Life Science Compliance Update

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April 10, 2009

Academic Medical Centers: Partners Healthcare Adopts Strict COI Policy

In an e-mail to their physicians, Partners Healthcare, which includes Massachusetts General, Brigham and Women’s Boston, and most of the hospitals severing Harvard University, announced that they have adopted a strict conflicts of interest policy today which goes into effect October 1, 2009 for its physicians.

The policies include:

Gift Ban

A total ban on gifts, including meals and funding for meals, provided directly to staff by industry for their personal use, on a Partners’ site or off-site.

This prohibition will also apply to Partners’ institutions accepting gifts from industry for this purpose.


Forbids meals except for CME events, prohibits physicians from eating meals on a company’s tab, including lunches bought for doctors in training in the hospital.

Drug Samples

Free drug samples will only be permitted if they are distributed through the hospital pharmacy or some other centralized system.  Once such a mechanism is in place, physicians will no longer be allowed to accept or distribute free drug samples.

Pharmaceutical and Device Reps

Pharmaceutical, medical device, and other industry representatives will be required to have written invitations defining the purpose and terms of their visits before having access to Partners’ sites and staff.

Educational Programs and Fellowships

To ensure that educational programs and fellowships continue to be insulated from industry influence, industry funding must be directed to a centrally pooled President’s Fund that will be established at each hospital or approved by a newly-created, Partners-wide Educational Review Board (ERB).

The ERB, except under extraordinary circumstances, will require funding for a specific program or fellowship come from multiple companies.

Speaker Bureaus

Partner physicians will be limited in participating in speakers’ bureaus, perhaps to one to two times per year.  According to Peter Slavin, M.D., President of Massachusetts General, who is responsible for implementation of this policy, “We don’t want our faculty being on the road,” as “hired guns.”

Boards of Directors

Limiting and reviewing payments to those who serve on corporate boards.


Reviewing and possible limitations to consulting agreements.


Banning all ghostwriting.

Disclosure to Patients

The new policy does not address public disclosure, but Slavin, who will oversee implementation of the policy, said the hospitals will develop a plan for disclosure to patients.

In a statement, Senator Grassley said:  It's good that the hospitals associated with Harvard are responding to these concerns."  "I'm especially glad that these hospitals are taking a national lead on issues such as ghostwriting and speakers' bureau fees."

According to The Boston Globe, the rules go further than a state law passed last year to restrict doctors’ relationships with industry, the law allows doctors to pay for certain meals and to distribute drug samples to doctors.

Dr. Thomas Stossel, Director of the Division of Translational Medicine at Brigham and Women's Hospital, who was an adviser to Merck several years ago, said restrictions on the interactions between doctors and industry could ultimately hurt patient care. "We have all these tools now [for caring for patients], and those tools have come from physicians working with industry."

One top Partners’ physician is considering that as the state, medical schools, and now the hospitals become more and more restrictive, he may consider a job at a South Eastern institution which values collaboration.  He also outlined that moves like this may motivate physicians to accept short-term faculty positions then move on to more friendly political environments.

Universities and health systems will find that the penalty these policies place on junior faculty members is enormous and may force debt burdened faculty to pass on what is considered a prestigious position with little pay (Partners pays about $80K/year to attending physicians).

Earlier this week, Johns Hopkins adopted a similar measure.  As more and more institutions and hospitals adopt these policies, most of which were recommended in the AAMC Taskforce on Conflicts of Interest last summer, we will see industries’ ability to work with academic clinicians become harder and harder to implement.

Key Documents

Partners Commission on Interactions with Industry April 10, 2009

Partners Press Release

The Boston Globe:  Partners Healthcare Restricts Doctors Ties to Drug Industry

Partners:  James Mongan, President of Partners e-mail to physicians

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