policy

Approval: This Policy was last reviewed and revised in 2021 and approved by the dean and CEOs of Stanford Health Care and Stanford Children’s Health | Lucile Packard Children’s Hospital Stanford.
Questions: For Policy-related questions, please complete the SMIIP Intake Form. This Policy was created to account for most industry-related interactions. Should the characteristics of a desired industry interaction not be specifically outlined in this document, Stanford Medicine personnel should seek approval first.
Adjudication: A SMIIP oversight committee will assist with the adjudication of SMIIP questions to provide consistent interpretation of policy and monitor questions to continue to improve the effectiveness of the policy’s communication and implementation.

Scope: This Policy applies to interactions by Stanford Medicine or Stanford Medicine personnel with industry or funders/sponsors, whether on or off campus.
Related Policies: The subjects covered by SMIIP are connected to other important Stanford Medicine, university, and external policies. See Appendix A: Policies Related to SMIIP for additional policies that should be reviewed in conjunction with this Policy.
Definitions:

a. “Development” refers to Stanford Medical Center Development (MCD) and the Lucile Packard Foundation for Children’s Health (LPFCH), individually or collectively. MCD is responsible for gifts to SOM and SHC. LPFCH is responsible for gifts to LPCH, pediatrics, and maternal-fetal medicine and obstetrics, as applicable.

b. "Educational Space" includes the rooms or defined physical or virtual space where educational content is being delivered. It does not include the foyer, hallways, other indoor surrounding areas, and outdoor space of the building.

i.Stanford Medicine Event receiving Industry support;

ii. Event created, organized, or hosted by Stanford Medicine in collaboration with other Stanford University schools or programs, if the Event is receiving any Industry support;

iii. Event created, organized, or hosted by Stanford Medicine in collaboration with third parties, if Stanford Medicine is receiving any Industry support for the event and/or the event is co-branded with Stanford Medicine; and iv. Event created, organized, or hosted by Industry.

c. "Events" are inclusive of many activities, forms, and formats, such as programs, meetings, conferences, lectures, workshops, symposiums, skills labs, individualized learning, and regularly scheduled series. These can be in person, at any location, online in real time, and on demand. Events include any:

d. "Exhibits" are promotional activities and include any attempt by Industry to promote its products or services with a sales and marketing goal via display tables, booths, showcases, or promotional lectures.

e. "Faculty" includes all members of the Academic Council, including university tenure line, non-tenure line (research), non-tenure line (teaching) and non-tenure line (clinical), the medical center line (MCL), the clinician educator line (CE), and adjunct clinical faculty (ACF). All Faculty are required to comply with this Policy whether they are full-time, part-time, or active emeriti.

f. "Funder" or "Sponsor" is an industry entity that provides financial or in-kind support.

g. "Industry" includes any for-profit entity, including, but not limited to, pharmaceutical, medical device, research equipment, technology, and data service providers. SMIIP may apply to not-for-profit organizations, on a case-by-case basis as determined by the dean’s office.

h. Dev"Medical Education" includes Events for the following audiences: i. Undergraduate medical education (UME) for medical students; ii. Graduate medical education (GME) for residents and fellows; iii. Post-graduate medical education for any practicing clinicians (e.g., physicians, pharmacists, psychologists, nurses, nurse practitioners, physician assistants, social workers) and PhD students. This includes external-facing Continuing Medical Education (CME) and non-CME Events as well as internal-facing regularly scheduled series, such as grand rounds; and iv. Non-clinician education for undergraduate students, patients, and the public.

i. "Presenter" includes any Stanford Medicine personnel speaking or lecturing at an Event.

j. "Site" refers to any facility operated by an entity that is part of Stanford Medicine.

k. "Sponsor" see Funder definition.

l. "Stanford Medicine" refers to the Stanford University School of Medicine (SOM), Stanford Health Care (SHC), Lucile Salter Packard Children’s Hospital at Stanford (LPCH), Stanford Health Care Tri-Valley, University HealthCare Alliance (UHA), the Packard Children’s Health Alliance (PCHA), and any other entities that are designated as part of Stanford Medicine.

m. "Stanford Medicine Personnel" includes Faculty, staff, employees, residents, fellows, School of Medicine students, and contracted medical groups of Stanford Medicine.

n. "Trainee" refers to an intern, resident, and/or fellow.

