The Patient Protection and Affordable Care Act was signed into law March 23, 2010. The new law contains a “Physician Payment Sunshine Provision” that requires drug and medical device manufacturers to publicly report gifts and payments given to physicians and teaching hospital personnel beginning in September of 2013. This Act, in addition to healthcare reform in general, has raised widespread national interest in reforming how academic medical centers interact with Vendors.
Effective January 1, 2011, all faculty, staff, and students of the School of Medicine and employees of the Health Care System will be required to comply with the new policy called the “Policy on Vendor Relationships in Biomedical Research or Patient Care,” adopted jointly by the Health Care System and the University for the School of Medicine.
Our policy is intended to promote the safety of patient care activities, the integrity of our institutions, and the trust of our patients, while setting up a process to report relationships that are appropriate for the patient care, academic, and research missions we support. Key elements of the policy include:
- Individuals may not accept personal gifts, even of nominal value, from vendors or their representatives, including pens, notepads, or trinkets which are typically intended as marketing tools.
- Individuals who have financial relationships with vendors, through employment, contracts, or investments will have to report this annually (in addition to the reporting required to get approval for external professional activities for pay), and certain information will be posted publicly in order to appropriately disclose relationships to patients.
- Family members of UNC employees are also prohibited from accepting gifts, meals, and marketing products from vendors. Employment, contract, and/or investment relationships between family members and vendors must be reported annually.
- Vendors may continue to make gifts to the University, the Health Care System, or the Medical Foundation, but they may not make contributions directly to a department or for an event such as an educational lunch.
- Individuals may not accept vendor-sponsored meals unless they are (1) served as part of a general professional conference or meeting and are included in the registration for the conference/meeting, or (2) offered or reasonably reimbursed as part of an approved external professional activity for pay.
The policy is available online at:
Frequently Asked Questions (FAQs) are available online at:
The policy requires that all faculty, staff, and students of the School of Medicine and employees of the Health Care System complete a certification form each year. You will receive more information in the coming weeks as to how you are required to report. The form will ask you to disclose your relationships with Vendors as of July 1, 2010 and forward. If you have an unmanageable conflict of interest that predates the effective date of this policy (January 1, 2011), please discuss this matter with your supervisor. Educational documents that further explain the new Policy and provide instructions for filling out the disclosure form will be provided soon. In the meantime, questions may be sent to email@example.com.