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

AUDIENCE
All medical students and faculty

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

POLICY

  1. Faculty members and other university representatives who provide academic assessment of students should be free from conflicting relationships with students.
  2. Students, residents, faculty, and staff are regularly informed of the School’s Conflict of Interest (COI) policy. The COI policy is:
    1. Emailed to all students, residents, and faculty at the start of each academic year.
    2. Presented to students during Orientation activities at the start of each phase of the curriculum.
    3. Posted to students’ learning management systems.
    4. Posted on the School’s website.

DEFINITIONS

Conflicting relationship or COI may result from one or more of the following:

  1. Student is an immediate family member of the faculty, resident, or staff member who is assessing the student.
  2. Student has a personal financial relationship with the faculty, resident, or staff member.
  3. Student has received medical or mental healthcare from the faculty, resident, or staff member.
  4. Student has an immediate family member who has received medical or mental healthcare from the faculty, resident, or staff member. Immediate family members include:
    1. Spouse
    2. Child or step-child
    3. Parent
    4. Sibling
    5. Mother/Father-in-law
    6. Sister/Brother-in-law
    7. Grandparent
    8. Step-parent or step-sibling
    9. Member of the immediate household
  5. Student, faculty, resident, or staff perceive a COI to exist that is not specified above (items A-D), for which additional information may be requested.

PROCEDURE

  1. Identification of COIs

Whenever possible, potential COIs should be identified prior to 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 provided with a list of known faculty or residents participating in the assessment of students at the start of each academic year.
      2. Any student who identifies a potential COI at the start of the academic year must inform the Associate Dean of Curriculum and their designee(s) in writing within one week in order 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 with a faculty member or resident with whom a COI could exist for a future experience must inform the Associate Dean of Curriculum and their designee(s) in writing within one week from the schedule being posted.
      4. Failure to notify the Associate Dean of Curriculum and their designee(s) of potential COIs 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 Associate Dean of Curriculum and their designee(s). The appropriate staff member will work closely with the Associate Dean of Curriculum to create a plan to remove the faculty, resident, or staff member from the assessment of the student.
  2. Faculty and Resident Identification of COI
    1. Faculty members and residents are provided with a class roster (including photos) at the start of each academic year to identify any potential students with whom they may have a COI.
    2. Faculty and residents in clinical departments are provided with rotation-specific rosters prior to the start of each rotation by the Associate Dean of Curriculum.
    3. All faculty members and residents who assess students should disclose in writing the presence of a COI to the Associate Dean of Curriculum and to their designee(s) at the start of each academic year.
  3. Faculty members and residents who identify an immediate COI should immediately notify the Associate Dean of Curriculum and their designee(s). The appropriate staff member will work closely with the Associate Dean of Curriculum to create a plan to remove the faculty, resident, or staff member from the assessment of the student.
  4. All faculty members and residents must confirm the lack of a COI for each student they assess on the individual assessment forms completed for each learning experience.
  5. Faculty, students and staff who serve on a School committee which 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. 
    1. Committees include, but are not limited to:
      1. Faculty Executive Committee, and its standing committees:
        1. Admissions Committee, and its subcommittees
        2. Committee on Student Promotions
        3. Committee for Honors and Awards

Any COI identified exists until the student is no longer a student (as defined in Section 2. c.).

Sanctions for Breach of Policy

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

Reports of suspected violations may be made to the Associate Dean of Curriculum and their designee(s). Suspected violations will be investigated and appropriate sanctions will be determined by the following, as appropriate:

  1. Associate Dean of Curriculum and the Office of Human Resources
  2. Associate Dean of Students
  3. Associate Dean of Graduate Medical Education
  4. Vice Dean for Medical Education and/or their designee
  5. Dean, School of Medicine and/or their designee

Possible sanctions may include:

  1. Written advisory for placement 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

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

    REVIEWED DATE and REVIEW CYCLE
    July 2021; 3-year cycle