Personal Gifts Policy: Stanford Medicine Personnel may not accept any form of personal gift from Industry under any circumstance, including but not limited to, for listening to a sales talk, prescribing medication, or attending an Event. Personal gifts, other than de minimis items of little or no value, are prohibited. These gifts include, but are not limited to, industry swag, drug samples, meals, and travel costs, unless Industry is providing travel support for students and Trainees to attend educational conferences in accordance with Section 8 below. Business courtesies paid for or provided by Stanford Medicine are outside the scope of this Policy. Please refer to the gifts/non-monetary compensation policy for the applicable Stanford Medicine entity. See Appendix A: Policies Related to SMIIP.

Adjunct Clinical Faculty Exception: No provision of this section shall apply to members of the ACF when engaged in patient-centered clinical activities unrelated to Stanford Medicine.

Gifts from Industry to Stanford Medicine

Philanthropic gifts: both financial and in-kind, from Industry to Stanford Medicine or in support of the work of Stanford Medicine Personnel or Stanford Medicine Events, are allowed. Gifts may be processed and accepted only through Development, either MCD or LPFCH, as applicable. See Appendix B: Process for Soliciting and Accepting Gifts from Industry.

Meals

Meals present unique challenges and opportunities for influence by Industry. Stanford Medicine Personnel should refer to the following guidelines when either receiving or providing any food and/or beverage paid for with Industry funding:

When you are receiving a meal	Meals provided as a personal gift, including gift cards	Not allowed
	Meals provided by Industry at a promotional Event	Not allowed
	Meals provided at a non-promotional Event receiving funding from Industry in which no registration fee is paid, or the meal value exceeds the registration fee	Allowed but discouraged (may be disclosed by the Funder under the Sunshine Act)
	Meals provided at an Event receiving funding from Industry in which the registration fee exceeds the meal value	Allowed
	Meals provided at CME Events receiving funding from Industry	Allowed
	Meals funded and provided by Stanford Medicine	Allowed
When you are providing a meal at an Event	Meals at all other Stanford Events paid for with Industry funding	Not allowed
When you are providing a meal at an Event	Meals at Stanford Accredited CME Events may be paid for with Industry support as long as this funding is managed by the Stanford Center for Continuing Medical Education (Stanford CME).^[1]	Allowed

[1] Under the Physician Payments Sunshine Act, which is a section of the Patient Protection and Affordable Care Act, nearly all “transfers of value”—including gifts, consulting and speaking fees, and meals worth more than $10—from medical product manufacturers to physicians and teaching hospitals must be reported to the federal government and will then be disclosed in a public database. Funding of accredited CME programs is exempt from that mandate. Accordingly, using funding that would result in a disclosure to the U.S. Centers for Medicare & Medicaid Services (CMS) Open Payments Database is permitted, as long as funding is managed by Stanford CME.

Meals paid for by Stanford Medicine are outside the scope of this Policy. Please refer to the gifts/non-monetary compensation policy for the applicable Stanford Medicine entity. See Appendix A: Policies Related to SMIIP.

Industry Support for Medical Education Events

Oversight: Events seeking industry support must secure prior approval from one the following oversight groups. GME Events fall under the oversight of the Associate Dean for GME. All other post-graduate medical education Events fall under the auspices of the Associate Dean of Post-Graduate Education and the Stanford CME office, regardless of the Event’s designation as a CME activity. If the activity is not CME, Faculty shall seek and receive approval prior to the activity from both the Associate Dean of Post-Graduate Medical Education and either the department chair or division chief. Adjudication of questions for Events that serve multiple audiences will be provided by the SMIIP oversight committee in collaboration with the respective associate deans.

Event Policy: Industry support, both financial and in-kind, for Medical Education Events is allowed, subject to the following conditions:

Education Focus: Industry support is used for the purpose of education;
Curriculum Control: Industry may not influence Medical Education curriculum in any way. Stanford Medicine must be the party responsible for identifying the needs, determining the educational objectives, selecting and presenting the content, selecting the individuals and organizations that control the content, and selecting educational methods and final evaluation of the Event;
Free of Bias: Medical Education must be evidence-based and free of commercial bias; and
Development/Stanford CME Coordination: Industry support must be sought in collaboration with and pursuant to the rules of Development or the Stanford Center for Continuing Medical Education (Stanford CME). See Appendix C: Process for Seeking Industry Support for a Medical Education Event.

Event Expenses: Industry support may be used for selected expenses as defined below. Note that each Sponsor may have its own policy about the expenses related to the Event it is able to fund.

