Policies to Manage Conflict of Interest
Employees and officers must act in the best interests of ICER. Employees must refrain from engaging in any activity or having a personal interest that presents a “conflict of interest.” A conflict of interest occurs when a personal interest interferes, or appears to interfere, with the interests of ICER. A conflict of interest can arise whenever an officer or employee takes action or has an interest that prevents the employee from performing her or his organizational duties and responsibilities honestly, objectively and effectively.
ICER Employees and Collaborators:
- ICER is prohibited from taking funding from health plans or manufacturers for studies or appraisals of specific health care interventions.
- No employee may take honoraria from or enter consulting agreements with health plans or manufacturers. ICER staff may, with explicit written approval from their supervisor, consult on a limited basis with organizations representing or working with health plans and manufacturers, as long as any such activity is not related to evidence assessment of specific medical interventions.
- Any employee offered honoraria for a speaking engagement, expert testimony, key opinion leader interviews, or similar, must make arrangements for the honorarium to be paid to ICER, not the individual employee. Employees are allowed to have their reasonable travel expenses reimbursed by outside entities in conjunction with conference appearances, speaking engagements and other activities that promote ICER’s business interests.
- No employee or employee’s spouse/partner may own individual securities in companies with products or services that may be subject to a comparative effectiveness appraisal, including health plans and pharmaceutical, biotechnology or medical device manufacturers. Ownership of health plan, pharmaceutical, biotechnology or medical device securities in a mutual fund or managed portfolio over which the employee or employee’s spouse/partner has no trading control is permitted.
- No employee shall perform services as a consultant, employee, officer, director, advisor or in any other capacity for, or have a financial interest in, a direct competitor of ICER, other than services performed at the request of ICER.
- No employee shall use his or her position with ICER to influence a transaction with a supplier or customer in which such person has any personal or financial interest
Independent Appraisal Committees:
Members of ICER’s voting bodies, including CTAF, Midwest CEPAC, and New England CEPAC, excluding ex-officio members, cannot work for any public or private payers. Members, excluding ex-officio members, are expected to be free from financial conflicts of interest, and all members will be required to disclose financial ties to any private health care organization. While issues of financial influence will be handled on a case-by-case basis, as a guideline, members, excluding ex-officio members, may not have substantial financial interests in the health care industry, defined as the following:
- A specific financial association, such as individual health care stock ownership (including those held by the member or anyone in the member’s household) in excess of $25,000 during the previous year from any one health care manufacturer or insurer (e.g., $25,000 holdings in XYZ healthcare manufacturer or $25,000 consultancy income from ABC health insurer).
- Financial association, such as individual health care stock ownership (including those held by the member or anyone in the member’s household) in excess of $50,000 in aggregate during the previous year from health care manufacturers or insurers (e.g., $15,000 holdings in XYZ healthcare manufacturer, $15,000 in speaking fees from ABC health insurer, and $20,000 in consultancy income from 123 health insurer).
Any member with a potential influence on judgment, including, but not limited to, a personal experience with a particular technology or condition, or a political consideration, shall recuse themselves from voting at a public meeting. Any member with a direct financial association with the particular product, service, or comparator being evaluated at a meeting shall also recuse themselves from voting at that meeting. “Direct financial association” is defined as 1) individual health care stock ownership (including those held by the member or anyone in the member’s household) in excess of $10,000 during the previous year in any company with a product under study at the meeting, including comparators, or 2) any health care consultancy income from the manufacturer of the product or comparators being evaluated.
Any member who has previously expressed public opinions about a particular technology, such as in a lecture, editorial, review article, or on social media, shall disclose this at the public meeting and state whether they can provide an impartial evaluation of the information presented at the public meeting. If they are unable to do so, they shall recuse themselves from voting on that technology.
Public Meeting Participants:
To ensure transparency, all participants in ICER meetings, including members of the policy roundtable and any individual giving oral public comment, are required to disclose any potential conflict of interest. All participants must complete a conflict of interest disclosure form prior to the meeting. Participants will be asked during the meeting to verbally restate any potential conflicts they may have.
A potential conflict is defined as a relationship with any health care company (life sciences manufacturer, health plan, health plan association, life sciences manufacturer association, etc.) in the last 36 months. A relationship is defined as you or anyone in your household meeting one or more of the following criteria:
- Receipt or potential receipt of anything of monetary value, including but not limited to, salary or other payments for services such as consulting fees or honoraria in excess of $5,000
- Equity interests such as individual stocks, stock options or other ownership interests in excess of $10,000. Ownership of stock in a mutual fund over which an individual has no trading control does not count toward this item.
- Status or position as an officer, board member, trustee, owner or employee of a health care company, or an organization which receives more than 25% of its funding from health care companies
- Loan or debt interest; or any intellectual property rights such as patents, copyrights and royalties from such rights
- Manufacturer support of research in the clinical area of this meeting in which you are participating (serving as PI for a trial of any of the agents included in this report at any time warrants disclosure).
- Collaborating with any third party entity to directly compose public comments to be delivered at the meeting.
- Any other relationship that could reasonably be considered a financial conflict of interest
Disclosing a potential conflict does not disqualify a speaker or roundtable member from participating in the meeting.