AACE Conflicts of Interests Policy

AACE is dedicated to the art and science of clinical endocrinology and enhancing the ability of its members to provide quality care to their patients. The Organization is a recognized leader in the delivery of education, clinical practice guidelines and other information resources worldwide. Confidence and trust in the integrity of the Organization’s resources is enhanced by maintaining independence and transparency in financial relationships with Companies. That integrity may be questioned if the Organization does not demonstrate a commitment to these values via a robust conflict of interest policy (“COI Policy”) including disclosures, management, and restriction of financial relationships that could be perceived to compromise the Organization’s objective voice.

  1. APPLICABILITY

The COI Policy applies to all employees and staff of the Organization as well as all persons who participate on the Organization’s boards, committees, and task forces, or in any volunteer activity, whether or not the activity includes a stipend, in an official capacity for the Organization.  The COI Policy is intended to be adapted for implementation in connection with particular roles or activities.  

Portions of this policy apply to the following Organization leadership and volunteers (collectively “Volunteers”):

  • Executive Committee
  • Board Members
  • Committee Chairs
  • Committee Members
  • Guideline Chairs
  • Guideline Panels
  • Journal Editor-In-Chief
  • Journal Co- or Assistant Editors-In Chief

This COI Policy interprets and implements the Organization’s COI principles as they relate to those in leadership positions within and for the Organization. Specific decisions made in accordance with this policy are included in this document. Any issue not specifically addressed herein will be managed on a case-by-case basis consistent with Organization policies and procedures.

  1. DEFINITIONS
  • Blind Trust – A trust instrument in which the trustee has full discretion over the assets, and the trust beneficiaries has no knowledge of the holdings of the trust. The trustor initiates the trust and maintains the ability to terminate the trust, but otherwise exercises no control over the actions taken within the trust and receives no reports from the trustee while the blind trust is in force.
  • Clinical Practice Guideline (“CPG” or “Guideline”) - A systematically developed statement to assist practitioner and patient decisions about appropriate healthcare for specific clinical circumstances. The term Clinical Practice Guideline also refers to Algorithms or any other evidence-based clinical practice tools, as well as updates to existing Clinical Practice Guidelines.
  • Code for interactions with companies Council of Medical Specialty Societies (“CMSS”) (“CMSS Code” or “Code”) - A voluntary “code of conduct” for Medical Specialty Societies, developed by the CMSS, to enhance professionalism and to disclose, manage, and resolve relationships with the industry. The Organization’s Boards voted to adopt the CMSS Code at their July 2018 meeting.
  • Company - A Company is a for-profit entity that develops, produces, markets, or distributes drugs, devices, services or therapies used to diagnose, treat, monitor, manage, and alleviate health conditions. “Company” may be used interchangeably with “manufacturer” or “industry”.
  • Conflict of Interest (COI) – A situation when professional judgment concerning some primary interest or responsibility is affected by a secondary interest or responsibility. This may occur whenever the interests of a Volunteer may be seen as competing with the interests of the Organization. A monetary payment, or in-kind value, given to an individual by a third party that does not fit the definition of a Company, in association with giving a CME presentation, does not create a presumption of a COI.
  • Continuing Medical Education (CME) - CME consists of educational activities for which the learner may receive CME credit (e.g. American Medical Association (AMA) Physician’s Recognition Award Credit, American Academy of Family Physicians (AAFP) Prescribed or Elective Credit, American Osteopathic Association (AOA) Credit – various categories) based on accreditation awarded to the continuing education provider by a recognized accrediting body (e.g., Accreditation Council for Continuing Medical Education (ACCME), AOA, AAFP). CME activities “serve to maintain, develop, or increase the knowledge, skills, and professional performance and relationships that a physician uses to provide services for patients, the public, or the profession.”
  • Covered Transactions - Any direct financial relationship in which there may be an actual or perceived conflict of interest.
  • Direct Financial Relationship (DFR) - A relationship held by an individual that results in wages, consulting fees, honoraria, or other compensation (in cash, in stock or stock options, or in kind), whether paid to the individual or to another entity at the direction of the individual, for the individual’s services or expertise. This definition does not include intellectual property licensing arrangements or payments in connection with giving an accredited CME presentation.
  • Journal - A Journal or “Society Journal” is a peer-reviewed scientific journal published by a Society or by a publisher on a Society’s behalf.
  • Related Society – Any national or international medical or disease oriented professional, scientific, education, research, or advocacy organization whose primary mission includes the prevention, diagnosis, or treatment of any endocrine disease.
  • Satellite CME Symposium - A Satellite CME Symposium is a Company-supported CME program held as an adjunct to a Society meeting where CME credit for the Symposium is provided by a third party CME provider, and for which the Society receives a fee.
  • Significant Ownership Interest – Possession of shares of a publicly traded Company greater than $50,000 in value or an equity interest in a privately held Company greater than 5% at the time of disclosure. This does not include interests invested in diversified funds whose holdings cannot be controlled by the disclosing individual.
  • Speakers’ Bureau - means a compensated role as a presenter for which any of the following criteria are met: (a) a Company has a contractual right to dictate or control the content of the presentation or talk; (b) a Company creates the slides or presentation material and has final approval of the content and edits; or (c) the presenter is expected to act as a Company’s agent or spokesperson for the primary purpose of disseminating company or product information. Some activities called “speakers’ bureaus” may not meet these criteria and, conversely, activities may meet these criteria and not be termed “speakers’ bureaus.” AACE will rely on the judgment and integrity of disclosing individuals to determine whether an activity constitutes a speakers’ bureau.
  1. COI DISCLOSURES