Permissible Expenses include speaker fees or honorariums, speaker travel and lodging (refer to the Administrative Guide 5.4.2 for travel policies), venue fees, logistics, meeting planning, marketing, audio visual, accreditation, and administrative staffing.
Meals: For guidance on using Industry funding for meals, refer to section 6.
Infrastructure, Indirect Cost Rates, and Fees: Financial sponsorships from Industry will be assessed the appropriate university’s infrastructure or indirect cost rate, in accordance with university policy, and such charges must be included in the Event budget. Further, many Stanford organizations that facilitate Events, including Event Services and Stanford CME, charge for their services.

Event Fund Management: Medical Education Event funds must be managed by a Stanford department, program, division, or institute, rather than by individual Faculty. For CME funding, Stanford CME manages the funds (see section 6.7).

Event Content and Delivery: Organizers and presenters are subject to the following additional principles when preparing for Medical Education Events:

Minimizing Bias: The Stanford Medicine Personnel or entity responsible for creating, organizing, or hosting the Medical Education Event, in coordination with each presenter, must ensure that all educational content is free of commercial bias. See Appendix D: Presenter Checklist to Minimize Bias.
Conflict of Interest: Any Stanford Medicine Personnel organizing and/or presenting at a Medical Education Event and having a content-relevant financial conflict of interest should disclose their financial interest to Event participants both orally and on a slide at the beginning of their presentation.
Industry Educators: Industry employees may serve as educators in Medical Education Events only when their unique expertise and experience is requested and not able to be replicated by Stanford Medicine Personnel. For CME Events, Industry employees must abide by Accreditation Council for Continuing Medical Education (ACCME) requirements.
University Protocol: All Medical Education Events must follow established University Event Policy and Guidelines for Event Organizers. “Fronting” for an off-campus organization looking to gain use of Stanford venues, organize an event, create a web presence, or access the Stanford name is prohibited.
Non-Traditional Programming: New formats of Medical Education Events, such as Industry-sponsored competitions, must follow the same guidelines as traditional educational content.

Acknowledgement of Event Funding: Acknowledgement of Industry funding or in-kind support may be made on Event promotional materials, subject to the following guidelines:

Benefit Approval: The coordinating entity, either Development or Stanford CME, is responsible for approving and accepting all funding/support and for pre-approving the benefits, if any, offered and ultimately provided to the Sponsor. Stanford Medicine Personnel should not discuss benefits with a Sponsor without first engaging with Development or Stanford CME to ensure that what is being offered to the Sponsor is consistent with this Policy, other university policies, and applicable laws and regulations.
Agreement and Timing: Any acknowledgement will be explicitly stated in the sponsorship agreement with Industry. Sponsors may be acknowledged only after the sponsorship agreement has been fully executed and sponsorship funding/support has been received.
Acceptable Formats: Acknowledgement is allowed on the Event website, in printed materials related to the Event, and in selected Sponsor-created content, following the guidelines in Appendix E: Acknowledgement Guidelines for Medical Education Events.

Industry Promotion at Medical Education Events: Industry promotion and/or marketing is restricted and allowed only at CME Events, subject to the following guidelines:

University Policy: Any Industry promotion must comply with the Guidelines Regarding Stanford’s Promotion of Non-Stanford Entities.
For Accredited CME/CE Events: Exhibits/promotion are permitted in accordance with the ACCME and Joint Accreditation guidelines, if the following conditions are met:
1. All activities adhere to the ACCME Standards for Commercial Support.
2. Industry support is sought in collaboration with and under the auspices of Stanford CME.
3. Stanford CME manages the receipt and disbursement of all funds from Industry, unless other arrangements are made with the prior consent and approval of Stanford CME.
4. Commercial promotion adheres to the Stanford CME Exhibit Policy and is consistent with the values and decorum befitting of Stanford University.
5. Logos from Industry are not permitted in the Educational Space. Logos may appear in the Sponsor’s section of physical or online program materials per university Guidelines Regarding Stanford’s Promotion of Non-Stanford Entities. See Appendix E: Acknowledgement Guidelines for Medical Education Events.

