(p. 21). Other activities identified as having a high potential for fraud and abuse include the provision of gifts, entertainment, and personal services compensation arrangements. The OIG guidelines also recommend (pp. 20–21) that manufacturers

1. separate grant-making functions from sales and marketing functions;

2. establish objective criteria for awarding grants that do not take into account the volume or value of the recipient’s purchases;

3. establish objective criteria for awarding grants that ensure that the funded activities are bona fide; and

4. refrain from controlling speakers or content of educational activities funded by grants.

The 2007 Senate Finance Committee staff report cited above concluded that most large pharmaceutical companies had established written policies and procedures on educational grants, limited sales representatives from soliciting requests or promising funding, and established a centralized mechanism for administering grants.

Two hallmarks of academic integrity are intellectual independence and accountability for one’s work. Certain practices by medical school faculty create a hidden curriculum that subverts the professional values endorsed by the formal curriculum. One example is taking credit as the author of a manuscript prepared by an unacknowledged or inadequately acknowledged industry-paid writer. (An adequate acknowledgment would specify the roles of these writers, for example, as the preparers of the first draft, as well as the roles of the listed authors.) Another example is participating in an industry speakers bureau or other long-term speaking arrangement with a company, regardless of how the relationship is labeled. One concern is that ongoing company payments for presentations (and travel to attractive locations) create a risk of undue influence. A second concern that is frequently tied to the speakers bureau label is that the company exerts substantial control over the content of a presentation. Industry influence in these arrangements may be direct (e.g., when a talk and slides are largely or entirely prepared by someone else or when speakers are instructed to provide the company-prepared responses to questions and avoid the favorable mention of competing products). Influence may also be less direct (e.g.,