At the beginning of each association year, and on an as needed basis throughout the year, Volunteers must provide a disclosure of all DFR with any Company and include other relationships that may give rise to COI, including non-financial relationships, such as certain volunteer positions with Related Societies. Specific disclosure requirements will be included on a COI disclosure form provided to Volunteers. The COI forms will assist the Organization in managing COI.

Disclosure should be made at the beginning of service, then annually, and include any disclosable exchange that occurred over the previous 12 months. Disclosure should be updated when there are material changes in the information disclosed. Disclosure must be made whether compensation is paid directly to the individual leader or to the leader’s institution or to another entity such as a charity. Disclosure should include financial interests and relationships held by the individual’s spouse, domestic partner or dependent child. These disclosures will remain under consideration for COI purposes until the start of the next association year when the leader completes a new disclosure form.

Staff will compare COI disclosure forms to publicly available sources of information (e.g., the Open Payments database) of a Volunteer’s DFR. This will be done to ensure that publicly available data matches the information provided to the Organization. Volunteers may be asked to provide an explanation for any discrepancies, so the Organization is prepared to respond to any questions regarding Volunteer or Organization COI.

  1. MANAGEMENT OF CONFLICTS

The management of actual or potential COI will depend on the particular circumstances, including the nature and extent of the financial interest or relationship. Volunteers should recuse themselves from decisions in situations where they have a COI or a potential conflict. Participation in discussions and deliberations, and speaking publicly on behalf of the Organization, may be permissible as long as the financial interest or relationship is disclosed.

Any COI management procedures, including announcing a conflict, dismissals from discussion, and recusals from voting, will be documented in meeting minutes.

The Professional Standards Committee (PSC) will work with staff to ensure that conflicts are managed appropriately. Prior to any deliberative session, including Board, Committee, Guideline Development Meetings, staff will work with appropriate Chairs to identify potential COI and determine the appropriate strategy to manage the COI. Any questions regarding COI management should be addressed to the PSC.

