Policy on Conflict

Title:  SVS Policy on Conflict
Policy Number: G6: Ethics & Conflict of Interest
Effective/Approval Date: Approved by the SVS Executive Board on 8.8.2023
Supersedes: 2.15.2022;12.3.2019
Responsible Department: Executive Office/Governance
Contact: Deputy Executive Director
Approved by: SVS Executive Board

SCOPE:

This policy applies to all individuals serving in the SVS, SVS Foundation, PSO and PAC leadership.

POLICY:

The overall goal of establishing guidelines for managing possible conflicts is to maintain public confidence in the Society and to protect the stature of the Society by ensuring that the integrity of the decision-making processes by the leadership of the SVS is not biased by financial or professional interests. 

As stewards of the Society, the leadership has an obligation to maintain the highest standard of conduct in the execution of their roles and responsibilities on behalf of the SVS.  Conflicts of commitment, whether perceived or actual, may influence decision making and negatively impact the organization.

General Principles

SVS leadership is defined as any individual serving on the Board of Directors, councils, committees, task forces, ad -hoc committees or in any other volunteer capacity for the Society, its publications, Foundation or PSO.  A conflict of interest or commitment is a circumstance or situation that is present when an individual's primary responsibility of providing unbiased and impartial decisions, judgments, or opinions on behalf of the SVS might be influenced by a secondary factor. Problems arise if the secondary interests influence or appear to influence the primary responsibility.  Conflicts may be financial or may derive from leadership positions in other organizations where there is a potential for competition of interests.

The leadership of the SVS shall avoid conflict between the well-being of the SVS and their own personal financial gain or other responsibilities. This shall apply in fulfilling their obligations, making decisions, and expressing their views on behalf of the SVS.  The following principles and guidelines address conflict of commitment.  SVS leadership should:

  • Place the interests of the SVS first while carrying out the duties and responsibilities of their SVS role.
  • Be fair and respect the rights of others in performing their SVS responsibilities.
  • Exercise due diligence and reasonable competence in conducting SVS business affairs, always acting with good faith and integrity.
  • Be supportive of the actions of the collective body that they are serving on even if they differ from their personal position, unless the actions are unlawful, unethical or otherwise improper.
  • When conducting meetings, be inclusive and encourage open and candid discussion.
  • Maintain confidentiality of meeting proceedings; do not share, copy, reproduce, transmit, or disclose confidential information or work in progress related to the business of the SVS (unless otherwise required by law or directed by the Board of Directors).
  • Disclose potential conflicts as they arise in the conduct of SVS business and recuse themselves from discussion and/or voting on the matter as necessary.
  • Adhere to the guidelines for financial relationships with industry included in this policy.
  • Adhere to all other SVS policies related to the conduct of their roles and responsibilities on behalf of the SVS; this includes but is not limited to the SVS Anti-trust Policy, Whistleblower Protection Policy, and Policy Against Harassment. 

Disclosures

Members serving in a leadership role are required to update their disclosure annually and prior to assuming their positions. Updates are also necessary at such times as required by the activity members are engaged in, such as CME offerings, and when there is a substantive change in their relationships.  SVS staff are required to complete disclosures and update annually.

Definitions

Industry:

  • Industry for the purposes of these guidelines and COI policy is defined as for-profit entities that develop, produce, market or distribute drugs, devices, and services or therapies (other than the delivery of patient healthcare) used to diagnose, treat, monitor, manage, and alleviate health conditions.

Direct Financial Relationship with Industry:

  • A direct financial relationship is a compensated relationship held by an individual that should generate an IRS Form W-2, 1099 or equivalent income report.  Deferring compensation from a current relationship with industry is not allowed.  Employee or ownership status in a company as defined by this policy is not permitted regardless of compensation.

    The threshold for an individual to be considered conflict-free is zero income.

    Research support is permitted as long as the grant money is paid to the institution (e.g., academic medical center) where the research is conducted, not to the individual

    Research support, uncompensated services and other permitted relationships should nevertheless be disclosed to the Society.

Employee:

  • Employees are defined as individuals hired to work for another person or business (the employer) for compensation and who are subject to the employer's direction as to the details of how to perform the job.

Owner:

  • Owners are defined as individuals who have an ownership interest in a company, except for stockholders of publicly traded companies, or holders of shares through a pension or mutual fund.

