Policies to Manage Conflict of Interest
ICER’s value assessments are free from financial conflicts of interest from health care companies (see definition below). As an organization, we value transparency and hold ourselves, and our collaborators, to high standards for conducting our work.
As an advocate for transparency in the health care system, we lead by example, by voluntarily disclosing all financial interests that have been reported to us. We do so by different means:
1) ICER employees must adhere to ICER’s full Code of Business Conduct and Ethics
2) Our independent appraisal committees are subject to limits on financial associations with health care companies and fill out an annual disclosure form, in addition to reporting conflicts of interest for each public meeting
3) ICER collaborators (health services researchers and health economists with whom ICER contracts to do our work) report any conflicts of interest ahead of each project, and
4) All public meeting participants who provide an oral comment, or participate in the policy roundtable, fill out a conflict of interest form.
ICER reviews this information on an on-going basis to ensure that any conflicts can be appropriately managed. It is important to acknowledge that declaring an interest does not necessarily mean that there is a conflict of interest.
We invite anyone who is declaring their interests based on this policy to disclose any interests they think may impact their judgement. The ICER Senior Leadership team will review any situations or circumstances that fall outside of the categories listed below on a case-by-case basis.
Health care company: Any life sciences manufacturer and/or life sciences association (for example, pharmaceutical, biotechnology, or medical device companies), pharmacy benefit manager, or health plan, and/or health plan association, etc. Per our definition, this does not include hospitals and/or academic institutions.
Direct salary: salary payments received directly from a health care company (for example, manufacturer A pays individual X directly via check or direct deposit).
Salary support: in many academic institutions, employees (faculty or staff) may receive a percentage of their salary from a health care company’s financial support on a specific research project or grant. We define this as salary support.
Stocks and securities: This includes equity, and/or options to purchase equity at a given price, in a health care company. Stock and stock options are treated as a potential conflict of interest from the moment they are received or, if they have not yet vested, from the moment a vesting arrangement is known. Whether or not stock or stock options have vested, we wish to know their monetary value as if fully vested at the time of reporting. The value of stock options should be assessed assuming they could be executed at the strike price at the time of reporting. We do not consider ownership of a health care company in a mutual fund, index fund, or managed portfolio over which the individual or their household have no trading control to be a potential conflict of interest, and reporting of such ownership is not required.