RUSH requires its employees; faculty, clinician/physicians, researchers, and in some cases, vendors and contractors whom it does business with, to follow policies and procedures related to conflicts of interest. The following policies are COI related:
- Conflict of Interest and Commitment, and Vendor Guidelines
This document sets forth the RUSH Comprehensive Policy Statement Regarding Conflicts of Interest in detail, including descriptions of business, institutional, clinical and research conflicts; conflicts of commitment; the steps RUSH mandates to avoid, reduce or manage such conflicts; and definitions of key terms used in this document. This should be read together with RUSH’s Relationships with Vendor and Referral Source Guidelines, which supplements and provides additional guidance.
- External Relationships and Financial Conflict of Interest in Research
This policy establishes a consistent disclosure and review process to collect external professional and innovative activities to determine financial conflicts of interests (FCOI) related to research from:
1. all research personnel engaged in the design, conduct, and reporting of research and to oversee and manage significant financial interests in research, in accord with 42 CFR 50, Subpart F, 21 CFR 54, and 45 CFR 94 which addresses perceived, potential or actual conflicts in research; and
2. all Covered Officials and Covered Offices, in order to identify business relationships to assess institutional financial relationships that may compromise research objectivity at RUSH.
- Drug Samples
The purpose of this policy is to establish a procedure to provide vendor-supplied samples of medications without charge to patients of RUSH in compliance with federal and state laws and standards of The Joint Commission.
- Disclosure and Management of Conflict of Interest by IRB Members
RUSH Institutional Review Board (IRB) members must disclose all financial or other types of conflicts of interest, whether potential or actual, to the RUSH IRB in accordance with Federal regulations and RUSH policies and procedures at least annually.
- Procurement for Non-Capital Goods and Services
RUSH complies with the Procurement Standards set forth in sections 200.317 – 200.326 of the Uniform Guidance. This guidance focuses on increased competition and transparency in the procurement process for goods and services procured from Federal Award sources.
- Prevention of Conflicts in Assessment and Promotion (RUSH Medical College)
Many RUSH University Medical Center (RUMC) healthcare providers have faculty appointments in the RUSH Medical College (RMC). As such, RMC students may encounter RUMC faculty when seeking health care services. To protect student confidentiality and prevent conflicts of interest, RUMC health professionals are required to recuse themselves from the academic assessment or promotional (including graduation) decisions of medical students receiving healthcare services performed by RMC faculty.
- Intellectual Property Policy
RUMC has established a set of Intellectual Property Policies and Procedures to facilitate the discovery, development and application of new research, ideas, creative works, technology and other innovations which may benefit the public. RUMC seeks to encourage scholars, researchers, inventors, and authors through the allocation and distribution of incentives and rewards while protecting its own business interests and financial investment towards such innovations.