Harvard Medical School Revises Conflicts of Interest Policy for Faculty Relationships with Industry


The life science industry has had a long and mutually rewarding relationship with Harvard Medical School (HMS). HMS faculty members have founded life science companies, served as advisors and directors to life science companies and conducted crucial pre-clinical and clinical research in collaboration with life science companies. HMS has long maintained a policy to govern potential conflicts of interest between its faculty and the life science industry (the “Conflicts Policy”), which it recently revisited and substantially revised. These revisions will impact industry’s current and future relationships with HMS faculty. The new Conflicts Policy will take effect on a rolling basis starting in January 2011.

The changes that are relevant to life science companies include: (1) requiring public disclosure of financial interests between faculty and life science companies, (2) lowering the compensation a faculty member can earn from a life science company when participating in research related to that company’s interests, (3) introducing “wash-out” periods before (A) clinical research can be conducted following a consulting or similar arrangement and (B) a consulting or similar arrangement can be entered into following clinical research, and (4) prohibiting the participation in speaker bureaus or the provision of gifts and most travel and meals.

The revised Conflicts Policy will apply to relationships with HMS faculty in existence on January 1, 2011. Therefore, you should review your current relationships with HMS faculty to make sure that the relationship doesn’t need to be modified in light of the revisions to the Conflicts Policy. For future relationships, you should consider the nature of the relationship you want to have with an HMS faculty member, short term and long term, prior to entering into a relationship, which may require significant planning and regular review of the relationship.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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