FAQ

Topic 1: Gifts & Meals

Can vendors buy books or equipment for faculty, residents or staff?

No. A vendor can provide an unrestricted educational gift/donation to the department. The department MUST be the party to determine how the gift/donation will be spent on educational priorities within their respective department.

Can a vendor take a clinician out to lunch or dinner for a business purpose?

No. All gifts and meals that are directly funded or provided by industry or vendors, regardless of nature or value, are prohibited regardless of whether they are offered in Health Sciences Center‐operated sites or off‐site. However, meals provided as a part of the program of an off‐campus event offered by an accredited continuing education organization or a recognized academic, professional, or scientific society are permitted, so long as the organization's conflict‐of‐interest policies are followed.

Can vendors provide food to departments for educational and other events (i.e. journal clubs, noon conferences, weekly lunches, journal clubs, section conferences, special events - open houses, section gatherings)?

All gifts and meals that are directly funded or provided by industry or vendors, regardless of nature or value, are prohibited regardless of whether they are offered in Health Sciences Center‐operated sites or off‐site. However, meals provided as a part of the program of an off‐campus event offered by an accredited continuing education organization or a recognized academic, professional, or scientific society are permitted, so long as the organization's conflict‐of‐interest policies are followed.

A vendor can provide an unrestricted educational gift/donation to the department. The department MUST be the party to determine how the gift/donation will be spent on educational priorities within their respective department.

Topic 2: Marketing Verses Education

Can we accept and use vendor marketing material (i.e. pens, note pads…etc.)?

Can patient educational materials be used in our clinic or given to patients that have been provided by a vendor (i.e. diagrams of body parts, brochures with regard to particular diseases… etc.)?

Yes. Patient educational materials should avoid vendor promotion if possible and if not, they should not contain advertising for specific products.

What kind of information will departments have to keep demonstrating that the Chair or Program Director approved the conference?

Each department is responsible for assuring compliance with the policy. No specific documentation is required by the policy.

Can vendors attend on-campus educational sessions?

Yes. Vendor is not permitted to speak during the session and should not draw attention to themselves in any manner.

Are exhibits allowed at on-campus educational events?

Yes, as long as only educational materials are distributed. The material should not contain company logos. Promotional items, giveaways, or any sorts of gifts without education value should not be distributed.

Topic 3: Research

How are research grants to faculty and staff regulated to avoid the potential for conflict of interest as is the aim of this policy?

Grants, contracts and charitable gifts provided by Industry are subject to current policies of the Office of Sponsored Programs and WVU Foundation respectively.

Topic 4: Vendor Access

Can vendors come into the work rooms within patient care areas?

No. Our policy prohibits vendors from patient care areas (with the exception of our satellite facilities).

Medical device company representatives are not allowed to enter in‐patient or out‐patient areas with the following exception: under certain limited circumstances, device industry representatives who are properly credentialed by the Health Sciences Center‐affiliated hospital may be allowed in patient care areas at the request of a clinician to facilitate a clinical procedure involving a pertinent device and with the permission of the patient. In these circumstances, medical device company representatives shall register with a designated central office before entering and after leaving the patient care area.

Topic 5: Disclosure

How do I disclose pertinent information?

Annually, each clinical faculty member and UHA staff person completes a conflict of interest disclosure form via Netlearning.

Topic 6: Industry Sponsored Engagements

Can a conference sponsor pay for an attendee's registration if that attendee is presenting at the conference?

Yes, as long as the vendor does not be have a role in determining presentation content. The preference would be for the vendor to give a grant to the conference and have the conference pay for the attendee's registration as a scholarship. We try to avoid direct gifts in the policy.

Can a vendor sponsor a fellowship?

Yes. Industry support of clinical fellowships or scholarships to support trainees may be used ONLY if the funds are directly provided to the administrative office of the particular Health Sciences Center School.

If I am giving an industry sponsored presentation can I use the WVU name and/or logo in my presentation?

No. Using the WVU name or logo in your presentation implies that the School is endorsing the material. However, if you have been approved to give the presentation in your official WVU role – you may use the WVU name and/or logo. Special written permission must be obtained from either the Department Chair or Dean for the latter.

Topic 7: Enforcement

What is my responsibility if I suspect there is a violation of the COI policy?

You can anonymously submit your concern on-line or bring it to the attention of your department chair or Dean. Strict confidentiality will be maintained.