Conflict management procedures are as follows:

  • If the volunteer leader has a conflict with a company who is specifically implicated by a policy, the member will not vote on that specific issue, and the President or Chair may ask the member to exit the room, or not otherwise participate, during discussion.
  • If the volunteer leader has a conflict with a company that is generally, but not specifically, implicated by a policy, the member may discuss the policy but not vote. This will be the level of scrutiny applied to votes approving guidelines or other papers or positions regarding clinical guidance.
  • If the volunteer leader has a conflict with a company who makes a product for a disease state, but the discussion is broad enough that it does not implicate the product generally, the member should announce their conflict before commenting on the issue, but the member may vote.
  • When the President or Committee Chairs consider conflict management issues prior to meetings they will also consider the dollar values at issue and any other variables that are relevant to a perceived conflict. If the President or Chair believes that the conflict is so great as to require higher scrutiny than what is otherwise prescribed, they may exercise their discretion and require heightened management.
  1. RESTRICTION ON FINANCIAL RELATIONSHIPS

Certain volunteer positions, because of their public visibility, or necessity for the perception of unbiased work product, require a more stringent approach to COI. The following table includes COI rules for each volunteer position (for more detailed information see attachment 1):

Volunteer Position

COI Restrictions

Executive Committee
(EC)

  • No DFR* with a Company that develops products connected with endocrine disorders.
  • No service as a fiduciary, committee chair, or chair of major projects (e.g., guidelines) for a Related Society.
  • No participation, beyond that of an attendee, of Satellite CME Symposium.
  • No participation in promotional/marketing events at any meeting connected with AACE.
  • No direct stock ownership by EC member, their spouse, or dependent children, in an amount greater than $50,000 of a Company that develops products connected with endocrine disorders. Stock ownership that exceeds $50,000 may be placed in a blind trust. Ownership of stock in a mutual, index, or similar fund, where the Volunteer does not have control of stock purchasing is permissible.
  • May not be a full or part-time employee of a Company.

Board Member

  • Any DFR* greater than $10,000 with a Company that develops products connected with endocrine disorders will be managed in a manner as described above.
  • Participation as a fiduciary, committee chair, or major project chair for a Related Society will receive heightened scrutiny. Though it is not prohibited, the PSC may require Board Members to divest of certain Related Society relationships.
  • Direct stock ownership of a Company by the member, their spouse, or dependent children, that develops products connected with endocrine disorders in an amount greater than $50,000 will be treated as a COI and require management. Ownership of stock in a mutual, index, or similar fund, where the Volunteer does not have control of stock purchasing is permissible.
  • May not be a full or part-time employee of a Company.

Committee Chair

  • Any DFR* greater than $10,000 with a Company that develops products connected with endocrine disorders will be managed in a manner as described above.
  • May not be a full or part-time employee of a Company.
  • Participation with a Related Society will be reviewed by PSC prior to appointment as chair and may be disqualifying.
  • Direct stock ownership of a Company that develops products connected with endocrine disorders in an amount greater than $50,000 will be treated as a COI and require management. Ownership of stock in a mutual, index, or similar fund, where the Volunteer does not have control of stock purchasing is permissible.

Committee Member

  • DFR will require COI management.
  • Certain volunteer roles at a Related Society will require COI management.
  • Employment with a Company will receive heightened scrutiny and may be disqualifying for committee service

Journal EIC/Co-EIC

  • No DFR* with a Company that develops products connected with endocrine disorders.

Guideline Chair

  • No DFR* greater than $10,000 with a Company that develops products connected with affected companies – in the event there are multiple guideline chairs, a co-chair may, with special approval by both the PSC and Clinical Practice Guidelines Oversight Committee, have a DFR greater than $10,000 with an affected company. However, at least one guideline chair MUST have no DFR greater than $10,000 with an affected company - see section 6 for more information.
  • Other COI prohibitions as defined in section 6 below.
  • No DFR with affected companies for at least 1 year after publication of guidelines.
  • May not be, or have been within the preceding 12 months, employed by any affected company.
  • No direct stock ownership by the Chair, their spouse, or dependent children, in an amount greater than $50,000 of a Company that develops products connected with endocrine disorders. Stock ownership that exceeds $50,000 may be placed in a blind trust. Ownership of stock in a mutual, index, or similar fund, where the Volunteer does not have control of stock purchasing is permissible.

