Relationships with Industry
Physician Payment Sunshine Act (“Open Payments”)
The Physician Payment Sunshine Act, operated by the Centers for Medicare and Medicaid Services ("CMS") as the Open Payments Program, was enacted to increase transparency around relationships that physicians and teaching hospitals have with manufacturers and group purchasing organizations. ASTRO works to educate its membership about the Open Payments Program, including alerting them to the types of activities that will result in data being reported about them and the steps they need to take to review data after it has been reported. ASTRO maintains FAQs on this topic for its members. For the most comprehensive and up-to-date information about the Open Payments Program, visit the CMS website.
Approved November 2009
We are committed to abiding by the highest business standards and engaging in behaviors that will enhance the reputation and maintain the integrity of ASTRO Corporate Membership. To this end, we look to the ASTRO code to provide a framework and mechanisms for setting minimum standards of behavior, educating Members, monitoring Industry activities and development and promoting self-regulation and disciplinary functions.
As a Corporate Member, we agree to adhere to the ASTRO Corporate Member Code of Ethics in the way we conduct our business activities as follows:
- Place the highest priority on the safety and welfare of patients being treated with or on our products, and the health care professionals working with these products.
- Adhere to relevant law and regulations that govern our Industry, including: requirements for the advertising and promotion of our products as prescribed by the U.S. Food and Drug Administration relating to product claims and promotion and requirements for our interactions with health care professionals relating to improper inducements to purchase our products and services.
- Adopt ethical standards that are consistent with the Department of Health and Human Services’ Office of Inspector General (OIG) Compliance Program Guidance for Pharmaceutical Manufacturers and any other applicable codes or standards, such as the Accreditation Council for Continuing Medical Education (ACCME), the American Medical Association’s Code of Ethics Opinion relating to Continuing Medical Education and Gifts to Physicians from industry, the PhRMA Code on Interactions with Health care Professionals, the Medical Imaging and Technology Alliance (MITA) Code of Ethics on Interactions with Health care Providers, and AdvaMed’s Code of Ethics on Interactions with Health Care Professionals.
ASTRO Policy on Corporate Relationships
ASTRO’s organizational mission statement and strategic plan provide principled guidance for all corporate relationships. The types of corporate relationships developed by ASTRO shall be consistent with the core purpose and values of ASTRO. All corporate relationships must be evaluated against ASTRO’s primary objective to provide representation and leadership for the profession and to advance public health.
ASTRO should participate in corporate arrangements when these guidelines are met and the arrangements prove to further ASTRO’s purpose, avoid conflict of interest and safeguard ASTRO’s objectivity.
Definition of Corporate Relationship
Corporate relationship shall mean any arrangement or transaction between ASTRO and a corporation that furthers the mission of ASTRO.
General Principles
- Any proposed relationship must be evaluated to ensure that it is driven by a commitment to the general principles established in the Society’s mission.
- The relationship must preserve and promote trust in the Society by the medical profession, medical corporations, regulatory agencies and the public.
- The relationship must maintain objectivity with regard to health issues.
- The relationship should be mutually beneficial with clearly defined and transparent expectations from ASTRO and from the industry perspective.
Guidelines
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Consistency with ASTRO’s Mission. When appropriate and desirable, ASTRO will participate in corporate relationships to support activities that further the Society’s objective of promoting the practice and science of radiation oncology and the betterment of public health.
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Review and Approval. All ASTRO major service and educational program support shall be reviewed by the Board of Directors and/or their designates. All industry-supported programs must be in accordance with ASTRO policies.
ASTRO accepts corporate support only if acceptance does not pose a conflict of interest and in no way impacts actual or perceived objectivity of the Society, its members, activities, programs or employees. All educational programming is organized and conducted by the Education Committee and is independent from Corporate Relations and any sponsorship activity.
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No Endorsement. Participation in specific corporate relationships does not in any way imply ASTRO’s endorsement of that corporation’s general policies or products, nor does it imply that ASTRO will exert any influence to advance the corporation’s interests outside the substance of the support itself. ASTRO does not permit use of its logo or name unless it is used with specific and written approval by ASTRO. Current policy is as follows:
ASTRO, the name American Society for Radiation Oncology and the ASTRO logo are registered trademarks of the American Society for Radiation Oncology. Use of the aforementioned in conjunction with advertisements, promotional materials, endorsements, statements, contests and/or awards of any kind without the expressed consent of the American Society for Radiation Oncology is prohibited. Violators may be subject to such civil and criminal penalties as provided by federal and state laws.
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Promotion/Marketing. The corporation will submit for review and approval all materials bearing Society’s name or identity in accordance with these principles and guidelines. Such review is not required for materials produced under ASTRO’s control. Corporate supporters will be appropriately recognized.
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ASTRO’s Authority. Any ASTRO program which has received a grant or contribution from a corporation will be managed and administered solely by ASTRO or an ASTRO approved process in accordance with these rules and principles. ASTRO retains editorial control over any information produced as part of a corporate relationship. All materials in print, broadcast, or electronic media prepared by the corporate entity must be submitted to ASTRO for approval in writing prior to release. All ASTRO CME activities will be planned and implemented without input from commercial supporters.
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CME Rules. ASTRO and its commercial supporters will abide by the standards established by the Accreditation Council for Continuing Medical Education(ACCME) in the Standards for Commercial Support, the American Medical Association’s Ethical Opinion on Continuing Medical Education and Gifts to Physicians, the Food and Drug Administration regulations regarding Industry-supported Scientific and Educational Activities, the PhRMA code on Interactions with Healthcare Providers, the AdvaMed Code of Ethics on Interactions with Health Care Professionals, the NEMA guidelines and the CMSS Code for Interactions with Companies. All commercial supporters of CME activities will sign a Letter of Agreement (LOA) outlining the conditions under which the commercial support will be provided. No funds from the commercial supporter will be paid directly to any ASTRO faculty/planner/committee member or others involved with the CME activity.
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Oversight. The ASTRO Board of Directors is responsible for overseeing the enforcement of these principles and guidelines governing relationships with corporations. The Chief Executive Officer is responsible for the implementation of each corporate relationship in accordance with the above principles and guidelines. The Education Department is responsible for ensuring compliance with ACCME requirements, specifically that every commercial supporter of a CME activity provides a signed LOA in advance.
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Benefits. It is understood that any relationship, membership, sponsorship or other where benefits are extended to industry by ASTRO will not be abused or misused.