Conflict of Interest Policy

Effective: 5/1/2026

To whom this policy applies

All University of Nevada, Reno School of Medicine ("UNR Med") residents, fellows, employed faculty, Letters of Appointment (LOA), and staff.

Definitions

UNR Med Campus: UNR Med-controlled clinical, educational, and administrative spaces. Activities in shared facilities and common-use spaces (e.g., atriums or venues reserved by other colleges or units) are not categorically prohibited by this policy.

Clinical Services: Provision of medical care to patients in a clinical environment for which payment by the patient, patient’s insurance, government programs (Medicare/Medicaid) and/or other payor is intended

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.

Purpose/Background

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 related to academic and clinical activities.

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 sales, marketing, or other product-oriented activities that include UNR Med staff, residents, fellows, employed faculty, and Letters of Appointment (LOA)

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. The UNR Med Conflict of Interest 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 residents or fellows train with clinicians who are not UNR Med faculty, UNR Med residents or fellows should continue to follow the principles established in this policy. For example, UNR Med residents, or fellows should not accept gifts provided by a pharmaceutical representative at an outside site. UNR Med residents or fellows who perceive that such refusal might jeopardize their evaluations should report their concerns to 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.

Clinical Activities

The UNR-Renown Affiliation Agreement (Affiliation Agreement) requires that UNR employed academic clinical faculty do not participate in clinical activity outside of Renown Health without prior written approval.

Clinical Activity Rules

Exclusive Clinical Affiliation: All UNR employed academic clinical faculty must provide clinical services only through Renown Health within the Designated Area as defined in the Affiliation Agreement. Questions about the Designated Area can be directed to the UNR Med Compliance Office.
No Independent Practice: UNR Med employed academic clinical faculty cannot engage in, own, operate, or provide clinical services outside Renown Health without prior written approval.

Permitted Exceptions

Existing Clinical Affiliations
Academic Affiliations (teaching/research)
GME Rotations for purposes of teaching
UME Rotations for purposes of teaching: New affiliations allowed with notice and AOC consultation.
Other Health Professions: Nursing, dental, psychology, counseling programs.

Individual Exemptions

Any exemptions must be approved in writing by Dean/CAO and the Assistant Dean of Clinical Affairs /CMO. Conditions:

Exemptions must be documented and maintained by both UNR and Renown Health. If either party denies the request, the request is denied.
Exemptions are revocable with 30 days’ notice
Exemptions must be reviewed annually through the COI process
Exemptions must be requested through UNR’s Compensated Outside Activity process and disclosed in annual COI reports

The above section does not apply to graduate medical education. Residents and fellows should follow GME policies on moonlighting. Moonlighting does not include incidental or unrelated personal activities not connected to professional duties

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 the UNR Med 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 teaching 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, UNR Med , residents, fellows, employed faculty, Letters of Appointment (LOA), and staff may be organized to include presentations in a “roundtable” or open discussion forum where Industry, UNR Med residents, fellows, employed faculty, Letters of Appointment (LOA), and staff 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, residents, fellows, employed faculty, Letters of Appointment (LOA), and staff 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 residents, fellows, employed faculty, Letters of Appointment (LOA), and staff 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 residents, fellows, employed faculty, Letters of Appointment (LOA), and staff, 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. Research-related vendor interactions must comply with applicable university-wide and UNR Med policies.

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 Office of Continuing Medical Education and then by UNR Med Office of General Counsel.

Industry-Supported Speaking and Authorship in Industry Sponsored Research

All UNR Med, residents, fellows, employed faculty, Letters of Appointment (LOA), and staff, are not to participate in industry-related “speakers bureaus.” A speakers’ bureau has the following characteristics:

the company has the contractual right to dictate or control the content of your presentation or talk, and/or
the company creates the slides or presentation material and has final approval of the content and edits, and/or
you are expected to act as a company’s agent or spokesperson for the purpose of disseminating company or product information.

Open Payments Law Compliance

UNR Med residents, fellows, employed faculty, Letters of Appointment (LOA), and staff 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, 4/29/2026