Guideline Panel

  • A COI is defined as a DFR* greater than $10,000 with a Company that is affected by the guidelines.
  • Other COI prohibitions as defined in section 6 below.
  • At least 51% of every guideline panel must be free of COI.
  • No DFR with affected Companies for at least 1 year after publication of guidelines.
  • May not be, or have been within the preceding 12 months, employed by any affected company.
  • Direct stock ownership of a Company that develops products connected with endocrine disorders in an amount greater than $50,000 will be treated as a COI and require management.

Executive Staff
(Members of Executive Leadership Team)

  • No DFR.
  • No volunteer service for a Related Society
  • The CEO may not have direct stock ownership in any Company that develops products related to endocrine disorders.
  • All other Executive Staff is prohibited from holding a Significant Ownership Interest in a Company that develops products connected with endocrine disorders.
  • Where there is a prohibition on DFR, or a DFR triggers a COI relationship at a specific dollar value, where asterisked, the Volunteer: may provide uncompensated service to Companies and accept reasonable travel reimbursement in connection with those services; may accept research support as long as grant money is paid to the institution (e.g., academic medical center) or practice where the research is conducted, not to the individual; may receive wages or other compensation from a Company in exchange for providing or overseeing the provision of health services to Company personnel; and may accept reasonable compensation for serving on an independent data safety monitoring board in a Company study.

Any requests for deviations from the restrictions listed above will be evaluated by the PSC and require approval from the Executive Committee.

  1. CLINICAL PRACTICE GUIDELINE COI PROCEDURES

Organization guidelines are a critical tool for the treatment of endocrine disorders worldwide. Clinician and public confidence in these guidelines is paramount, and depends on the cultivation of expert opinions based on the best available evidence and in a manner designed to minimize actual and perceived conflicts of interest.

The Organization requires COI disclosure by individuals involved in drafting, reviewing, and approving guideline recommendations and sets limits on the financial relationships that panel members and reviewers can have with Companies that could reasonably be affected by care delivered in accordance with guideline recommendations. As a signatory to the CMSS Code, the Organization requires the majority of panel members (51%), including the panel chair, to be free of certain relationships with affected Companies. The remaining 49% of panel members may be appointed to a panel if they hold some relationships with affected Companies; however, the Clinical Practice Guidelines Oversight Committee should consider forming guideline panels with minimal COI.

  1. Identifying Affected Companies

Companies with products affected by a guideline are considered “affected Companies” for purposes of determining whether a conflict of interest exists in the development of Organization guidelines. A Company is an “affected Company” if there is a reasonable likelihood of direct regulatory or commercial impact (positive or negative) on the entity as a result of care delivered in accordance with guideline recommendations.

Affected Companies will generally be identified at the time of development of the guideline protocol, prior to selection of panel members, chairs or co-chairs. Affected Companies will generally be identified by an independent party who will not serve as a panel member or guideline reviewer. The list of affected Companies should remain consistent throughout guideline development and adoption. If changes in the marketplace or in the focus of the guideline make revisions necessary, a modified list may be developed or reviewed by the independent party. The list of Companies affected by a guideline will be made available to prospective guideline panel chairs and panel members and the Clinical Practice Guideline Oversight Committee.

  1. Disclosures

All prospective panel members, including prospective panel chairs and co-chairs, will disclose financial interests and other relationships with Companies in accordance with Organization’s COI Policy. The disclosure form used is general and may or may not necessarily identify relationships with affected Companies. If a potential Guideline Panel member is not current serving on an Organization committee, and therefore does not have a current COI form on file with the Organization, the panel member will fill out the standard COI form.