For All Other Events (Not Accredited CME):

Industry promotion and/or marketing (e.g., corporate slogans, signs, brochures, or other marketing materials) are not allowed in the Educational Space.
Logos from Industry are permitted in the Educational Space only on an Industry presenter’s slides to identify the presenter’s affiliation and should be minimal in nature (such as in the slide footer). Logos may not appear anywhere else, with the exception of the Sponsor’s section of physical or online program materials per university Guidelines Regarding Stanford’s Promotion of Non-Stanford Entities. See Appendix E: Acknowledgement Guidelines for Medical Education Events.
Sponsors may not distribute or display sales or marketing brochures or any other branded materials or products (including samples) at the Event.
Industry exhibits are prohibited.

Additional Guidelines for Post-Graduate Medical Education Events: In addition to the above policies for all Medical Education Events, the following guidelines apply for post-graduate medical education Events, including CME:

Standards: With limited exceptions, post-graduate education receiving funding from Industry will go through the rigor of accredited CME, whether receiving CME or not, and will be subject to the ACCME Standards for Commercial Support.
CME Programs: Unrestricted educational grants from Industry are permitted for CME Events if the following conditions are met:
1. All CME Events, whether they originate from, are primarily organized by, or are hosted by Stanford, must be accredited by Stanford CME or authorized after consultation with Stanford CME.
2. Irrespective of location, all CME Events must comply with applicable university policies, Stanford CME policies, and ACCME policies, including the ACCME Standards for Commercial Support.
3. Stanford CME manages the receipt and disbursement of all funds from Industry, unless other arrangements are made with the prior consent and approval of Stanford CME.
4. Industry CME funding may be used to fund honoraria or travel expenses of planners, Faculty, and others in control of content for those roles only. It may not be used to pay for travel, lodging, honoraria, or personal expenses for individuals or groups of learners not in control of content, subject to section 8 (Industry Support for Scholarships to Medical Education Event Participants).

	Non-CME Medical Education Events	CME Medical Education Events
Industry funding for Event meals	No	Yes
Industry exhibits	No	Yes
Logos in Educational Space to identify speaker	Yes	No
Logos to recognize Sponsors (outside Educational Space) per university guidelines	Yes	Yes

Questions Regarding Medical Education Events: For questions regarding GME Events, contact the Associate Dean for GME. For questions regarding post-graduate medical education Events, contact the Associate Dean for Post-Graduate Medical Education and/or the Stanford CME office. For all other questions regarding philanthropic Industry support for Medical Education Events, contact Development and the Senior Associate Dean for Medical Education.

Industry Support for Scholarships to Medical Education Event Participants

Scholarship Policy: Grants from Industry for scholarships or other educational funds for students and Trainees are allowed for the purpose of attending medical education Events as long as they meet the following provisions:

Recipient Selection: The SOM department, program, division, or institute selects the student or Trainee.
Free of Commercial Bias: Industry support for students and Trainees is free of any actual or perceived conflict of interest or bias.
Educational Merit: The department, program, division, or institute responsible for the student or Trainee determines that the funded Event has educational merit.
Scholarship Fund Management: Scholarship funds are provided to the SOM, department, program, division, or institute and not directly to the student, Trainee, or an individual Faculty member.
Funded Expenses: Support may be used to cover expenses including travel, hotels, and conference registration fees, including for CME programs.
No Reciprocity: The student or Trainee benefiting from the support is not subject to any implicit or explicit expectation of providing something in return for the support, i.e., a “quid pro quo.”
Process: Solicitation and/or acceptance of Industry scholarships are done in collaboration with and under the auspices of Development.

Merit Award Exception: This provision does not apply to national or regional merit-based awards.

Industry Support for Fellowships

Fellowships can be sponsored by or receive funding from an Industry entity if the following conditions are maintained:

Funds Management: The funds are provided via a non-designated account that is managed by Stanford Personnel who have no relationships with the Funder.
Independent Programming: The educational program receiving funding is designed, executed, and evaluated independent of the Industry Sponsor, including any individuals with financial relationships to the Industry entity.
Awardee Selection: The fellowship awardee is chosen by Stanford Personnel with no relationship to or conflict with the Industry entity and without involvement or restrictions imposed by the Industry Sponsor.

Professional Activities Involving Industry

Stanford Medicine Personnel may engage with Industry or at Industry-sponsored Events as long as the activity is in support of the mission of Stanford Medicine to advance scientific research, medical education, and evidence-based clinical care. The following guidelines should be met to minimize the potential for conflict of interest and bias.

Providing Clinical Care

Avoiding bias: Stanford Medicine Personnel must consciously and actively divorce clinical care decisions from any perceived or actual benefits expected from Industry. It is unacceptable for patient care decisions to be biased or influenced by the possibility of personal or institutional financial gain. Refer to Stanford Medicine Code of Conduct policy.

