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MAPS Non-promotion and Conflict of Interest Policy
Introduction:
This policy applies to all content whether generated by MAPS member companies or by vendors of goods and services that can be used by MAPS or any of its individual or institutional members.
MAPS educational content should be presented in a neutral manner that does not “promote” a specific company, product, or service.
A good general rule to follow for non-promotional content is: The audience should be able to apply the learning to any situation, even those that do not include or require the use of a specific company/product/service.
Purpose:
MAPS seeks to ensure quality content across all media types to provide value to MAPS members and the wider Medical Affairs community. The actuality or appearance of conflicts of interest (COI) or promotional intent by authors/contributors detracts from the substance of these materials. Thus, it is the purpose of this policy to ensure all contributors work in good faith to provide valuable education, information and insights without using MAPS content as a vehicle for self- or organizational promotion.
Definitions:
Promotional Materials: Promotional materials are those recommended or creating a perception of to recommend, e.g. through branding or logo on presentation materials, a specific product or service either as a sole recommendation or as a clear leader in a list of product/service options. Promotional intent may be conveyed in written, visual, audio or any other media format.
Examples:
- An Elevate article written with a solution provider co-author referencing the solution provider’s company/product/service as the clear leader.
- A Webinar, eLearning module, workshop slides etc. in which presenters use company/product/service-branded video backgrounds.
- A podcast in which a guest offers a case study demonstrating the superiority of his/her company’s specific product/service.
Non-Promotional Materials: Non-promotional materials provide valuable educational content without recommending or seeming to recommend a specific product or service.
Examples:
- An Elevate article written with a solution provider co-author that leverages the solution provider’s expertise to offer valuable, topic-relevant insights while including the company/product/service as an illustrative example among other options
- A Webinar in which presenters include their company titles in their introductions and first slides, but without company branding
- A podcast in which a guest describes his/her topic-relevant experience without using the discussion to drive interest in a company/product/service.
Policy:
This policy applies to items mentioned below and to any other content issued through MAPS.
- Disclosures regarding content for presentations:
The following information will be published along with all MAPS deliverables:
- Content Authorship Disclosures: Name, photo, title, company, and, academic designations per content developer/presenter (e.g., MD, PharmD).
- Conflicts of Interest Disclosures: All content developers are required to complete Conflict of Interest statements and advise the audience of such accordingly. Any disclosures will be noted in both marketing materials and presentations for IACET aligned courses and at presentations only for non-accredited presentations.
- Use of Proprietary Technology Platforms in Case Study Demonstrations:
MAPS recognizes the unique nature of visual presentations where demonstration of platforms and inclusion of case studies is central to the content of any deliverable. However, to avoid promoting, or the appearance of promotion, of any company’s proprietary platform, product, and/or service, the following are required:
- The example or case study of the proprietary platform, product and/or service should ideally be presented by someone who is notan owner or agent of the company who offers the platform/product/service, or at minimum should be co-presented with an industry member or subject matter expert who is not an owner or agent of the company who owns the platform/product/service and:
- If the presentation is showing the use of only one (1) platform in the presentation, the presentation may notjust be a demonstration of that platform. Rather, it must reference the tool in the context of a broader discussion of competency/capability development.
- If the presentation is showcasing multiple platforms to educate the audience on available technologies, it must include at least two different products from different companies, describe the platforms in a balanced manner, giving equal time to each platform optionand be based on current science, evidence, and clinical reasoning
- Wherever possible, use of generic phrases for the technology instead of proprietary brands should be made.
- When responding to specific questions from the audience about the technology demonstrated/mentioned no company name or proprietary brand will be mentionedor mention will be made of at least one competitor’s products with similar capabilities.
- No references will be made to “our products”.
- Conference Workshops, Panels or Training Programs (virtual or in-person):
MAPS does not offer company “sponsored” workshops at its conferences/events. Thus, MAPS has a strict policy on corporate branding, and workshops and panels should not be deemed promotional in nature:
- Discussing company products is not allowed, unless fair and balanced presentation of competing products or services is also included.
- Logos of facilitators’ companies are permitted only on the secondary title slide in conjunction with the facilitators’ names, title and company.
- Evaluations will be completed by workshop participants and low scores on the objective (i.e., non-promotional) nature of the workshop could factor into future invitations to present at MAPS events.
- Sponsored Podcasts:
MAPS offers podcasts to Partner Circle member (PCM) companies. A notice of the podcast sponsorship must be disclosed to the audience in all marketing materials and shhared verbally with the audience at the beginning of the podcast
- Partner Circle Member (PCM)-led Webinars:
MAPS offers PCM companies to host a webinar. A notice of the webinar sponsorship must be disclosed to the audience In all marketing materials and on the first slide of the webinar.
Responsibilities:
- The CEO and Director L & D will:
- Through active promotion of this policy, regularly review the leadership and commitment given to Non-Promotion and Conflict of Interest Disclosure.
- Monitor performance by way of periodic review of staff reports and evaluations
- Ensure that the organization’s practices and processes incorporate precautions against infractions of this policy;
- Review and report to the Board of Directors, as appropriate, on the effectiveness of the management systems established to ensure non-promotional nature in all MAPS issued content.
- Analyze material breaches and identified compliance system weaknesses for systematic trends and ensure that any adverse trends are addressed.
- Promote a culture of effective policy compliance across the organization.
- MAPS officers, directors, employees, independent contrators, volunteers, or agents otherwise will:
- Ensure that they are aware of the organization’s policy and agree to adherence of this policy.
- Not act in a manner that is contrary to the policy.
- Where appropriate, suggest ways in which practices, systems and procedures could be improved so as to reduce the likelihood of discrimination occurring.
Processes:
The CEO will initially review the organization’s procedures in all areas to ensure that these are in accordance with the principles expressed in this policy, and will report to the Board of Directors on this matter.
The CEO will review any changes to the organization’s procedures in all areas to ensure that these are in accordance with the principles expressed in this policy.
Educational content developers/planners and instructors are made aware of the policy through their Content Participation Agreement, and through a discussion of this and all relevant policies during the kickoff call. Everyone involved in the development of course content and all MAPS staff are required to accept compliance with the policy via the Content Participant Agreement /via email confirmation acknowledgement.
This policy, as well as all other applicable policies, is provided to learners via a link to the policy posted on MAPS website.
MAPS staff is trained on this policy through an email notice and subsequent in-service to discuss adherence.
Non-Compliance:
Any notice of non-compliance with the policy will be immediately reviewed. If a content developer/presenter is deemed to not be in compliance with the policy in regards to the development, presentation, or learning of a MAPS continuing education offering, s/he will be advised of the infraction, and will be given one opportunity to immediately correct the infraction. If the infraction is not corrected forthwith or if a second violation occurs, the individual and company will be removed from the program and from any working group or team responsible for content and barred from participating in any current and future MAPS content development and/or presentation.