The Harvard Medical School’s Faculty of Medicine Committee on Conflicts of Interest issued a report last month on its review of the school’s 20-year-old COI policy. The policy, according to the report, seeks to reinforce the “essential principle: Interactions between academia and industry are crucial to science and to facilitating the translation of knowledge from the research bench to the hospital bedside.” Noting the heightened scrutiny of industry-faculty collaboration lately,the report also provides guidance on how to keep those interactions transparent and worthy of public confidence that the results of collaborations are legitimate. Harvard Medical School receives approximately $2.5 million in commercial support for its program, which has revenues of $24.9 million.
Among the CME-related recommendations:
• Incorporate more COI education throughout the continuum of education and training at HMS and its affiliated institutions.
• Require that all HMS/Harvard School of Dental Medicine–accredited CME activities have multiple sources of commercial support, and that support must be shared equitably (i.e., no one company can contribute more than half of the activity’s budget).
• Have the HMS/HSDM CME Review Committees determine if there is funding equity among multiple sponsors, and evaluate the potential for COI due to financial relationships between industry and the organizers or faculty.
• Require additional separation of industry exhibits and CME educational content. For example, the HMS/HSDM Review Committee would have to approve in advance the physical separation of education and exhibits for an activity (exhibits have to be in a separate room so learners don’t have to see it if they don’t wish to). Promotion of industry content also must be completely separate from HMS/HSDM content, and industry-sponsored educational programs also must be kept separate from HMS/HSDM content.
• Mandate CME speaker slides that disclose the value of relevant financial ties between the faculty member and industry.
• Apply Accreditation Council for Continuing Medical Education Standards for Commercial Support to nonaccredited events.
Pri-Med/HMS Relationship Gets Special Scrutiny
The committee also sought to clarify its relationship with Pri-Med, a communication and education platform owned by M/C Communications LLC, a for-profit medical education company. HMS is the accredited provider of the Current Clinical Issues in Primary Care course offered at Pri-Med conferences. Although the Pri-Med conferences have a significant commercial aspect, independent and HMS committee reviews found that “the development and delivery of HMS CME-accredited content at the Current Clinical Issues in Primary Care courses is independent from and uninfluenced by any Pri-Med conference exhibitor or advertiser.”
To err on the side of caution, the committee recommended additional safeguards be taken to minimize the marketing aspect of the conferences and further distinguish a separation between the Pri-Med conferences and the HMS-accredited Current Issues in Clinical Care CME courses. For example, HMS CME course participants would have to opt in to being put on any Pri-Med advertising distribution list. The committee also suggests that members of the HMS Standing Committee on Conflicts of Interest check out a Pri-Med conference during the transition period and make recommendations to the dean if they find any COI issues that should be addressed. The Pri-Med conference can still have an exhibit hall, as long as it follows the rules requiring a separate exhibit room and barring industry education held on the same day and/or same location as the HMS-accredited CME activity.