Conflict of Interest Disclosure
Question: Am I required to complete an annual conflict of interest disclosure form?
Answer: All UAMS officials, faculty, researchers, non-classified employees, and any employees who approve or release purchase requisitions in SAP must complete a conflict of interest disclosure annually. If you aren’t sure of your status, contact your department administrator for assistance. All UAMS Conflict of interest disclosures are made in the UAMS Muse system, which may be accessed here: http://muse2.uams.edu.
Question: How often do I have to complete a conflict of interest disclosure form?
Answer: Conflict of interest disclosure forms must be completed within the first two weeks of employment and annually thereafter. Disclosure forms must also be updated within thirty days of a change. If you are named key personnel on a funded research project, you will also be required to submit a research based disclosure before the project funds may be released.
Question: How do I log in?
Answer: To log in to Muse, the location for all UAMS conflict of interest disclosures, use your UAMS domain name (including “@uams.edu” after your domain name) and password. If you are unable to log in, email your UAMS username and SAP number to the Conflict of Interest Office (WLAshley@uams.edu) so we can make sure your account is set up correctly.
Question: I entered my email address and password, but I am unable to log in.
Answer: When entering your username, please remember to include “@uams.edu” in your username.
Question: When I log in, there is nothing in my inbox to complete. How do I complete a new form?
Answer: To complete a new disclosure form, select “Create My Certification” on the left of the screen, below “My Current Actions.” Only items pending some sort of action on your part will appear in your inbox. For example, if you complete a disclosure and your department chair asks a question about the disclosure in the Muse system, the disclosure will appear in your inbox until you submit a response. Select the disclosure to view the question and respond by selecting either “Edit COI” on the left side of the screen (to make changes to your disclosure form), or selecting “Email COI Administrator” (to enter comments that can be viewed without making changes to your disclosure form).
Question: How do I edit my conflict of interest disclosure form in Muse?
Answer: Log in to Muse and choose the disclosure form you wish to edit under the Inbox or My COI tab (near the center of the page). Select “Edit My Certification” on the left side of the screen to re-open the form. Use the “Continue” button to navigate through the pages. Make any changes needed; then check the attestation box on the Assurance and Certification page of the form and select “Finish” to submit the form. If you need assistance, contact the Conflict of Interest Office at 501-686-6447.
Question: How do I complete my disclosure if an organization’s name is not listed in Muse?
Answer: When adding a new disclosure to your form, follow the prompts to select the new organization. If you are unable to find your organization, enter the name in the second text box and click OK.
Question: How do I see my old conflict of interest disclosures in Muse?
Answer: Log in to Muse, and select the “My COI” tab near the center of the screen. Click on any of the disclosures shown. Then, select either the “Disclosures” tab near the center of the screen or “Printer Version” on the left side of the screen to view your prior disclosures.
Question: Who is required to take conflict of interest training?
Answer: Conflict of interest training is only mandatory for researchers who participate in federally-funded research projects. Training must be taken before beginning work on the project and at least every four years thereafter. If this does not apply to you, you may answer “no” to question number 7 on the UAMS Responsibilities page of the disclosure form and continue to the next question.
Question: How do I find out if I have taken conflict of interest training?
Answer: Check your record in MyCompass at https://uams.sumtotal.host/.
Question: I completed the conflict of interest training, why am I still getting emails about my conflict of interest disclosure form?
Answer: The conflict of interest training is different than the conflict of interest disclosure form. The conflict of interest training is a training presentation that is mandatory for federally-funded researchers, but optional for others. Training must be completed at least every four years. The disclosure form must be completed at least annually by most campus employees. A record of when you have completed both your conflict of interest disclosure form and conflict of interest training can be viewed in MyCompass at https://uams.sumtotal.host/.
Question: Who do I contact if I need assistance with Muse?
Question: How do I view or complete my own disclosure if I am a department chair, college dean, or college administrator?
Answer: To view your personal disclosure forms, select the COI tab after logging into Muse. From there, you should be able to select the disclosure you would like view. Once you have selected the disclosure, click the “Printer Version” button at the top to view the entire disclosure form. Likewise, to complete your disclosure, select the Inbox tab followed by “Create My Certification.”
Question: Why do I need to complete a conflict of interest disclosure form?
Answer: Under federal regulations and UAMS policy, conflict of interest disclosures must be completed at least annually and within 30 days of a change of discovering or acquiring a new significant interest by most employees. Failure to comply with this requirement can result in violations of state laws or federal regulations. Noncompliance can also result in sanctions to UAMS employees, including loss of computer access and prohibition from conducting research until the deficiency is cured and clearance is received from the Conflict of Interest Committee.
Question: May I accept an honorarium for participating in a drug company’s speaker’s bureau?