COI Tiers for Leadership - Financial Relationships with Industry

Tier 1:  SVS Officers (President, President-elect, Vice President, Secretary & Treasurer); COI & Professional Conduct Committee; JVS Publications Executive, Senior, Associate and Assistant Editors; Rutherford Editors; PSO Executive Committee; PSO Industry Steering Committees; and SVS Staff

  • May have no direct financial relationships with industry*
  • Committee Chairs, Vice Chairs, Officers, JVS Publications Editors, PSO Executive Committee, and PSO Industry Steering Committee members have a six month window from appointment to terminate direct financial relationships.
  • *PSO Industry Steering Committee members may have no direct financial relationships with the company or companies sponsoring the Committee’s Industry Study.

Tier 2: Document Oversight Committee; Performance Measures Committee; Government Relations Committee; Clinical Practice Guidelines Writing Groups; Reporting Standards Writing Groups; Appropriate Use Criteria Writing Panels; Basic and Translational Research Committee, Education Council, and the following education committees under the Education Council:  Postgraduate Education Committee, VAM Program Committee, VAM Video Committee, Self-Assessment Committee

  • Chairs and Vice Chairs may have no direct financial relationships with industry
  • Chairs and Vice Chairs have a six month window from appointment to terminate direct financial relationships with industry; this is not applicable to the Basic and Translational Research Committee, Education Council and its CME planning committees as they may have none at time of appointment.
  • The majority of the members of the Document Oversight Committee and Performance Measures Committees may have no direct financial relationships with industry.
  • The majority of the members of writing groups/panels may have no direct financial relationships with industry relevant to the subject matter of the Guideline.  If a member discloses a direct financial relationship with industry for a product not related to the subject matter of the guideline and said company also produces a product related to the subject matter of the document, this still constitutes a conflict of interest.   
  • Individuals with more than $50,000 in income in aggregate from industry may not serve on the Document Oversight Committee, Performance Measures Committee, Clinical Practice Guidelines Writing Groups, Reporting Standards Writing Groups and Appropriate Use Criteria Writing Panels.

All members of the SVS Executive Board, SVS Strategic Board, and SVS, PSO and Foundation volunteer leadership not covered in Tiers 1 and 2 will submit full disclosure and resolve appropriately.  

CME, practice guidelines and editorial volunteers will also manage disclosure and resolution according to the specific COI disclosure and resolution requirements established for their activity by the accrediting, credentialing or other oversight entities to which their activities are accountable (e.g. ACCME for CME).

 

SVS Policy on Conflict Implementation

  1. A. SVS will appoint a Conflict of Interest and Professional Conduct Committee.
  2. B. Members of this Committee will themselves be free of conflicts of interest and have no industry relationships.
  3. C. Responsibilities of this Committee include the following:
    • Review annually disclosures for those covered by the scope of this policy
    • Address appeals for exceptions to the policy and make recommendations to the Executive Board.
    • Respond to requests from the Executive Board for review/recommendations regarding conflict of interest and commitment issues.
    • Make policy recommendations to the Executive Board as needed.

In situations where there is information that is at variance with disclosure information provided by an individual, the Committee may request clarification from the individual and/or company.

In situations where there is a significant conflict of interest that may impair the integrity of the SVS, the Committee will notify and advise the SVS Executive Board.

In accordance with ACCME guidelines, an individual who fails to disclose relevant financial relationships will be disqualified from being a member of any committee with CME planning responsibility or oversight. Those intentionally failing to disclose relevant financial relationships will be disqualified from holding any elected or appointed position in the society for a period of five years.

The Committee will review the Guidelines for SVS Management of Relationships with Industry and SVS Policy on Conflict of Interest as needed and update them to be consistent with guidelines promulgated by other major organizations such as the AMA, ACS, CMSS, AAMC, IOM, AdvaMed, PHRMA and others.

PROCEDURE:

At the beginning of all SVS, Foundation, PSO and publications leadership meetings (Councils, committees, ad hoc committees and task forces/workgroups), the Chair will remind participants of the SVS Policy on Conflict and ask members to recuse themselves if a conflict exists. This information should also be included on all meeting agendas as a reminder.

The COI and Professional Conduct Committee provide oversight of this policy as noted above.  Staff is responsible for the implementation internally based on department procedures.

EXCEPTIONS:

None

RELATED POLICIES AND OTHER REFERENCES:

Management of Relationships with Industry