MCOM Health Care Conflict of Interest and Recusal Policy

Purpose & Scope

The purpose of this policy is to identify and prevent academic conflicts of interest arising from healthcare provider-patient relationship between Rocky Vista University (RVU) employees or appointed faculty and RVU students. This policy seeks to uphold impartiality in the assessment and promotion processes for all RVU students. It applies to all University employees, appointed faculty, and students.

Policy Statement

Rocky Vista University is committed to ensuring that any employee or faculty member who provides healthcare services to an RVU student does not engage in any activities or decisions related to assessment or promotion of the student.  If a conflict of interest is identified, the involved employee or appointed faculty member must disclose it immediately and recuse themselves from any involvement in the student’s assessment or promotion.  
 

Roles & Responsibilities

Dean	Annually communicates this policy to employees, faculty and students and is ultimately responsible for compliance of this policy.
Chair/Course Director/ Regional or Site Director	Ensures procedures are in place and that these procedures are being followed.
Employees and Appointed Faculty	Avoids provider-patient relationship with students as much as feasible. Must disclose conflict of interest and recuse themselves if such a relationship was or is established.
Students	Discloses conflict of interest if a provider-patient relationship exists.

 

Related Processes, Procedures, and/or Definitions

Appendix 1: Preclinical Procedure for Students to Disclose a Conflict of Interest

Appendix 2: Preclinical Procedure for Faculty to Disclose a Conflict of interest and Recusal.

Appendix 3: Student Conflict of Interest Disclosure and Recusal Form 

Appendix 4: Clinical Education Procedures for Conflict of Interest & Student Confidentiality in the Clinical Setting

Appendix 5: Conflict of Interest and Student Confidentiality in the Clinical Setting Attestation Form

 

Appendix 1

Preclinical Procedure for Students to Disclose a Conflict of Interest

Student conflicts of interest must be reported promptly to the department supervisor, course director, or designee via email.

Conflict of interest emails should include the following:

1. Acknowledgement that a conflict of interest exists (specific details not required)

2. Name(s) of faculty involved

Each conflict of interest will be reviewed and verified by the email recipient, communicated to the department supervisor, and recorded in a Conflict of Interest and Recusal Log. The department supervisor or designee will update the log on a regular basis and reference it when scheduling testing or graded assignments.

Conflict of Interest Disclosure and Recusal forms are also available at practical or clinical assessment situations/locations for any last-minute disclosures.

 

Appendix 2

Preclinical Procedure for Faculty to Disclose a Conflict of interest and Recusal

Faculty recusals must be reported promptly to the department supervisor, course director, or designee via email.

Recusal emails should include the following:

1. Acknowledgement that a conflict of interest exists (specific details not required) and of the need for recusal

2. Name(s) of student(s) involved

Each recusal will be reviewed and verified by the email recipient, communicated to the department supervisor, and recorded in a Conflict of Interest and Recusal Log. The department supervisor or designee will update the log on a regular basis and reference it when scheduling testing or graded assignments.

Conflict of Interest Disclosure and Recusal forms are also available at practical or clinical assessment situations/locations for any last-minute disclosures.

 

Appendix 3

Conflict of Interest Disclosure and Recusal Form

 

Name of Attestant: ________________________

 

Role at RVU (check one):

▢ Faculty 

▢ Student 

 

Attestation

­­____  I understand the importance of maintaining integrity and transparency within the educational environment at RVU and that conflicts of interest are to be reported truthfully and completely.

 

____  I attest to a conflict of interest with the individual(s) listed below.

 

Name(s) of Faculty/Student(s) involved:

1. ­­­­­_________________________________________
2. _________________________________________
3. _________________________________________
4. _________________________________________

 

Signature:        __________________________

 

Print Name:     __________________________

 

Date:                __________________________

 

Appendix 4:

Clinical Education Procedures for Conflict of Interest & Student Confidentiality in the Clinical Setting

RVU-MCOM students will not be academically assessed by a physician who has seen them as a patient in the clinical setting. In situations where physician faculty must deliver emergency care to a student due to unavailability of another provider, the faculty will recuse further assessment of the student and delegate academic assessments to an available regional/site director, rotation director, or clinical dean. These situations must be reported at once by faculty and student through processes outlined in Appendices 3 & 4. This may necessitate withdrawal, change, or repeat of the clinical rotation, if a rotation does not meet the requirement for clinical education assessment.

RVU-MCOM students taking part in clinical training will not be involved in the medical care of other RVU students, unless expressed permission is individually obtained from the student patient. Patient confidentiality will be strictly protected for RVU students in clinical settings. The student will inform their clinical coordinator and regional/site director of any conflict of interest or breach of student confidentiality at once.

 All OMS III and IV students must complete an End-of-Clerkship Evaluation, where students must attest that they did not receive medical or professional services from their preceptor during the clerkship. If a conflict of interest is found, the Regional or Site Director will complete the student’s evaluation after gathering feedback and relevant information from other people who were involved in the student’s clinical clerkship experience. _____________________________________________________________________________________________________________

End-of-Clerkship Evaluation:  Question 25

 Please select one and then enter your preceptor’s name in the comments box:

• I have read the Health Care Conflict of Interest and Recusal policy found in the course syllabus and attest that I have not ever received medical or other professional services or treatment from (enter the preceptor’s name in the comment box).

 

• I have read the Health Care Conflict of Interest and Recusal policy found in the course syllabus and attest that I have received medical or other professional services or treatment from (enter the preceptor’s name in the comment box).

 

 

Once per academic block, the Clinical Curriculum Coordinator will review the End-of-Clerkship Evaluations to determine completion of the question. Any unanswered questions will be sent to the Assistant/Associate Dean of Clinical Education for review and investigation if necessary.

 

Appendix 5:

Conflict of Interest and Student Confidentiality in the Clinical Setting Attestation Form

Rocky Vista University – Montana College of Osteopathic Medicine (RVU-MCOM) is committed to ensuring the prevention of any type of conflicts of interests for students regarding academic advancement and the protection of student confidentiality in the clinical setting.

RVU-MCOM is committed to ensuring the prevention of potential conflicts of interest for student academic advancement and the protection of student confidentiality in clinical education settings. Neither RVU-MCOM faculty nor any RVU-MCOM adjunct clinical faculty will serve as health care providers for RVU-MCOM students except in emergency situations. RVU-MCOM Students have the right to not be academically assessed by a physician preceptor who has seen them as a patient in the clinical setting. Students are responsible to inform their clinical coordinator and regional/site director immediately upon recognizing such a situation.

RVU students participating in clinical training will not be involved in the medical care of other RVU students, unless expressed permission is individually obtained from the student patient and if this is not in conflict with any RVU program-specific policies. Patient confidentiality will be strictly protected for RVU students in clinical settings.

Student Attestation

 I, _______________ , have read and understand the above statement and will inform my clinical coordinator and regional/site director of any potential conflict of interest or breach of student confidentiality immediately.

 

___________________________________________________________________________________________________________

Student Signature                                                                               Date

 

revised 9.23.24