Attending an Industry Event

Disclosure: Attendance is permitted, but attendees should be mindful of the impact of financial support by Industry on a given Event.
Gifts: Stanford Medicine Personnel may not receive gifts from Industry for attending an Event. The only exception to this rule is if the gift is an unrestricted grant for student and Trainee scholarships (see Sections 5 and 8).
Meals: For guidance on meals at Industry Events, refer to section 6.

Presenting at an Industry Event

Presentation Content: The Stanford Presenter, not the Industry Sponsor, determines and prepares the lecture content. The Presenter is expected to provide a fair and balanced assessment of therapeutic options and to promote objective scientific and educational activities and discourse. Sponsors may not make their support contingent upon the Presenter’s acceptance of Industry advice regarding presentation content.
Use of Stanford Name: The use of the Stanford name, regardless of location, for a non-Stanford Event is limited to the identification of the Presenter by their title and affiliation. Refer to Stanford Name Use Guidelines.
Conflict of Interest Disclosure: When the Presenter has a financial interest that poses a content-relevant conflict of interest, this should be disclosed to the audience both during the talk and on a slide at the beginning of the presentation.
Honorarium: Presenters may receive compensation from Industry for speaking at an Event, subject to appropriate disclosure. If a Presenter’s participation is sponsored by Industry, they must disclose at the beginning of their presentation that they are being paid for giving the talk.
Reimbursement: Lecturers may be reimbursed for travel and lodging expenses from the Industry sponsor.
Prohibited Events: Stanford Medicine Personnel may not participate in
1. Industry-sponsored speaking engagements, such as speakers’ bureaus or drug dinners, where there is a contractual relationship to give talks in which the content is overseen, provided, or approved by the Sponsor.
2. Dedicated marketing and training programs, for the purpose of educating and training a Sponsor’s personnel or sales force, where the content is overseen, provided, or approved by the Sponsor.

See Appendix F: Promotional Talk Checklist to assess whether presenting at an Industry Event is promotional in nature.

Consulting for Industry (Outside Scope of Stanford Employment)

University Policy: Consulting with Industry is allowed, subject to university guidelines included in Consulting and Other Outside Professional Activities by Members of the Academic Council and MCL Faculty (RPH, 4.3).
Use of Stanford Name: The use of the Stanford name, regardless of location, is limited to the identification of the consultant by their title and affiliation. Refer to Stanford Name Use Guidelines.
Presentation Disclosure: When a Presenter is speaking as part of consulting activities, they must communicate to the audience that the content reflects their individual views and not the views of Stanford University or Stanford Medicine.
Publication Disclosure: If Stanford Medicine Personnel are listed as an author on any publication resulting from performance of their consulting services, the following disclosure must be made in the publication: “[NAME]’s contribution to this publication was as a paid consultant to [COMPANY NAME]. [NAME] is not providing this material as part of their Stanford University duties or responsibilities.” [confirm that this applies to more than just Faculty]
Market Research: Stanford Medicine Personnel should not engage in Industry-sponsored market research as part of their institutional responsibilities. If the research is performed on a member’s own time, then it is allowed provided they report the activity and compensation to document the fair market value. Personnel should be aware that this compensation may be disclosed on the Open Payments website as an indirect payment from Industry.

Publishing

Conflict-of-Interest Disclosure: In scholarly publications, regardless of the physical or online location of such publication, Stanford Medicine Personnel must disclose their related financial interests in accordance with the International Committee of Medical Journal Editors (www.icmje.org).
Ghostwriting: Stanford Medicine Personnel are prohibited from engaging in ghostwriting, defined as publishing articles under their own name that are written in whole or material part by Industry employees.
Use of Stanford Name: Refer to Stanford Name Use Guidelines for use in academic publications.

Teaching: Stanford Medicine Personnel with teaching or supervisory responsibilities for students, Trainees, or staff should ensure that a conflict or potential conflict of interest does not affect or appear to affect their teaching or the supervision of the student, Trainee, or staff. If a teaching individual has an Industry relationship that is related to his/her/their teaching content, it is recommended that this relationship be disclosed to his/her/their learners.

