Conflict of Interest Policy

Effective: 7/1/25

To whom this policy applies

All University of Nevada, Reno School of Medicine (“UNR Med”) faculty, trainees and staff.

Purpose

The University of Nevada, Reno School of Medicine is committed to maintaining public trust and transparency within our academic and clinical environments. To support this commitment, the purpose of this policy is to establish the requirements for disclosing, reviewing, managing and eliminating conflict of interest situations within our academic medical institution. This policy is a supplement to the University of Nevada, Reno Conflict of Interest Policy (UNR UAM 2,050) and all related regulations and policies as set forth therein. In all cases, where this policy is more restrictive than the University of Nevada, Reno Conflict of Interest Policy, this policy shall control. This policy applies to interactions with all sales, marketing, or other product-oriented personnel of Industry.

Definitions

Industry: Biotechnology, pharmaceutical, medical devices, hospital equipment supply industry entities, and other medical commercial entities that make, market, or distribute supplies, devices, equipment, products or services that are used in research, in the treatment of patients, or other provision of medical care. “Industry” does not include hospitals (or their related entities) with an affiliation agreement with UNR Med and/or clinical teaching site affiliates of UNR Med.

Personal Gifts: Anything that is received by an individual for which the recipient has not paid fair market value.

Trainees: UNR Med students, residents, fellows. It further includes graduate and undergraduate students conducting biomedical research in UNR Med laboratories.

Policy

All University employees, including academic faculty, administrative faculty, classified staff, salaried letters of appointment (hourly letters of appointment are excluded), fellows and medical residents, are to submit conflict of interest disclosures as set forth in UAM 2,050. Failure to comply with such disclosures may subject such persons to disciplinary actions, as set forth in Title 2, Chapter 6 of the Nevada System of Higher Education Code, UNR UAM 2,370 and other applicable provisions.

Any activities not permitted by this policy require submission of an Exception Request to the UNR Med Conflict of Interest Committee at compliance@med.unr.edu, which reviews, approves or denies such requests pursuant to 2.3.7 of UNR Med Bylaws. Such committee focuses on conflicts of interest in clinical and educational interests, while the University of Nevada, Reno Conflict of Interest Committee has a broader scope that includes research and institutional conflicts of interest.

When UNR Med trainees rotate with clinicians who are not UNR Med faculty, trainees should continue to follow the principles established in this policy. For example, trainees should not accept gifts provided by a pharmaceutical representative at an outside site. Trainees who perceive that such refusal might jeopardize their evaluations should report their concerns to UNR Med’s Associate Dean for Medical Education, the Student Clerkship Director of the relevant specialty, UNR Med’s Associate Dean for Graduate Medical Education, or the residency/fellowship Program Director.

Faculty with outside appointments are also responsible to be compliant with those institution’s respective policies.

Nothing in this policy is intended to diminish the value of charitable contributions. Industry wishing to make such charitable contributions to UNR Med may do so by contacting the University of Nevada, Reno School of Medicine Foundation.

Gifts and Provision of Meals

Personal gifts, including food, travel support to meetings, training subsidies, training funds, complimentary tickets to entertainment or other events, and promotional materials, from representatives of Industry are not to be accepted or used, regardless of the nature or dollar value of the gift. Meals, other gifts or hospitality funded by Industry may not be accepted, whether on campus or off campus. However, gifts do not include attendance or admission to events sponsored by hospitals (or their related entities) with an affiliation agreement with UNR Med or UNR Med clinical teach site affiliates. Further, routine meals provided by a clinical teaching site affiliate, during assigned work hours, are exempt. At the direction of the UNR Med Graduate Medical Education program, lunch time meetings and/or Grand Rounds that involve Industry personnel may be organized to include presentations in a “roundtable” or open discussion forum where Industry personnel may participate. These educational venues must include an Industry-sponsored speaker, and must be disease or illness based. Representatives of at least two (2) different Industry entities must attend such event; however, Industry participation in discussion with trainees would be at the discretion of the Graduate Medical Education program.

Site Access for Pharmaceutical and Device Sales/Marketing Representatives

Representatives of Industry, including pharmaceutical, device and other medical companies, whose sole purpose is sales and marketing are not permitted to access the UNR Med campus nor distribute promotional items. In contrast, it may be appropriate for UNR Med personnel to meet with Industry representatives for the limited purpose of training and technical assistance for medical devices, when such assistance cannot be obtained from other sources. UNR Med personnel may meet with drug – and device-industry scientists to discuss potential research collaboration or to receive in-depth scientific and educational information. These limited purpose meetings shall be at the request of UNR Med personnel, by appointment only in faculty offices, with the prior approval of the relevant Department Chair or the Dean. Records of such approved visits must be maintained by each UNR Med Department, pursuant to the UNR Record Retention policy.

Companies with a non-medical purpose are also subject to the guidelines of this policy.

Support of Education in the Health Sciences

Industry may not direct or restrict content or speakers for CME activities. Accredited continuing medical education (CME) provides healthcare practitioners with critical educational support and must be designed to ensure that it serves the needs of patients and the public, is based on valid content, and is free from commercial influence. As such, all CME activities are to meet the standards for accredited CME activities, pursuant to the national Accreditation Council for Continuing Medical Education (ACCME). Any agreements for industry support of medical education must be reviewed by UNR Med legal and the UNR Med Office of Continuing Medical Education.

Industry-Supported Speaking and Authorship in Industry Sponsored Research

UNR Med personnel and trainees are not to participate in industry-related “speakers bureaus.” Participation as an author or co-author on manuscripts, wholly or partially ghostwritten or whose content has been unilaterally altered by industry representatives is prohibited.

Open Payments Law Compliance

UNR Med personnel covered by Open Payments Law and Policy must register with the Centers for Medicare & Medicaid Services (CMS), review their data, and ensure accuracy during the annual voluntary review and dispute period. Inconsistencies between Open Payments data provided by pharmaceutical companies and UNR disclosures will be reviewed by the UNR Med Conflict of Interest Committee for policy compliance.

Review

Approved by UNR Med Executive Committee, 06/20/2025