After reviewing the general disclosures and the list of affected Companies, the Clinical Practice Guideline Oversite Committee Chair or staff may request more detailed information from an individual about the nature, value, or extent of his or her disclosed relationship with an affected Company in order to apply this COI Policy.

Occasionally, an individual may have a relevant indirect or non-financial interest or relationship that is not covered by Organization’s general COI disclosure, such as an intellectual property interest from which no royalties or other payments have yet been received; a strong professional or research opinion; or an outside affiliation. In these situations, the interest should be disclosed to the panel chair or co-chair or appropriate staff.

Disclosure reports identifying panel members’ relationships with affected Companies will be available to panel members throughout the guideline development process. The Organization body responsible for final guideline approval will have this information available when considering guideline recommendations.

  1. Panel Eligibility

Having a relationship with a Company does not necessarily mean an individual is biased or has a conflict of interest. However, certain financial relationships give rise to conflicts of interest that are not capable of being effectively managed and are, in fact, inconsistent with actual and perceived independence in the guideline development process. An individual is not eligible to serve on a clinical practice guideline panel if he or she:

  • is employed by an affected Company, or has been employed by an affected Company at any time during the year prior to appointment to the panel and to continue for one year after the publication of the guideline;
  • holds a significant ownership interest in an affected Company;
  • serves as a national principal investigator (PI) on a class of drugs, or a medical device, or other medical product that is indicated for use by the proposed guidelines; or
  • has a financial relationship with an affected company that, in Organization’s discretion cannot be effectively managed.
  1. Guideline Chair

Generally, individuals who have disclosed financial interests in or relationships with affected Companies will not be appointed as panel chairs or co-chairs. A panel chair or co-chair must have been free of all interests and relationships for one year prior to appointment as chair and remain free of these interests and relationships at all times during the panel’s work and through one year after the guideline is published.

However, the Clinical Practice Guidelines Oversight Committee may appoint a panel chair who has a COI relationship that is permissible for service on the minority of the panel, if doing so would ultimately help the panel develop a better-quality guideline. In this case, the Committee must appoint a co-chair who has no COI with affected Companies, including research funding.

If a panel chair or co-chair wants to continue to serve as chair for future guideline updates, he or she must remain eligible as described above. If, at the time of update, an individual is no longer eligible to serve as a chair, he or she will be eligible to serve as a panel member at the discretion of the PSC and Clinical Practice Guideline Oversight Committee and in accordance with this COI Policy.

  1. Guideline Panel

In accordance with the CMSS Code, a majority of guideline panel members must be free of conflicts of interest relevant to the subject matter of the guideline. All relationships with Companies must be disclosed as described above. The PSC, the Clinical Practice Guidelines Oversight Committee Chair or staff may ask for additional information about a relationship with an affected Company to apply this COI Policy.

For the purpose of appointing at least 51% of guideline panel members who are free of conflicts of interest, the Organization defines the following relationships as COI:

  • Research funding from an affected Company, paid to the individual or his or her practice or institution if: (a) research payments are made directly from the affected Company to the individual; (b) the individual’s salary is supported (in whole or part) through a research grant from an affected Company; (c) the individual is a national or overall principal investigator for a study funded by an affected Company, only if the product in the study is not for a class of drug, medical device, or medical product indicated for use by the proposed guidelines; and (d) the individual is a member of a steering committee of a study.
  • Compensation (including honoraria) from any one affected Company that equals, in aggregate, $10,000 or more in a calendar year, including fees and honoraria for leadership positions, consulting activities, speaking engagements, expert testimony, and patent or other licensing fees. This definition does not include disqualifying payments, as defined above.

Individuals with any of these relationships are not eligible to serve in the panel majority, but may be eligible to serve in the panel minority. A member of the panel majority must remain free of these conflicts of interest from the time of his or her appointment to the panel through the end of the calendar year in which the guideline is published. If an individual’s relationships change during that period such that he or she is no longer eligible to serve in the panel majority, the panel member will count as part of the panel minority. If that is not feasible given the panel composition, the individual must resign from the panel.

