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UCDHS Vendor Relations Policy Development & Implementation
Teresa Porter, CHC - Chief Compliance Officer David Levine, JD - Legal CounselAllan Siefkin, MD - Chief Medical OfficerTimothy Albertson, MD,MHP, PhD - Professor/Division ChiefGaren Wintemute, MD,MHP – Professor, Emergency Medicine
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Our Goals for Sharing
Vendor Policy Development
Vendor Policy Implementation
Bumps in the Road
Where we are today
Best Practices – Campus Sharing & Q/A
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JAMA Article, P&T Committee (sub), Pharma Code
Systemwide start Medical Staff, P&T - whose decision was it to
extend the definition of “vendor” to include all, rather then just health care vendors.
Policy Rollout Industry Relations Committee (IRC)
development
Starting Points
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UCDHS Vendor Relations
Background on Development JAMA Article Pharma Code Dr. Wintemute’s interest/guts to move forward His foresight for soliciting Dr. Albertson for
assistance as the Chair of the P&T Committee P&T appoints a sub-committee for
recommendations
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P&T Sub-Committee
Important acknowledgement that ownership of the recommendations being made were done through a Medical Staff Committee
Vendor relations would apply to “all” vendors, not only health care related
Recognizing existing policies that covered COI, financial interest, preceptorships and manufacturer relations
Appointment of Dr. Albertson to the newly formed UCOP committee to develop systemwide vendor policy
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UCOP Vendor Committee
Early draft of the UCOP policy was used to initiate the UCDHS Vendor Policy.
P&T subcommittee recommendation to the Dean who codified the policy.
Presentation to Governing Body
UCDHS Vendor Relations Policy approved
Recognition that the success of this policy would require transparency and buy-in from the bottom-up.
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Policy Implementation Rollout
CMO/CCO, Allan Siefkin, MD committed to education
Peer Pressure – Evolutionary change from the bottom
Transparency and light on the subject
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Rollout CMO/CCO Plan
Six months prior to policy implementation the campaign began Periodic Email Notifications Education
Focus Groups- Medical Staff- Department Managers, Department CAO’s, Nursing- Individual Department Faculty/Resident Meetings- Marketing & Fundraising personnel- Early version of FAQ’s developed and distributed
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Important Notes
Transparency Peer pressure – Evolutionary change Concerns about implications for clinical
research and the need to maintain industry relationships to further science and funding
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System Developments/Components
P&T Committee Products and Standardization Committee Value Analysis Committee
Medical Staff Committee Collaborative committee with the hospital Emphasis on supply purchasing for the OR
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Concerns about the Vendor Relations Policy from Faculty, Residents and Staff
Food - need to budget or obtain unrestricted funds
Samples – Most had been removed due to stricter Joint Commission requirements Additional need for samples imposed a need
for policy requiring Pharmacy to receive and distribute
Recognized Pharma Patient Assistance Programs
No distribution to any individual
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Supporting Mission
Care – Research Important reminder for faculty related to:
speakers’ bureaus compensation plan consulting/outside professional activities
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Recognized Need
Based on the number of questions to various sources throughout the institution
Need to coordinate Need to provide direct source Establish formal committee to address
questions about Vendor Policy implementation
Ability for physicians to “plug-in”
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Dean’s Recommendation Industry Relations
Committee Charge:o This committee is advisory to the Vice Chancellor of Human Health
Sciences and reports to the UCDHS Executive Compliance Committee to draft directives and review health system policy; provide resources and direction to faculty and administration; review annual faculty conflict of interest disclosure statements; review teaching, and professional service arrangements or proposals; and field questions and inquiries related to conflict of commitment, conflict of interest and vendor relations for faculty and staff.
o Conduct substantive review of issues presented. o Recommend changes or restrictions in the project and/or recommend
changes to manage, reduce or eliminate potential conflicts of interest. o Recommendation whether the grant, contract, or gift should be
accepted.o The committee will meet monthly and may conduct business outside of
regularly scheduled meetings when the Chair of the Committee deems necessary.
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Best for Last - Interactive Sharing
Open Sharing