Interactions with Vendors Policy
The Interactions With Vendors Policy at Children's Hospital of Philadelphia is designed to:
- Provide guidance regarding appropriate interactions of Hospital healthcare and research professionals and administrative staff with vendors
- Minimize actual or perceived undue influence of vendors on business decisions of Hospital professionals and administrative staff
- Support the safety and privacy of patients and research subjects
Summary of key policy provisions
Gifts, meals and compensation
- Gifts to Hospital personnel are prohibited. This includes token items such as pens and pads, cash or cash equivalents such as gift cards, raffled items, entertainment, payment/reimbursement of travel expenses when not given in exchange for services under a formal arrangement, and any other item of value for which something of equal value is not provided in exchange.
- Food may not be provided to Hospital personnel on-site. This includes snacks, meals, holiday gifts baskets, and any other food or drink.
- Except for modest meals in a supplier’s office while working on Hospital business, meals at supplier’s expense at any off-site location (e.g., restaurants) are prohibited.
- Non-cash gifts from vendors to the Hospital or clinical departments (but not individuals) may be accepted, with advance approval, if serving a substantial clinical, research or educational function.
- Participation by Hospital personnel in supplier-sponsored speakers bureaus is discouraged. For clinicians and researchers speaking on professional topics, certain restrictions apply (e.g., the supplier may not restrict or censor the content of the presentation).
- Hospital personnel may not allow their professional presentations (oral or written) to be ghostwritten by anyone.
Supplier funding for Hospital-run educational programs
- All arrangements for supplier funding of educational programs for clinicians or researchers must be handled through the Continuing Medical Education Department (or for nursing education, the Office of Nursing Education).
- All supplier funding for education programs must:
- Be made in the form of an educational grant to the Hospital or The Children’s Hospital Foundation and documented in an approved written agreement.
- Follow the relevant accrediting bodies’ standards for commercial support (e.g., ACCME or
American Nurses Credentialing Center
Purchasing decision making
- Hospital personnel who are decision makers with actual, potential or perceived conflicts with respect to a supplier must:
- Disclose the conflict.
- Not participate in the decision about which supplier to select (except to provide any important information to others).
Supplier support for research
- All supplier support for research (whether funding or in-kind donations) must be paid or gifted to the Hospital or The Children’s Hospital Foundation, approved by the Office of Technology Transfer and documented in an approved written agreement.
- Vendors may not prohibit the Hospital or its personnel from publishing the results of the Hospital’s research.
Supplier funds for resident and fellow training
- All supplier funding for resident and fellow training must be:
- In the form of a grant to the Hospital or The Children’s Hospital Foundation (not directly to individual personnel, departments, divisions or programs), approved by the Graduate Medical Education Committee and documented in an approved written agreement.
- Specifically for the purpose of education and free of any actual or perceived conflict of interest.
- The selection of the trainee who will receive the support is to be exclusively in the control of a Hospital department, division or program, and the supplier may not recommend or suggest a candidate.
Supplier gifts for other purposes
- For other situations in which vendors may seek to provide support for Hospital programs, such as funding a position in a clinical division, the terms under which such support may be accepted (if at all) are subject to advance review by the Office of General Counsel, and the support must be documented in an approved written agreement with the Hospital or The Children's Hospital Foundation.