Involvement in Decisions on Industry Product/Service Procurement and Industry Collaborations

Financial Interest Disclosure: Stanford Medicine Personnel having a direct role in making institutional decisions on a) the procurement of equipment, services, technology, or drugs from Industry, or b) the status of Industry collaborations, must disclose to the decision-making unit or committee, prior to making any such decision, any financial interest they, or their immediate family, have with the recommended company(ies) that might substantially benefit from the decision. “Financial Interest” is defined in this case to be an immediate family member employed in a decision-making role (Director or higher) or having a significant direct financial investment in the form of equity or other assets. The decision-making unit or committee, following the applicable guidelines, will decide whether the individual must recuse him/herself from any relevant decisions.
Additional Policies: Additional policy concerning procurement activities at the hospitals can be found in hospital and medical staff policy documents.

Research with Industry

Oversight: Sponsored research in the School of Medicine is governed by the guidelines of the Industrial Contracts Office (for interactions or funding with Industry or material transfers), the Research Management Group (for grants, fellowships, and clinical trials), the Research Policy Handbook, and the Dean of Research.
Shared Use of Clinical Data: Industry collaborations involving the sharing of Stanford health data must abide by all applicable laws and regulations, and Stanford’s Secondary Data Use principles which are expected to be published in early 2022. Questions can be directed to the Secondary Data Use committee via the SHC Compliance office.

Site Access to Industry Sales and Marketing Representatives

Patient Areas: Industry sales and marketing representatives are not permitted in any patient care areas, except to provide in-service training on devices and other equipment, and then by appointment only.
Non-patient Areas: Industry sales and marketing representatives are permitted in non-patient-care areas by appointment only.
Appointments for Site Access: Appointments will be made for such purposes as service training of hospital personnel for research/clinical equipment or devices already purchased, and evaluation of new purchases of equipment, devices, or related items. Appointments may be made on a per-visit basis or as a standing appointment for a specified period of time, at the discretion of the Faculty or Staff member, his/her/their division or department, or designated Stanford Medicine Personnel issuing the invitation and with the approval of appropriate hospital management.

Annual Disclosure of Relationships with Industry

OPACS Requirement: All Faculty, except Adjunct Clinical Faculty, must complete on an annual basis the Outside Professional Activities Certification System (OPACS).
Disclosure of Relationships with Industry Entities Recommended or Prescribed: In addition, all Faculty engaged in clinical care activities, except Adjunct Clinical Faculty, must disclose on an annual basis through the OPACS any financial relationship with a company, entity, or third party that produces, manufactures, or distributes a medical device, implant, pharmaceutical, or other medical care–related product as well as other Industry products and services (e.g., software, data services) that they recommend or prescribe to their patients.
Adjunct Clinical Faculty Policy: ACF must sign an attestation on an annual basis that they understand and comply with this SMIIP.

SMIIP Dissemination

Appendix A: Policies Related to SMIIP

The following related policies should always be reviewed in conjunction with SMIIP.

Stanford Medicine Policies

University Policies

External Policies and References

Appendix B: Process for Soliciting and Accepting Gifts from Industry

The process for soliciting and accepting offers of support starts with contacting MCD or LPFCH for advice to ensure all funding is consistent with Development objectives and Stanford policies. MCD or LPFCH can provide strategic guidance and will facilitate communication with the Funder in coordination with the Faculty member. Once Development is involved, the steps below should be followed:

Step 1	Seek approval. Obtain preliminary written approval from your department chair or center director regarding the purpose and use of the funding.
Step 2	Development prepares gift agreement. Once the written approval is secured, Development will begin its standard gift review process, which will include asking diligence questions of the faculty and the funder. Once the review process is successfully completed, Development will begin working on a gift agreement outlining the terms and conditions of the funding. Development will handle all negotiations with the Funder and must approve the final terms of the gift agreement.
Step 3	Development manages execution of agreement. Once the gift agreement has been finalized, Development will manage the signature process. Each gift agreement must be signed by (i) the Funder and (ii) the VP of Development. Please note that only Development has signature authority for accepting gifts and support for Stanford Medicine. No individual Faculty member, dean, department chair, center director, or other staff member may accept support or sign philanthropic agreements on behalf of Stanford.
Step 4	Processing and payment. The executed gift agreement will be processed by Development, and Development will provide the Funder with payment instructions regarding sending a check or wiring funds to Development Services. Funds should never be sent to the department. Your department will establish a Projects, Tasks, and Awards, or “PTA,” billing account through the Gift Transmittal System once the funding is received. This PTA will be used by the department to manage the funds.

