General Practice Services Committee (GPSC) Policy on Declaration of Competing Interests
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- Cuthbert Elliott
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1 General Practice Services Committee (GPSC) Policy on Declaration of Competing Interests A competing interest exists when professional judgment concerning a primary interest (such as patients' welfare) may be influenced by a secondary interest (such as a desire to amass academic publications, career advancement or professional gains). As such, situations may arise for GPSC-affiliated committee members, individual support staff, or individuals or organizations who partner with the GPSC have personal or business interests that may influence decision making or policy work they undertake on behalf of the GPSC. GPSC s primary interest is articulated in relation to the Triple Aim, which is a focus on approaches to optimize the primary care system by taking into account three dimensions: 1. The experience of the individual (patient and provider) 2. The health of a defined population 3. Per capita cost for the population In relation to this primary interest, competing interests could include: 1. Pharmaceutical sales, research or promotion 2. Academic or other research sponsored by pharmaceutical organizations 3. Involvement with industry groups or association that generates profit from the provision of health care or ancillary services. Competing interests are almost inevitable. The purpose of this policy is not to eliminate competing interests, but rather to ensure that, in GPSC matters, competing interests are openly declared by those who participate in GPSC decision-making and policy work. By doing so efforts can be made to ensure that, where competing interests exist, there is a balance of perspectives on committees. Thus, all GPSC and GPSCaffiliated committee members, individual support staff (including but not limited to BCMA, Health Authority and Ministry staff), and individuals or organizations who partner with the GPSC, regardless of whether any of such committee members, support staff or partners are funded or compensated for participating in GPSC decision making or policy work, are required to adhere to this policy. In situations where individuals or organizations are uncertain as to whether they are in conflict with this policy, they should contact the GPSC senior staff directly related to the committee or GPSC-funded initiative. Appearance of conflicted or competing interests: Because GPSC initiatives are collaboratively supported by the BCMA and the BC Ministry of Health, the activities of affiliated committees are vulnerable to scrutiny in the public eye. What may appear to be a simple relationship without competing interest may be seen by others to be unfair or biased. For this reason, it is important that attention be paid to the appearance of competing interests. Speaking engagements, advertising, and promotion of events are often seen as de facto gifts or marketing, or an illustration of a relationship that may be in competition with the GPSC s primary interest. Therefore,
2 GPSC-affiliated committees should not provide advertising or sponsorship opportunities to healthcare industry groups such as pharmaceutical companies or to organizations where there could be a reasonable assumption of a competing interest. Similarly any publicly-accessible document or resource should be free of content or messages (including logos) that could reduce confidence in the primary interest of the GPSC. Procedure for identifying competing interests: A declaration of existing and potential competing interest shall be completed annually by each GPSC and GPSC-affiliated committee member, each individual support staff (on his or her own behalf) and each individual or representative of an organization who partners with the GPSC. The declarations shall remain confidential unless disclosure is deemed appropriate by the co-chairs. If a competing interest pertains to a GPSC or sub-committee decision-making process, it shall be openly declared by the member prior to the start of the decision-making process, and the member shall consider refraining from voting. All contracts produced through the GPSC will require that funded organizations explicitly agree to adhere to this competing interest policy. GPSC majority-funded organizations: Divisions of Family Practice who receive a bulk of their infrastructure funding from the GPSC can in no way use their developed infrastructure to support activities that are funded by healthcare industry groups such as pharmaceutical, information technology, or medical supply companies. An example includes advertising continuing medical education events, where presenters or other elements of the event received any kind of pharmaceutical, information technology, or medical supply company support. Exceptions: Three situations are exempt from this policy: 1. Individuals or organizations sponsored by the GPSC to attend a conference whose organizers (who are not related to the GPSC or their funded individuals or groups) have received health care industry funding. 2. GPSC-partially funded groups that receive healthcare industry funding or support but in no way use this support or influence within their work in partnership with the GPSC. 3. Individual physicians who bill GPSC incentives for work performed in their private practice. Procedure for handling competing interests: The GPSC as a whole has a duty to disclose specific competing interests to GPSC members, staff, and external stakeholders where that interest may, in their judgment, affect the reputation or credibility of the GPSC and its partners. The GPSC must also disclose the procedure for operating in the presence of such conflicts.
3 GPSC members, its support staff, and any individuals participating in GPSC decision making or policy decisions have a duty to exempt themselves from participating in any discussion and voting on matters where they have, or may be perceived as having, a conflict of interest. Such exemptions should be recorded in minutes of meetings. Any business relationship between an individual (or a company where the individual is an owner or in a position of authority) and the GPSC, outside of their relationship as a committee or staff member must be formalized in writing and approved by the GPSC. When a concern surfaces in relation to perceived competing interests, the GPSC will review the concern and provide guidance to the individual and/or organization in question. The GPSC will consider the specific context under which concerns were raised. Additional information may be collected to assist in any decision making as required. All decisions will be documented in committee minutes and communicated to all individuals and/or organizations concerned. Individual-focused GPSC declaration of competing Interests: 1 Please answer the following questions 1. Do you currently accept or have you in the past five years accepted any of the following from a health care industry group such as pharmaceutical company, information technology company, medical supply company, or community- based medical organization: Funding Type A fee for speaking? A fee for organizing education? Funds for research? Financial support for a member of your staff? Organization Fees for consulting? Funds for the purchase of or maintenance of IT equipment? 2. Do you hold any stocks or shares in any organization that may in any way gain or lose financially from your work with the GPSC? No Yes 3. Do you hold a university appointment? No Yes 1 Appended from the British Medical Journal policy on competing interests.
4 4. Do you sit on any boards of health care organizations or community organizations or societies that may gain or lose financially from your work with the GPSC? No Yes If so, please specify: 5. Do you have any other competing financial interests? No Yes If so, please specify: Name Please Print District Signature Date Please return to: Attention: Tanya Chu Fax: or Mail: West Broadway, Vancouver BC V6J 5A4
5 Organization-focused GPSC declaration of competing Interests: 2 Please answer the following questions: 1. Does your organization currently accept or has your organization in the past five years accepted any of the following from a healthcare industry group such as pharmaceutical company, information technology company, medical supply company, or community- based medical organization: Funding Type A fee for speaking? A fee for organizing education? Funds for research? Financial support for a member of your staff? Fees for consulting? Funds for the purchase of or maintenance of IT equipment? Organization 2. Do leaders or individuals on the Board of Directors of your organization hold a university appointment? No Yes 4. Do leaders or individuals on the Board of Directors of your organization sit on any additional Board of Directors of health care organizations or community organizations or societies that may gain or lose financially from your work with the GPSC? No Yes If so, please specify: 5. Do leaders or individuals on the Board of Directors of your organization have any other competing financial interests? No Yes If so, please specify: Name Please Print District Signature 2 Appended from the British Medical Journal policy on competing interests.
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