COI and the Sleep and Health Benefit Dinner

A new Massachusetts law effective July 1, 2009, affects pharmaceutical and medical device manufacturers making provisions or payment for meals for health care practitioners licensed in the Commonwealth of Massachusetts (Chapter 111N and implementing regulations). In response, the Division of Sleep Medicine has adopted a new policy to ensure that support from our affected sponsors will not be used to offset the cost of meals of health care practitioners attending the event. Download (pdf 69kb) our policy statement regarding Faculty attendance at the Sleep and Health Benefit Dinner.

Message to DSM Affiliated Faculty:

Massachusetts General Laws, Chapter 111N “Pharmaceutical and Medical Device Manufacturer Conduct” and other nationwide conversations about Conflict of Interest (COI) have significantly changed the landscape in which an event like ours occurs. The intention of the new Massachusetts law, effective July 1, 2009, is to provide specific guidelines for company conduct to avoid creating or the appearance of creating a conflict of interest. Our annual Benefit dinner is impacted because the law disallows companies from subsidizing or paying for event meals like ours for health care practitioners who are licensed by the Commonwealth of Massachusetts. Harvard University, the Medical School and hospitals – like others around the country – have also responded to these changes by implementing policies and guidelines for their own faculty and staff to protect them against real or perceived conflict.

In the past, DSM Affiliated Faculty may have attended this event as the invited guest of a pharmaceutical or medical device manufacturer, or of the Division itself (potentially subsidized by funds raised from many pharmaceutical and medical device manufacturers). This year, in order to provide a mechanism by which the pharmaceutical and medical device manufacturers can continue to support our Benefit Dinner, yet be in full compliance with Chapter 111N, and also to enable our faculty to participate under the guidelines of their institution(s), we have conferred with Harvard, HMS, Partners and BIDMC and adopted the following policy: that those affiliated faculty members who are health care practitioners licensed by the Commonwealth of Massachusetts must pay the fair market value of their meal at the Benefit Dinner, so that they cannot be said to have been subsidized and thereby suffer COI.

Gifts above the fair market value of this dinner are naturally also quite welcome, and will be recognized as they have in the past. We are honored by our faculty members’ gifts, and believe that they demonstrate support within our academic community that is crucial for the success of the Division’s educational mission and advancement of sleep science at Harvard.

Please contact us if you have any questions or concerns. We thank our faculty for their support.


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