COM – Conflicts of Interest – Academic

Policy Number: 3349-AC-412
Effective Date: 10/13/2015
Updated: 11/16/2020
Reviewed: —
Responsible Department: Office of the Dean and Medical Education, College of Medicine
Approval Authority: Senior Associate Dean for Academic Affairs
Responsible Office: Office of the Dean and Medical Education, College of Medicine

A. Purpose

The purpose of this Policy is to establish guidelines regarding conflicts of interest for assessment and promotion of students. This Policy is intended to remove, as much as possible, bias in assessment of a student’s performance, assigning a student’s grade or in decisions of student promotion in accordance with the Liaison Committee on Medical Education (LCME).  The Relevant LCME Elements are as follows (LCME Functions and Structure of a Medical School, effective July 1, 2019):

1. 12.5 Non-Involvement of Providers of Student Health Services in Student Assessment/Location of Student Health Records Element
2. 9.9 Student Advancement and Appeal Process

B. Scope

This Policy applies to credit-bearing courses that are contained in the College of Medicine (COM) curriculum, M1 though M4, and the Committees on Academic and Professional Progress. This policy does not apply co-curricular activities at any level, student independent study effort or student employment.

C. Definitions

1. Committee on Academic and Professional Progress (CAPP): CAPP Phase 1 and Phase 2 evaluate students’ academic performance, assess professional readiness for continued studies and determine appropriateness of curricular leave. CAPP Phase 1 is concerned with progression of students from partner universities into the COM program. CAPP Phase 2 is concerned with current COM students. (NEOMED Appendix G, College of Medicine, College of Medicine Standing Committees.
2. Conflict of Interest: The ability of a faculty member to improperly influence a decision about a student due to a preexisting relationship between the faculty member and the student.
3. Course Director: The appointed faculty member who is responsible for the overall design, conduct, student assessment within and evaluation of a credit-bearing course.
4. Credit-bearing Course: A course offered by the College of Medicine in which a student is enrolled, the course appears on the student’s official transcript with either contact hours or credit-bearing acknowledgment, and a grade is assigned.
5. Faculty: Faculty is defined as instructional faculty, clinical faculty, research faculty, residents, postdoctoral fellows, graduate student instructors and graduate student research assistants(NEOMED Academic Policy 3349-AC-100) responsible for assignment of a course grade to a student, or a major component thereof, or responsible for contributing to a promotion decision regarding a student.
6. Clinical Site: Instructional sites not located on the NEOMED campus where students are taught, supervised or assessed by a preceptor/supervisor or clerkship site/elective director on the development of their clinical knowledge, skills, and/or behavior.   Does not include the NEOMED Wasson Center.

D. Policy Statement

1. This Policy applies to credit-bearing courses within the COM curriculum. At the course level, this policy applies to those courses in which there is no anonymity in assessment and/or assignment of a final course grade to a student. This policy does not apply to courses in which the principle means of assessment is a multiple-choice examination for which cut lines for grading are predetermined or assigned using a distribution of scores in which individual students are anonymous. This Policy is applicable to Course Directors, and those who contribute substantially to a course grade, and those who are members of a Committee on Academic and Professional Progress (CAPP).
2. The LCME specifies conflict of interest in terms of a health care relationship, including the provision of any type of health services, which also includes psychiatric/psychological counseling. The NEOMED College of Medicine furthers that definition to include relatives of students as well as individuals who have a close personal or professional relationship with the student, or in the case of CAPP, a course director who has assigned a failing grade to a student in a course in a way that was not anonymous, or faculty who contributed substantially to the failing grade. Attachment 1 provides examples of what the NEOMED College of Medicine considers to be conflicts of interest.
3. This Policy is designed to remove, as much as possible, bias in assessment of a student, assigning a grade to a student, or making a promotion decision regarding a student.
   1. The goal is to avoid Conflicts of Interest to the extent possible.
      1. For example, when a known Conflict of Interest is identified, a student will not be assigned to be precepted by an individual faculty member or assigned to a clinical site that would present a Conflict of Interest. (Attachment 1)
   2. It is recognized that it may not be possible to remove all bias. In this situation, the goal is to manage the bias to the best of the ability of the curriculum or CAPP.
      1. For example, in the case of identified bias in an M4 elective that is considered to be in pursuit of a residency, the Course Director will work with the elective director to explore options for managing bias.
4. Faculty responsibilities:
   1. Faculty, in reference to this policy are considered to those who are responsible for assignment of a course grade to a student, or a major component thereof, or responsible for contributing to a promotion decision regarding a student.
   2. Faculty are responsible for disclosing any and all Conflicts of Interest prior to the inception of a course or a meeting of CAPP by acknowledging any Conflicts of Interest, or not, by signing an Attestation Regarding Conflicts of Interest form. (Attachment 2)
   3. Members of CAPP must recuse themselves from discussions concerning and decisions about students for whom they are the Course Director or have contributed in a substantial way to a Course Grade of fail if the grade was assigned in a manner that was not anonymous. A substantial way can be considered to be the assignment of the grade for a component of a course, such as seminar or Primary Ambulatory Care Experience (PACE) as part of the M1 Foundations of Clinical Medicine course.
5. Student responsibilities
   1. Students are responsible for disclosing any and all Conflicts of Interest prior to the start of an academic year and/or the assignment of students to a particular course activity or schedule by completing and submitting a disclosure form by the specified date. (Attachment 3)
      1. Students will be made aware of the need to disclose Conflicts of Interest via AIMS on-boarding sites and course orientations.
   2. Disclosure must be prior to the start of a graded experience.
   3. Should the student fail to disclose the relationship until the graded experience has begun and it is discovered, the student will be removed from the educational pursuit and place under other supervision, if possible. Removal may result in failure to meet graduation requirements on time.
   4. Failure to disclose a potential Conflict of Interest prior to the start of a graded experience is a conduct concern that will be reported.

Download the Policy*