PURPOSE
To outline policies and procedures pertaining to conflicts of interest related to assessment of student performance in the curriculum.

AUDIENCE
All medical students, faculty, residents, and staff

LCME STANDARD
12.5 Non-Involvement of Providers of Student Health Services in Student Assessment/Location of Student Health Records

POLICY 

DEFINITIONS

  • Conflict of Interest (COI) or conflicting relationship: incompatibility between the private interests (e.g., student's academic success) and the official responsibility (e.g., educator, health care provider, staff member, etc.) of the person employed by UC Davis School of Medicine. COI may result from one of more of the following.
    • Student is an immediate family member of the faculty or resident who is assessing the student.
    • Student has received medical or mental healthcare from the faculty or resident.
    • Student has an immediate family member who has received medical or mental healthcare from the faculty or resident.
      • Immediate family members include: Spouse, Child or Step-child, Parent, Sibling, Mother/Father-in-law, Sister/Brother-in-law, Grandparent, Step-parent or step-sibling, Member of the immediate household.
    • Student has a personal financial relationship with the faculty, resident, or staff member.
    • Student, faculty, resident, or staff perceive a COI to exist that is not specified above, for which additional information may be requested.
  1. Faculty members and other university representatives who provide academic assessment of students must be free from conflicting relationships with students.
  2. The COI policy is distributed and attested to by each student at the start of each academic year, posted on the school's website, and linked through the student's learning management system (LMS).
  3. Faculty, residents, and staff are regularly informed of the School's COI policy. 

PROCEDURE

  1. Identification of COI: Whenever possible, potential COI should be identified before the start of any coursework or committee function that requires assessment by a faculty, resident, or staff.
    1. Student Identification of COI
      1. Early Identification
        1. Students are asked to identify any COI with potential preceptors on each clinical/clerkship rotation preference form before site assignments are made.
        2. Any student who identifies a potential COI must inform the corresponding curriculum manager(s) via email within 48 hours of receipt of the site notification to ensure that the student is not scheduled with the resident or faculty member with whom the COI could exist.
        3. Students who are unknowingly scheduled for a future experience with a faculty member or resident with whom a COI could exists must inform the corresponding curriculum manager(s) via email within 48 hours of the notification.
        4. Failure to notify the corresponding curriculum manager(s) of potential COI in a timely manner could result in deferral of a course or clerkship if no other arrangements can be made.
      2. Immediate Identification
        1. Students who identify a COI in the moment should immediately notify the corresponding curriculum manager(s).
        2. The appropriate staff member(s) will work closely with the institutional designee to create a plan to remove the faculty or resident from the assessment of the student.
    2. Faculty and Resident Identification of COI
      1. Early Identification
        1. Faculty and residents in clinical departments are provided with rotation-specific rosters before the start of each rotation by the supporting curriculum coordinator(s) and/or manager(s).
        2. All faculty members and residents who assess students should disclose in writing the presence of a COI to the supporting curriculum manager(s) at the start of each academic year.
        3. The appropriate staff member(s) will work closely with institutional designee to create a plan to remove the faculty or resident from the assessment of the student.
      2. Immediate Identification
        1. Faculty or residents who identify a COI in the moment should immediately notify the Associate Dean of Curriculum and the related curriculum coordinator(s)/manager(s). 
        2. The appropriate staff member will work closely with the Associate Dean of Curriculum to create a plan to remove the faculty or resident from the assessment of the student.
    3. All faculty members and residents must confirm there is no COI for each student they assess on the individual assessment forms completed for each learning experience.
    4. Faculty, students, and staff who serve on a school committee that assesses and votes on student acceptance, progress, or promotion (including graduation) should inform the Chair of the committee on which they serve when a COI exists and recuse themselves from voting on or participating in the assessment of those students. 
      • Committees include, but are not limited to the Faculty Executive Committee (FEC) , and its standing committees, the Admissions Committee, the Committee on Student Promotions, and, Committee for Honors and Awards.
  2. Any COI identified exists until the student is no longer a student.
  3. Sanctions for a Breach of Policy
    1. Students, faculty, residents, and staff have an obligation to comply with this policy. Examples of conduct that violate this policy include, but are not limited to:
      1. Intentional deception or dishonesty in disclosures
      2. Omission of relationship disclosures
      3. Failure to comply with plans to avoid COI in student assessment
    2. Reports of suspected violations should be made to the Associate Dean for Curriculum and Medical Education.
    3. Suspected violations will be investigated and appropriate sanctions will be determined by the following individuals and entities, as appropriate:
      1. Associate Dean for Curriculum and Medical Education
      2. Associate Dean for Students
      3. Associate Dean for Graduate Medical Education
      4. Vice Dean for Medical Education
      5. Dean, School of Medicine and/or their designee
      6. Office of Human Resources
    4. Possible sanctions may include:
      1. Written advisory  in the employee, trainee, or student record
      2. Ineligibility to participate in grant applications or on committees
      3. Dismissal from an educational or training program
      4. Termination of employment

    RESPONSIBILITY
    Office of Medical Education

      REFERENCES
      UC Davis Health, Compliance and Privacy Services – Conflict of Interest
      University of California, Faculty Code of Conduct, AMP 015

      POLICY OWNER
      Associate Dean for Curriculum and Medical Education

      REVIEWED BY
      Committee on Educational Policy
      Committee on Student Promotions
      Associate Dean for Curriculum and Medical Education*

      REVIEWED DATE and REVIEW CYCLE
      January 2025; 3-year cycle