Policy on Interactions with External Partners and Potential Influences on Judgment

The Institute for Clinical and Economic Review (ICER) provides independent evaluation of the clinical effectiveness and comparative value of health care interventions. In order to ensure the integrity of its research and policy development activities, and to mitigate potential negative impacts, ICER has developed this statement on internal standards for conflicts of interest, interactions with external partners and its approach to managing potential influences on judgment among all participants in its appraisal and policy development work.

Governance
ICER’s activities are led by a senior management team with oversight from a Governance Board and strategic input from a diverse Advisory Board.

Funding
To meet ICER’s goals of objectivity and transparency, ICER accepts funding from a diverse set of sources (including government agencies, private philanthropies, non-profit foundations, health plans, manufacturers). The ultimate decisions within and across research projects are ICER’s alone.

Conflicts of Interest and Potential Influences on Judgment
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 has adopted the following criteria for employees of ICER for avoiding conflicts of interest in its work:

  • 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.