honoraria and to accept reimbursement for reasonable travel, lodging, and meal expenses.
Honoraria and reimbursement of travel-related expenses for accredited CME conferences
must be paid to faculty by the accredited CME provider or joint sponsor, not a commercial
- CEJA Guideline 6-Scholarships or other special funds to permit Resident Physicians
to attend carefully selected educational conferences may be permissible. The selection
of the attendees who will receive the assistance must be made by GMC and not the company.
Carefully selected educational conferences are defined as major scientific, educational,
or policy-making meetings of national, regional or specialty medical associations.
- CEJA Guideline 7-No gifts should be accepted if they are given in relation to the
physician’s prescribing practices. Gifts of any size should not be taken if there
is any correlation between the awarding of the gift and prescribing practices.