For questions related to gifts from Industry, contact either MCD at or LPFCH.

Appendix C: Process for Seeking Industry Support for Medical Education Events

Two different Stanford Medicine offices process Industry support for Medical Education Events: the Stanford CME office for education Events for clinicians or the office of Development (either MCD or LPFCH) for education Events for non-clinicians.

Education Events for Clinicians

If an Event is for post-graduate medical education for clinicians (whether or not the Event is a CME activity), requests are processed under the auspices of the Associate Dean of Post-Graduate Education by the Stanford CME office. Follow the steps below to secure Industry funding for clinician education Events:

Step 1	Consult Stanford CME office. Stanford Medicine Personnel coordinating the Event may engage in preliminary discussions for Industry support but should consult with Stanford CME for planning and execution. Early engagement by the Stanford CME office (at least 90 days before the event) is important to ensure compliance and receive funding in a timely manner.
Step 2	Complete planning document. Fill out the Activity Planning Toolkit to outline proposed objectives, agenda, and budget for the Event.
Step 3	Stanford CME office solicits funds and signs letter of agreement. The Stanford CME office will contact Industry to request Event funding. The office will also source and execute a letter of agreement with each funder. Stanford Medicine Personnel do not have signature authority for funding agreements.
Step 4	Stanford CME receives and distributes funding. The Stanford CME office will manage the disbursement of funding or transfer funds to a Department to pay for Event expenses. Any funds left over from the Event are returned to the Industry Funder.

For questions related to education Events for clinicians, contact the Stanford CME office.

Education Events for Non-Clinicians

If an Event is for a non-clinician audience (e.g., students, patients), requests are processed by the office of Development (either MCD or LPFCH). Follow the steps below to secure Industry funding for non-clinician education Events:

Step 1	Consult Development office. Stanford Medicine Personnel coordinating the Event may engage in preliminary discussions for Industry support but should consult with Development for solicitation and execution. The Development office must confirm that the Industry support is a gift to proceed. Early engagement of the Development office (4-6 weeks before the event) is important for timely receipt of funds and recognition of Funders.
Step 2	Develop an Event budget. Prepare a budget to determine overall financial needs and how Industry support will be applied to permissible expenses. Event organizers should consider seeking multiple Industry Sponsors to avoid the perception of bias.
Step 3	Seek Sponsor commitments. Stanford Medicine Personnel are responsible for identifying Sponsors for their Event.
Step 4	Development prepares sponsorship agreement. The Development office will connect with Sponsors to finalize documentation for the gift. For gifts <$10K, Sponsors are required to use our standard sponsorship agreement.
Step 5	Development executes agreement. Once the gift agreement has been finalized, Development will manage the signature process. Each gift agreement must be signed by (i) the Funder and (ii) the VP of Development. Only Development has signature authority for accepting gifts and support for Stanford Medicine. No individual Faculty member, dean, department chair, center director, or other staff member may accept support or sign philanthropic agreements on behalf of Stanford.
Step 6	Receive transmitted funds through PTA account. The executed gift agreement will be processed by Development, and Development will provide the Funder with payment instructions regarding sending a check or wiring funds to Development Services. Funds should never be sent to the department. Your department will establish a Projects, Tasks, and Awards, or “PTA,” billing account through the Gift Transmittal System once the funding is received. This PTA will be used by the department to manage the funds. Any funds left over from the Event are allocated to future educational events and not returned to Sponsors.
Step 7	Recognize Sponsors. Sponsors can be recognized only after funds have been received by Stanford.

Appendix D: Presenter Checklist to Minimize Bias

	This presentation is based on acceptable scientific principles that are generally accepted as valid by the profession.
	This presentation’s content and clinical recommendations are based on the highest available levels of evidence that are accepted in the general medical community.
	Scientific research referred to in this presentation conforms to generally accepted standards of experimental design, data collection, and analysis, and limitations are disclosed (e.g., ongoing research, interim analyses, preliminary data).
	The content promotes improvements or quality in healthcare and not specific proprietary business interest of a commercial interest; it provides a balanced view of therapeutic options – use of generic names will contribute to this impartiality – if the educational material or content includes trade names, where available. These trade names from several companies, not just a single company, should be used.
	Educational materials do not contain any advertising, corporate logos, trade names, or product-group messages of a Sponsor.
	The content of this presentation does not promulgate recommendations, treatments, or manners of practicing medicine that are known to have risks or dangers that outweigh benefits or known to be ineffective.
	This content aligns with the learning objectives for the educational activity, and the presentation was fair, accurate, and free from commercial bias.

