OHSU

Gifts

OHSU Gift Policy Links:

 

Gift Policy Summary:

  • The final policy on Gifts to Individuals includes the prohibition on individual gifts without regard to dollar value as recommended by national standards. However, this prohibition is limited to those in a "Position of Authority" with respect to the vendor offering the gift. 

  • Position of Authority is defined as: A position in which one does or is expected or anticipated to influence the selection, retention, evaluation, direction, or supervision of a vendor.  Any position that could influence the decision to place business, increase or decrease business, or continue, modify, or terminate a relationship with a vendor.  This includes but is not limited to:
    o    Health care providers with prescription privileges;
    o    OHSU Members with grants who purchase supplies related to the grant activities;
    o    OHSU Members with fiscal authority related to a specific business decision;
    o    A person who is a voting member of a RFP (request for proposals) committee;
    o    Each OHSU employee as to all vendor relationships:
         -  Within the employee's oversight authority;
         -  Where the vendor relationship is a part of a vendor selection process in which the employee participates; and/or
         -  Where the employee exerts or attempt to exert influence over the awarding of business to the vendor; and

    o    Employees with authority over specific financial decisions related to a vendor. 

  • OHSU policy requires that promotional gifts such as mugs, pens, notepads, clocks,  t-shirts, and similar items displaying vendor logos or symbols not be accepted by any OHSU Member (defined as all OHSU officers, employees, faculty, students, trainees, and volunteers).  These items must not be present on OHSU campuses.

  • The Gifts to OHSU policy includes the requirement that food provided at OHSU educational events must be paid for with funds provided to OHSU (as an unrestricted gift) and may not be directly provided by vendors.   

  • Additional requirements for OHSU Members participating in lectures and meetings directly sponsored by industry are outlined in the Gifts to OHSU policy as originally proposed and include that OHSU Members must have control over the content of the presentation, which must reflect a balanced assessment and not be promotional for a particular vendor's product(s).   

OHSU policies meet the requirements of the revised Oregon Ethics law.  The Oregon law also limits gifts from OHSU Vendors that may be accepted or solicited by your relatives, including spouse or domestic partner, child, sibling, spouse of sibling, parent, and spouse's parent.   OHSU policy advises you to instruct your relatives about the limitations on their accepting gifts.

 


 

OHSU Gift Resources:

The Integrity Office is happy to meet with schools, departments, and units to assist in education on the final policies. If you have any questions, please contact Dr. Gary Chiodo, Chief Integrity Officer, or Dr. Kara Manning Drolet, Associate Director, ORIO/OIO, or call 503-494-8849 (option 3).  We are available to attend department, School, committee, or operational unit meetings to discuss the gifts policies and respond to questions.


 

Physician Payment "Sunshine Provisions"

OHSU Members should be aware that the Patient Protection and Affordable Health Care Act includes new "Sunshine Provisions," requiring pharmaceutical, medical device, biological, and medical supply manufacturers to begin reporting to the federal government the payments they make to physicians and teaching hospitals.

Additionally, the law requires the Secretary of Health and Human Services to make this payment and ownership interest information available on a publicly accessible, searchable, and downloadable website. As a result, manufacturers' payments to consultants, researchers, and others; physician ownership interests held in a manufacturer or Group Purchasing Organization; and important information related to such payments and disclosures, will now be a matter of public record.

The scope of reportable payments is broad and includes consulting fees, compensation for non-consulting services, honoraria, gifts, entertainment, food, travel, education, research, charitable contributions, royalties or licenses, current or prospective ownership or investment interests, direct compensation for serving as faculty or as a speaker for a medical education program, and grants.

Reporting requirements begin in March 2013.  The Integrity Office will be monitoring this public database to ensure that all payments received by physicians have been disclosed on the Conflict of Interest disclosure form(s) as appropriate, and that gifts in violation of the OHSU Gifts Policies have not been received.

Additional resources on the Physician Payment Sunshine Provisions:

AAMC Summary PDF Icon

Ropes & Gray summary PDF Icon