institution has a financial stake (beyond the funding of the research itself), asking the IRB at another institution to review such research, or disclosing the institutional conflict of interest to research participants.

One university’s policy lists several issues to be considered in evaluations of the circumstances that might justify institutional involvement in a human subjects research project despite a conflict of interest (University of Rochester, 2006). The case for the institution’s participation in the project is stronger to the extent that

  • the work is carried out at multiple sites (e.g., under the auspices of several institutions);

  • the institution takes a relatively passive role in the conduct of the project (e.g., the gathering of data);

  • the number of research subjects under the institution’s supervision is small;

  • an adverse effect on research subjects appears more likely if the institution is not used as a research site; and

  • the investigators conducting the research or the university resources supporting the project are essential and are not readily available elsewhere.

In a position statement on organizational aspects of physician relationships with industry, the American College of Physicians (ACP) advised that “[m]edical professional societies that accept industry support or other external funding should be aware of potential bias and conflicts of interest” (Coyle et al., 2002b, p. 405). It recommended the adoption of explicit institutional policies on industry relationships, including policies that “avoid reliance on outside sources of support” and that guide the acceptance and disclosure of funding from industry and other outside sources. The ACP position on educational programs is that “it is unethical for academic institutions and educational organizations to accept any support that is explicitly or implicitly conditioned on industry’s opportunity to influence the selection of instructors, speakers, invitees, topics, or content and materials of educational sessions” (Coyle et al., 2002b, p. 405).

In a 2006 statement, the Society for General Internal Medicine (SGIM) reported limits on the share of its annual operating budget that could come from external sources (SGIM, 2006). The limit on external sources of funding was 33 percent overall, with limits of 10 percent from health care-related for-profit entities in combination and 5 percent for any single such entity. (Thus, 67 percent of the operating budget must come from internal sources, such as member dues and fees.) Furthermore, the statement declared that the organization should not accept funds from

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