- In general, the policy applies to full-time and part-time faculty and staff (the term staff includes all employees), students, trainees and volunteers of all Johns Hopkins Medicine member organizations and all Johns Hopkins Medicine member sites including the Johns Hopkins Health System and its entities.
- Industry is defined as biomedical, pharmaceutical and medical device companies and companies that make other products used in the treatment of patients or the provision of medical care.
- Other JHM policies govern interactions with companies in other fields.
- One may not accept gifts or entertainment, regardless of value, from industry with respect to any activity at any JHM member organization site and any activity conducted under the auspices of or using the name of any JHM member organization. Adherence to this policy in other settings is strongly encouraged. It is permissible to accept medical or scientific books or anatomical models if neither the product nor its packaging carries the name or logo of a company and if the books are distributed through a School of Medicine department or via JHM.
- Consulting arrangements involving personal compensation without commensurate associated duties are considered gifts and are prohibited.
- Industry promotional items may not be distributed or displayed in any JHM facility, except as permitted at certain CME events.
- Industry-supplied food and meals are considered personal gifts and will not be permitted and may not be accepted at any JHM member organization site, in connection with activity conducted under the auspices of or using the name of any JHM member organization, or in the context of professional activity off-site. Certain exceptions exist and are outlined in the policy.
- Travel funds from industry may only be accepted in connection with approved contractual services (e.g., consulting), to view capital equipment in situ if the equipment is being considered for purchase by a JHM entity, or for meetings directly related to ongoing sponsored research.
- Gifts must be made to the University or JHHS and deposited in a departmental account. There may be no quid pro quo, nor any limitations nor conditions placed on gifts that are inconsistent with the policies of the Fund for Johns Hopkins Medicine and applicable regulations. Gifts from industry may be used by the department at its discretion to support faculty and staff education, research, and/or patient education.
- Free pharmaceutical samples and vouchers for free pharmaceutical samples may not be accepted. When samples are necessary for patient education (e.g., instructing patients in the use of inhalers), they may be accepted, provided they do not carry the name of a company or the name of the company is covered.
- Access by pharmaceutical, medical testing and other industry representatives to individual physicians will be permitted only by invitation and must be restricted to non-patient care areas. Device or other industry representatives are permitted to be present during patient care interactions only if specified conditions are met.
- The JHU SOM Office of Continuing Medical Education (OCME) is the sole provider of programs offering continuing medical education credit under the Johns Hopkins name.
- For continuing education programs at JHM sites or using the JHM name or resources and sponsored by industry but not offering AMA PRA Category 1 CME creditTM, prior approval of the general terms of the program by the Vice Dean for Education will be required.
- All industry-sponsored continuing medical education programs at JHM sites or using the JHM name or resources must comply with ACCME standards whether or not CME credit is offered.
- Industry funding may not be accepted to support the costs of internal department meetings, retreats or social events.
- Faculty members may speak at an industry-sponsored program only if the faculty member retains full control and authority over the intellectual content of the presentation, there is no provision for prior approval by industry, the company does not create the slide set, and the faculty member is not acting as a spokesperson for industry.
- Scholarships, other educational funds, and support for travel from industry or not-for-profit organizations substantially supported by industry must be given to a department or division.
- Individuals may not permit their professional publications or presentations of any kind, oral or written, regardless of medium, to be ghost-written by any party.
- An individual with conflicting interests in purchases over which she or he has any influence must report the interests and be recused from the decision-making process.