  1. Conflict Management

The Clinical Practice Guidelines Oversight Committee will be responsible for defining the policy for managing conflicts on the guideline panel. These policies will include rules for recusal, voting on specific recommendations, and Guideline Chairs will oversee conflict management policies. Any questions regarding deviations from COI management policies should be referred to the PSC.

  1. Co-written Guidelines

Any guideline where another organization is the lead or co-lead sponsor of the guideline and AACE is listed as a co-author, endorser, or some indication is given that AACE approves of the content of the guideline must be written with COI policies at least as rigorous as the AACE Clinical Practice Guidelines COI policy.

Any organization that is invited to co-author, co-sponsor, endorse or otherwise provide input and approval of an AACE sponsored guideline must adhere to guideline COI procedures at least as rigorous as the AACE Clinical Practice Guidelines COI policy.

  1. QUESTIONS

Questions about this COI Policy should be directed first to PSC staff. Any question that can not be resolved by the PSC staff, or any request for an exception to this COI Policy will be referred to the PSC, and if needed, will be escalated to the Executive Committee or Board. Exceptions will only be granted in rare circumstances.

  1. VIOLATION OF COI POLICY

This COI Policy has been created to ensure the public is certain of the Organization’s ability to enact business in a fair and objective manner. Correct and consistent application of these policies serves as a guarantee to the public and an important risk management tool for the Organization. Any Volunteer found to be in violation of this COI Policy may face punitive action from the organization, up to and including revocation of your volunteer position and potential expulsion as a member of AACE.

Any violation of this policy will be reviewed by the PSC. Recommendations regarding punitive actions will be referred to the Executive Committee or Board, consistent with Organization bylaws and COI Policy.

  1. IMPLEMENTATION

The implementation timeline for this policy is as follows:

  • The Executive Committee must be in compliance at the start of the 2020-21 year, with the expectation that they begin to wind down any relationships with industry beginning the 2019-20 association year.
  • Conflict management will begin for the Board at the beginning the 2019-20 year. This will be a trial year to better understand unexpected issues that may arise. The program will function internally and documents will not be made publicly available until the 2020-21 association year. The policy will be revisited throughout the year to make adjustments as necessary. Full implementation of the policy will be effective 2020-21
  • Committee conflict management will be effective 2020-21. Committee staff and chairs will be trained in the policy throughout the 2019-20 year but will not be expected to implement the policy in committee meetings.
  • Journal Editors-in-Chief must be in compliance beginning 2020-21.
  • The Clinical Practice Guideline Procedures will be implemented immediately upon Board adoption of this COI Policy. A Clinical Practice Guidelines Conflicts of Interest Workgroup will evaluate these policies and make recommendations for amendments.

Attachment 1

AACE/ACE Conflict of Interest Policy

Conflict of Interest: Conflict of Interest Management Grid for AACE Leadership

Disclosures must be made at least annually and when material changes occur.

 

Disclosures Reviewed By

Made Public

Executive Committee

Professional Standards Committee (PSC)

Yes

Board

President and PSC

Yes

Committee Chairs and Members

Committee Chair and PSC

Only upon request

Journal Editors-in-Chief

EC and PSC

Yes

PSC

Executive Committee

Yes

Activity

Executive Committee

Board

Committee Chairs

Committee Members

Journal Editors-in-Chief

Leadership in Related Society: Board, Committee, Journal

Not permitted

Permissible – Disclose Review by Pres and PSC, high scrutiny.

Permissible – reviewed by PSC, may be disqualifying.

Permissible - Disclose and managed

Permissible – Must be reviewed prior to acceptance of position. Reviewed by EC and PSC. High level of scrutiny.

Scientific Consultant/Advisor to Industry or Commercial Enterprise, including Development of Educational Presentations, promotional educational activities.