Answer: The UAMS Ethical Conduct/Gift Policy (“Gift Policy”) does not prohibit accepting honoraria for services rendered. Where no services are provided an honorarium would be a gift which is prohibited by the gift policy. Participating in a drug company speaker bureau must be evaluated under the UAMS Conflict of Interest Policy (“COI Policy”) to determine whether there is a conflict of interest or a conflict of commitment. At times events sponsored by vendors are designed to influence participants in their relationship with the vendor. Faculty and staff should participate in such events only when there is a legitimate educational purpose and their presentation reflects his or her own work.
Question: I serve as a consultant for a medical device manufacturing company and they pay me $10,000 per year. Can I continue as a consultant?
Answer: Payment for consulting services should reflect fair market value for services performed. Arrangements that pay a guaranteed amount with minimal or no duties amount to gifts which are prohibited. Services as a consultant must be reviewed and analyzed under applicable policies; these include the Conflict of Interest Policy, University of Arkansas Board of Trustees policies and for College of Medicine faculty, the MCPG By-Laws. Amounts received from medical device manufacturing companies (as well as all entities in the health care industry) must be disclosed on the Conflict of Interest disclosure form and evaluated for potential conflict of interest and conflict of commitment. Additionally, Board of Trustee’s policy requires that all faculty and selected Administrative staff (deans, department heads, directors and vice-chancellors) report all outside employment.
Question: A drug company gave me $50,000 to do research on a drug they make. Is this acceptable?
Answer: Processes are established for sponsored research at UAMS. You should contact the Office of Research and Sponsored Programs to initiate the process. UAMS is the appropriate party to all contracts for sponsored research. An employee of UAMS may not personally accept funds to conduct research.
Question: I serve on a board and receive pay of $7500 per year for this. Can I continue this appointment?
Answer: Service on boards must be reviewed and analyzed under applicable policies; these include the Conflict of Interest Policy, University of Arkansas Board of Trustees policies and for College of Medicine faculty, the MCPG By-Laws. Amounts received from all entities in the health care industry must be disclosed on the Conflict of Interest disclosure form and evaluated for potential conflict of interest and conflict of commitment. Payment for board service should reflect fair market value for services performed. Arrangements that pay a guaranteed amount with minimal or no duties amount to gifts which are prohibited. Additionally, Board of Trustee’s policy requires that all faculty and selected Administrative staff (deans, department heads, directors and vice-chancellors) report all outside employment.
Question: One of my patients gave me a gift certificate to a local restaurant. Can I keep it?
Answer: The Gift Policy allows a one time token of appreciation from a patient provided its value is less than $25. The Gift Policy further provides: “items from a patient or patient’s family are often handmade and reflect heartfelt appreciation. In accepting these items employee should explain to the patient that while they appreciate the gift, under UAMS Policy they can not accept any future gifts.”
Question: A drug company sponsors our journal club (dinner/drinks) every month at a local restaurant. Can we continue with this arrangement?
Answer: UAMS employees may not accept gifts from drug companies and therefore UAMS may not accept a meal paid for by a drug company. Sponsorship of journal clubs and other educational programs are permitted but only if the funds are donated to the appropriate foundation account in accordance with guidance from the appropriate college.
Question: A drug company provides coffee and doughnuts for Grand Rounds every week. Can this continue?
Answer: The Gift Policy prohibits all gifts from drug companies to include coffee and donuts. The drug company may make a donation to a foundation account to sponsor educational programs in accordance with guidance from the appropriate college.
Question: A drug company brought lunch for our clinic staff last month. Is this OK?
Answer: The Gift Policy prohibits all gifts from drug companies including meals.
Question: We hold a free medical screening for the general public once a year. Meals are provided to the employee volunteers, and donuts and coffee are provided for the public that attends the screening. This food is normally supplied by different drug reps. Is that OK?
Answer: Coffee and donuts for the public attending the screening is not prohibited by the Gift Policy. UAMS employees cannot accept gifts (which include coffee and donuts) from drug reps. Your department may accept donations from various sources to its foundation account. Foundation account funds may be used to provide coffee and donuts for patients and employees attending this type of event.
Question: Can military recruiters provide lunch for our residents?
Answer: Yes, recruiters can provide lunches and other items to our residents.
Question: Often organizations (for example Critical Care Nurses Association) that each employee pays their own membership fee to and attends on their own time have vendor sponsored meals. They are not on UAMS time and are not representing UAMS. Is there any problem with them participating in meals, giveaways, etc.?
Answer: The Gift Policy applies to all UAMS employees regardless of whether they are “on UAMS time” or “representing UAMS”. Most conferences and programs have sponsors. UAMS employees may accept the meal if it is provided to all attendees of the conference or program and the drug company is merely listed as a sponsor of the meal. UAMS employees attending conferences and programs presented by these organizations may not accept gifts directly from the vendors, to include meals and gift items from a vendor booth at the conference.
Question: A drug company paid for me and my wife to attend an educational meeting at a resort in Palm Springs. Is this OK?
Answer: The cost of travel to and from an event and the cost of lodging during the event may only be accepted where UAMS has determined attendance is in its best interest and attendance has been approved by the department chair, director, dean or hospital CEO. Amounts received by the employee and immediate family must be disclosed on the Conflict of Interest form.
