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An Educational Session on HSC OP 10.27, Health Care Vendor Interactions. April 20, 2009. LAWMAKERS & ASSOCIATIONS. Senate Activities on Capital Hill Investigations of Industry Financing – S. Grassley Proposed Senate Bill: Physician Payments Sunshine Act Texas Activity
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An Educational Sessionon HSC OP 10.27,Health Care Vendor Interactions April 20, 2009
LAWMAKERS & ASSOCIATIONS • Senate Activities on Capital Hill • Investigations of Industry Financing – S. Grassley • Proposed Senate Bill: Physician Payments Sunshine Act • Texas Activity • SB 296 – Industry Disclosure Requirement • Association Activity • 2008 AAMC Report: Industry Funding of Medical Education • Recommends strict limits on industry support • AdvaMed Revised Code of Ethics • PhRMA Revised Code, effective 1/09
HSC OP 10.27 - BASIS • Federal Anti-Kickback • Federal Stark Laws • Texas Government Code, Section 572, Subchapter A, Section 572.001 • TTUS Regents Rule 03.01 • Ethics Policy • June 2008 AAMC Report on Industry Funding of Medical Education.
GENERAL OUTLINE • Provides Guidance on Allowable Interactions • Faculty and Staff • Health Care Vendors; Pharma, DME, Other Health Care Providers (SNF, Hospice, Home Health) • Does Not Impact • Continuing Education Criteria • Research Conflict of Interest Requirements • Non-Health Care Vendors – Those only on-site to assist in or coordinate patient care
GIFTS & CONFERENCES • Compensation and Gifts • Bans all promotional items/gifts other than patient educational items approved by Chair/Dean • Bans all other gifts and payments not otherwise allowed • Travel, Lodging, Meals and Conferences • Limited to REASONABLE honoraria and travel expense reimbursement for those ACTIVELY presenting.
HEALTH CARE VENDORS • Vendor Identification: • Registration, Sign-in and ID badge required • Appointment • Requires appointments for health care vendors visiting TTUHSC facilities • Acknowledgment of TTUHSC related Policies • HSC OP 10.27 • HIPAA Privacy rules
MEALS • Meals • Accredited Continuing Education Activities • Non-accredited – Approved by faculty designee • Drug, Equipment & Medical Device Samples • For patient use only; secured and tracked • Funding of Continuing Education only to through the Continuing Education Office • Consulting Honoraria
OTHER AREAS • Gifts for Scholarships • Not given directly to the student/resident • Dean/Department selects recipient • Ghostwriting • Prohibited • Does Not Address Speakers’ Bureaus • Under future consideration
WE ARE NOT ALONE! • Stanford University – June 2006 • Yale – May 2005 • Henry Ford Health Systems – 2005/2006 • University of Pennsylvania – July 2006 • University of Michigan Hospital and Health System – January 2008 • UTMB • John Hopkins – December 2008 • Banning Faculty Involvement in speakers’ bureau