Disclose. Permissible only if uncompensated except for reasonable travel reimbursement.

Permissible. Disclose. Managed if amount greater than $10,000.

Permissible. Disclose. Managed if amount greater than $10,000.

Permissible. Disclose. Managed if amount greater than $10,000.

Disclose. Permissible only if uncompensated except for reasonable travel reimbursement.

Data Safety Monitoring Board for Industry or Commercial Enterprise

Disclose – Permissible only if uncompensated except for reasonable travel reimbursement

Permissible. Disclose. Managed if amount greater than $10,000

Permissible. Disclose. Managed if amount greater than $10,000)

Permissible. Disclose. Managed if amount greater than $10,000

Disclose – Permissible only if uncompensated except for reasonable travel reimbursement

Activity

Executive Committee

Board

Committee Chairs

Committee Members

Journal Editors-in-Chief

Accredited CME

Permitted – disclose as FYI - payment may not come directly from a company, or a company directed by a third party to pay the volunteer leader directly

Permitted – disclose as FYI -  If payment comes directly from a company, or a company directed by a third party to pay the volunteer leader directly then amounts will be included in COI totals

Permitted – disclose as FYI – If payment comes directly from a company, or a company directed by a third party to pay the volunteer leader directly then amounts will be included in COI totals

Permitted disclose only If payment comes directly from a company, or a company directed by a third party to pay the volunteer leader

Permitted – disclose as FYI -  payment may not come directly from a company, or a company directed by a third party to pay the volunteer leader directly

Participation in promotional or marketing events connected with AACE Annual Meeting

Not Permitted

Not Permitted

Permissible – disclose

Permissible – Disclose

Not Permitted

Commercial Speakers’ Bureau

Not permitted

Permissible – disclose for review by Chair and PSC – will receive heightened scrutiny and may be disqualifying, managed over $10,000.

Permissible – disclose for review by Chair and PSC – will receive heightened scrutiny and may be disqualifying, managed over $10,000.

Permissible – disclose for review by Chair and PSC – will receive heightened scrutiny and may be disqualifying, managed over $10,000.

Not permitted

Company Employee, Officer, Director

Not permitted

Not permitted

Not permitted

Permissible – disclose for review by Chair and PSC – will receive heightened scrutiny and may be disqualifying

No permitted

Stock/Stock
Options with Relevant Pharmaceutical or Biotechnology Companies

Disclose. Any amount greater than $50K not
permitted, except in a diversified fund or independently managed.  May set up blind trust.

Permitted - Disclose. –
Significant ownership interests will be managed as COI.

Permitted - Disclose. –
Significant ownership interests will be managed as COI.

Permitted.  Disclose and manage

Disclose. Any amount greater than $50K not
permitted, except in a diversified fund or independently managed.  May set up blind trust

Activity

Executive Committee

Board

Committee Chairs

Committee Members

Journal Editors-in-Chief

Research Grants

Permissible – disclose - Funds must be paid to institution. – consider management needs.

Permissible - Disclose – manage if funds are paid directly to member

Permissible - Disclose – manage if funds are paid directly to chair

Permissible - Disclose – manage if funds are paid directly to member

Permissible - Disclose – Funds must be paid to an institution.

Intellectual Property Rights (Patents, Royalties, Licensing fees)

Permissible - Disclose. Review for management

Permissible - Disclose. Review for management

Permissible - Disclose. Review for management

Permissible - Disclose. Review for management

Permissible - Disclose. Review for management

Other

Disclose any questionable relationships to be considered by committees or persons of jurisdiction

Disclose any questionable relationships to be considered by committees or persons of jurisdiction

Disclose any questionable relationships to be considered by committees or persons of jurisdiction

Disclose any questionable relationships to be considered by committees or persons of jurisdiction

Disclose any questionable relationships to be considered by committees or persons of jurisdiction