Question: A drug company paid for my travel to present my research at a meeting in Paris. Is this OK?
Answer: The cost of travel to and from an event and the cost of lodging during the event may only be accepted where UAMS has determined attendance is in its best interest and attendance has been approved by the department chair, director, dean or hospital CEO.
Samples and Giveaways
Question: A device company attended my lecture last week and gave away pens and post-it notes. Is this acceptable?
Answer: No. Acceptance of any item of monetary value is prohibited by the Gift Policy, therefore pens and post-it notes may not be accepted from medical device companies.
Question: One of our department suppliers is offering a promotion of buy two, get one free. Is it permissible to accept this offer?
Answer: The Gift Policy prohibits gifts to employees; it does not restrict gifts or financial incentives to UAMS or any of its departments.
Question: One of our department suppliers has offered me an iPod if I purchase a minimum of five items. Can I accept the iPod if the department purchases the five items?
Answer: The Gift Policy absolutely prohibits accepting the iPod. The Gift Policy prohibits an employee from accepting gifts from any entity in the healthcare industry as well as any entity that does business or seeks to do business with UAMS.
Question: I received free baby formula from the manufacturer for 3 months when my baby was born. Is this OK?
Answer: The Gift Policy prohibits accepting gifts from any entity in the healthcare industry as well as any entity that does business with or seeks to do business with UAMS. Most baby formulas are manufactured by companies that do business with or seek to do business with UAMS; therefore gifts of baby formula may not be accepted.
Question: Our clinic gets free drug samples from the company to use for our patients. Is this OK?
Answer: The Gift Policy does not address drug samples provided to UAMS. Drug samples are addressed in Department of Pharmacy Policy 5:15. Drug samples may only be accepted and used in accordance with that policy.
Question: I drink out of a drug company coffee mug. Is that OK?
Answer: You may no longer accept coffee mugs provided by drug companies. Such mugs received prior to November 1, 2007, are not prohibited. You should certainly consider replacing the mug.
Question: A drug company purchases a textbook for each of our residents every year. Is this allowable?
Answer: Residents may not accept gifts from drug companies. The Gift Policy does not prohibit gifts to UAMS. A drug company may donate books to the department so that the books may be accessed and used by residents and faculty. These books must remain the property of UAMS.
Speakers and Presentations
Question: A drug rep wants to pay for a speaker to come to UAMS for a lecture to residents and nurses. The rep would also like to pay for lunch for those attending. The speaker and the topic were selected in conjunction with UAMS and the drug rep. Can we hold this event?
Answer: The Gift Policy does not prohibit sponsored speakers. There must be full disclosure of the sponsorship. The sponsor may not provide lunch for this type of program under our policies.
Question: A drug company sponsors a speaker for Grand Rounds for our department twice a year. Is this OK?
Answer: The Gift Policy does not prohibit sponsored speakers. There must be full disclosure of the sponsorship.
Question: Our representative for short and long-term disability wants to provide lunch for us on one of the three days of Orientation. It is mandatory that all staff members sign up for short-term disability. The representative said that even though he provides optional long-term disability, most staff approach him with questions concerning short-term disability. He always comes the last day of Orientation to answer their questions. We also have Human Resources personnel available that day for questions regarding the other benefits provided to the staff. The representative would be willing to discuss just the short-term disability to accommodate the residents. Would this be acceptable? Do you think our representative can provide food during Orientation since all the residents have him for short-term disability and all of benefits would be there to help answer questions also?
Answer: The representative may present information regarding programs offered through UAMS. The representative may not provide meals. The representative would have to provide funds to a foundation account established by your department to accept donations from various sources. The department could use those foundation funds for this type of event. All donors would then be listed as sponsors.
Question: A drug company has “free” online courses of educational business seminars. Some appear very helpful to residents and fellows in setting up a practice and performing other tasks. Do these fall under the gift category because they would have a monetary value?
Answer: The Gift Policy permits “free attendance provided by the sponsor of a[n]…event where UAMS has determined it is in the best interest of UAMS to attend the event”. This section would include on-line training. This is an opportunity to provide guidance regarding the content and potential “selling” of services by the program sponsor.
Employment at Non-UAMS Facilities
Question: Can you explain paragraph 4.b. of the policy concerning employees of UAMS that work at non-UAMS facilities?
Answer: This was to address UAMS employees whose duties require their presence at other locations (e.g., Arkansas Children’s Hospital). If such employees attended a lunch meeting at Arkansas Children’s Hospital they could not accept the meal without this change. Also, if a site gives all employees a t-shirt (under $25) UAMS employees working there may also accept the shirt. Employees may not accept meals or gifts from outside sources (e.g., drug companies), but may accept meals provided by that site (e.g., Arkansas Children’s Hospital). This paragraph allows UAMS employees to be treated similarly to the employees at the same location.