Conflict of Interest Policy
General Principles: The purpose of this policy is to provide guidance to medical students, faculty and supervising physicians who may have relationships that extend beyond the standard learner/teacher relationship. It is important to define these relationships and establish policy with regards to managing them in order to avoid conflicts of interest and both establish and maintain a constructive and supportive learning environment. The following LCME Elements were considered in the drafting of this policy:
LCME Element 1.2: A medical school has in place and follows effective policies and procedures applicable to board members, faculty members, and any other individuals who participate in decision-making affecting the medical education program to avoid the impact of conflicts of interest in the operation of the medical education program, its associated clinical facilities, and any related enterprises.
LCME Element 12.5: The health professionals who provide health services, including psychiatric/psychological counseling, to a medical student have no involvement in the academic assessment or promotion of the medical student receiving those services. A medical school ensures that medical student health records are maintained in accordance with legal requirements for security, privacy, confidentiality, and accessibility.
Definition: A conflict of interest (COI) is defined as a relationship in which an individual has competing interests or loyalties that have the potential to undermine their ability to act in an impartial manner.
Existing rules of the University of Nebraska Medical Center (Policy #8010) and State of Nebraska (statute 49-14.101) define COIs as they relate to industry, government agencies, individuals, and other enterprises to prevent private financial gain for themselves or family members.
This policy builds upon these existing rules to help students and faculty avoid and manage COIs that may arise in supervisory relationships that could unduly impact student grading in required activities, academic advancement, or the awarding of special awards such as scholarships or other special recognition. Example relationships that may cause a COI include but are not limited to:
- consensual intimate relationships
- familial relationships
- current or recent physician-patient (health care) relationships
- financial relationships
Reporting: Supervising educators (including UNMC faculty, volunteer faculty, and resident physicians) and students are expected to report each instance in which a relationship may cause a real or potential COI using the following guidelines:
- Supervising educators are required to disclose any relationship with the potential to cause a COI prior to the beginning of a course, clerkship, elective or any other relevant activity (course/clerkship administration, standing COM committee, awards committee, etc.) to the course/clerkship director, committee chairperson, or Office of Medical Education who will make a determination of the potential impact on the learner, educator, and/or learning environment and outline steps to eliminate or reduce potential conflict
- Supervising educators will be required to attest that they do not have such a relationship with students they are evaluating. An attestation statement will be included on each student evaluation. Data provided by supervising faculty that disclose a pertinent relationship may not be included in the student’s grade or final evaluation.
- Students should also report any such relationships or concerns that a COI may arise as soon as possible to the course/clerkship director(s), Office of Medical Education or campus Ombudsperson.
- Appeals on decisions related to the presence of relevant conflict(s) of interest are made to the Associate Dean for Medical Education whose decision is final.
Education: The College will provide supervising educators and students with regular education related to this policy, reporting relationships, and guidance for mitigating potential COIs.
Guidance: Supervising educators, students and other supervisory personnel must avoid, whenever possible, relationships that pose a potential COI.
Supervising educator or other
- If such a relationship is reported, supervising faculty will make arrangements with course/clerkship director(s) to avoid any contact with the student that may lead to a COI during teaching and evaluation periods. Faculty with such relationships should not evaluate students on an individual basis.
- If such a relationship is reported, members of Grading and Student Evaluation Committees, as well as any departmental committees responsible for determining grades, assigning awards, or making determination of student advancement, should recuse themselves from any discussion/voting related to a student to which they have a potential COI.
- If the supervising educator serves in the formal leadership of a course/clerkship in which a COI may take place, that educator should recuse themselves from administrative decisions related to assessment and advancement of students within that course/clerkship. Standard operational decisions related to the course/clerkship will be permitted such that they do not pose undue influence on a student, his/her evaluation, or the remainder of the students.
- Supervising educators should not serve in a caregiver-patient relationship with a student that they have the potential to supervise unless providing care in emergency situations.
- In instances in which a relationship exists but circumstances preclude avoiding a potential COI, the situation will be referred to the Curriculum Committee and Associate Dean for Medical Education for recommendations.
- If a medical student is hospitalized, being evaluated in the emergency department or other clinic setting, other medical students should not be involved in the student’s care.
- Based on the potential for COI, students will not be permitted to take part in an elective experience or rotation in which the main evaluator/elective director has such a relationship.
Approved by the Curriculum Committee: September 25, 2018
Modified by the Curriculum Implementation Team: April 20, 2021
Approved by the Curriculum Committee: May 25, 2021