Disclosing Financial Interests: Vendor Relationships

Employee-Vendor Relationships

It is the policy of the University to separate an employee's University and private interests, and to safeguard the University and its employees against charges of favoritism in acquisition of goods and services. University employees must disqualify themselves from participating in a University decision involving the purchasing of goods and services for the University if there exists a financial conflict of interest. No purchase, lease of goods, or contract for services shall be made from any employee or near relative (husband, wife, mother, father, daughter, son, sister, brother, in-laws and step-relatives in the same relationships) who has an employee-vendor relationship unless there has been a specific determination by the Materiel Manager or designee that the goods or services are not available either from commercial sources or from the University's own facilities.

If an employee-vendor relationship exists, it must disclosed to IPPS following the procedures outlined at buy-pay/responsible/policies/relationships. A careful analysis of the relationship may result in approval. Such relationships must be disclosed at the supplier setup process through Payment Compass or within a Oracle requisition. To disclose a relationship, complete and submit the Employee-Vendor Relationship Disclosure form (PDF).

If outgoing services or subaward are being issued the UCSD procurement COI policies must be followed at https://blink.ucsd.edu/buy-pay/responsible/policies/relationships.html.  If the outgoing services or subaward involves research and the PI has a financial conflict of interest with the outgoing service or subaward, the department and/or IIPS needs to contact the UCSD COI office (info-coi@ucsd.edu) to collect a COI disclosure in Kuali COI.  The COI office will collect a COI disclosure and the conflict will be presented to UCSD’s Independent Review Committee (IRC) for COI to develop a COI management plan, if necessary. 

Overview:

In July 2008, the University of California implemented a new policy; Policy on Health Care Vendor Relations, which provides systemwide standards aimed at eliminating the potential of industry influence on health care provider's decision making. This move is in keeping with approaches implemented at other Academic Medical Centers across the country.

Health Care Vendor Relations Policy:

• Prohibits gifts from vendors made directly to individuals
  • Examples of gifts include: free lunches, free drug samples, free promotional products
  • The policy permits vendors to donate money to the "Regents of UC" to support the University's mission of education, patient care and research. There is also an exception for sample donations for use in the University-sanctioned free clinics
• Prohibits uninvited health care vendor sales calls
• Prohibits on-site use of any branded promotional products
• Enhances patient confidentiality provisions
• Requires that vendor paid preceptorships be conducted as either University courses or as continuing education courses
• Requires training on the new policy with all affected individuals

The policy applies to all UC workforce members including UCSD Health Sciences, UCSD Medical Center, and UCSD Medical Group personnel.

Related Resources:

• UC Health Care Vendor Relations Policy (PDF)
• UC Health Care Vendor Relations Policy PowerPoint Presentation (PPT)
• Frequently Asked Questions (PDF)
• UC Announcement Letter by President Dynes (PDF)
• ACCME - Standards for Commercial Support of Continuing Medical Education from Industry (PDF)

Contacts:

• Compliance Advisory Services (858-657-7487), hscomply@ucsd.edu.