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Compliance Program

Compliance Program

Conflict of Interest

Because of the potential for abuse, having a financial interest that conflicts with the role you have within UC Davis Health System is of concern, even if you have good intentions, never exploit the conflict, and do not harm anyone.

UC Davis employees are government employees. California has special conflict of interest laws and regulations affecting government employees. These laws include the Fair Political Practices Act, also known as the Political Reform Act of 1974. In addition, Federal law has special sections relating to health care conflicts of interest that result in more stringent standards than for most other businesses. This all adds up to a set of strict standards every one of us must follow.

As a matter of policy, UC Davis Health System discourages the existence of potential conflicts of interest. Such conflicts may make it difficult for an employee to discharge his or her work duties.

AAMC Task Force on Financial Conflicts of Interest in Clinical Research

The American Association of Medical Colleges (AAMC) formed a task force charged with assessing the currency and sufficiency of existing AAMC guidelines, and with formulating new principles and guidance as necessary to address both individual and institutional financial conflicts of interest in research involving human subjects: assessing the currency and sufficiency of existing AAMC guidelines, and with formulating new principles and guidance as necessary to address both individual and institutional financial conflicts of interest in research involving human subjects.

 

PhRMA Conflict of Interest Code

Recently there have been several significant scandals involving physicians and the pharmaceutical industry. The Pharmaceutical Research and Manufacturers of America (PhRMA) has just adopted a voluntary PhRMA conflict of interest code.

 

Drug Status Allegations
Lupron — TAP Pharmaceuticals $875 million dollar settlement, several doctors indicted Kickbacks and bribes disguised as free samples, consulting fees, educational grants, and expensive gifts.
Neurontin — Pfizer Qui tam lawsuit filed Kickbacks disguised as educational grants, fees to physicians for ghostwritten articles, speakers fees, payment for attending consultants' meetings to promote drug

AMA Conflict of Interest Code

The American Medical Association (AMA) has an extensive code of ethics. It includes several sections concerning conflicts of interest, including a section on gifts to physicians from industry, conflicts of interest in biomedical research and managing conflicts of interest in clinical trials.

They also have a Web site dedicated to their guidance on gifts to physicians from industry, including educational programs with CME credit.

The NIH conflict of interest page includes links to many web resources and a report on the strengths and weaknesses of institutional policies.