Appendix E: Acknowledgement Guidelines for Medical Education Events

Acknowledgement Guidelines for Medical Education Events

All Sponsor acknowledgements, including usage of Sponsor logos, must follow university Guidelines Regarding Stanford’s Promotion of Non-Stanford Entities. All creative assets featuring a Sponsor’s logo must be approved by the Dean’s Office. To submit a request, complete the SMIIP Intake Form. Approvals and reviews of all creative assets will be processed within five business days of submission.

Website acknowledgement: Sponsors’ names may be acknowledged on the Event website, as set forth below:

Sponsors’ names and logos must be clearly identified as Sponsors, organized alphabetically, and featured beneath, less prominently, and in noticeably smaller font/graphics than references to Stanford University, Stanford Medicine, and the Medical Education Event.
Sponsors’ names and logos must be uniform in size, irrespective of the sponsorship amount, and may not be hyperlinks to their websites.

Social media acknowledgement: Sponsors’ names may be acknowledged in social media posts related to the Event, as set forth below:

Sponsors’ names must be clearly identified as Sponsors with their names listed in plain text and must be uniform in size, irrespective of the sponsorship amount.
Hashtags to the Sponsor’s social media accounts are allowed.
Sponsors may make factual statements regarding Events or their support and may tag Stanford Medicine in social posts, but the posting language should be reviewed and approved in advance by the Stanford Medicine Office of Communications.

Online materials acknowledgement for virtual events:

Sponsors’ names in plain text may be used to acknowledge a sponsor in online materials displayed during the virtual event, such as opening/closing slides, as long as they are clearly identified as sponsors. Their names must be organized alphabetically and featured beneath, less prominently, and in noticeably smaller font than references to Stanford University, Stanford Medicine, and the virtual event.
Sponsors’ names must be uniform in size, irrespective of the sponsorship amount.
Sponsor names may not appear on any slides with educational content or slides during the educational session.

Printed materials acknowledgement: Sponsors’ names and logos may be acknowledged on promotional materials, banners, signage, and event and program materials, as set forth below:

Sponsors’ names and logos must be clearly identified as Sponsors, organized alphabetically, and featured beneath, less prominently, and in noticeably smaller font/graphics than references to Stanford University, Stanford Medicine, and the Medical Education Event.
Sponsors’ names and logos must be uniform in size, irrespective of the sponsorship amount.
Sponsors cannot buy ad space on program materials.

Sponsor-created content

Public reports. Sponsors may make factual statements regarding their support in periodic public reports, but they may not use the name of any Stanford program, Faculty member, employee, or student, nor any trademark, service mark, trade name, logo, or symbol of Stanford or Stanford Medicine without Stanford’s prior written consent from the Stanford Medicine Office of Communications.
Press releases. Sponsors may not issue press releases regarding the support without Stanford’s prior written consent. All press releases issued by third parties should be reviewed and approved in advance as follows:
Medical Center Development and the Stanford Medicine Office of Communications for press releases to announce gifts and grants;
Communications director of the school, department, institute, or unit for press releases related to activities of Stanford’s schools, departments, interdisciplinary institutes, or other Stanford units; and
University Communications for press releases to describe or relate to Stanford’s activities.
Social media. Sponsors may make factual statements regarding Events or their support and may tag Stanford Medicine in social posts, but the posting language should be reviewed and approved in advance by the Stanford Medicine Office of Communications.

Appendix F: Promotional Talk Checklist

	Is compensation coming from the marketing division rather than the research division of the company?
	Is your compensation for giving the talk reasonable and customary?
	Is the company providing some/all of the content for the talk (slides, talking points, teaching aides, etc.)?
	Is the company dictating the topic of the talk with any level of specificity?
	Does the company have any control over the topic/content talk? Do they review the talk contents prior to presentation?
	Is the company offering inducements to learners to attend the talk (e.g., meals, travel, gifts, lodging, honoraria, other)?
	Has the company asked you to attend a speaker training session?
	Is the venue for the talk more appropriate for a holiday or vacation than for a learning experience?
	The SMIIP prohibition on engaging in educational activities that are promotional applies to all full-time and part-time faculty, including active emeriti, UTL, MCL, Clinician Educators, Adjunct Faculty, staff, students, and Trainees.
	When in doubt contact the COI office or your Department Chair.

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