IPSIS DISCLOSURE AND CONFLICT OF INTEREST POLICY

The International Pain and Spine Intervention Society (IPSIS) is committed to implementing the highest standards for commercial independence in our programs and products.

All IPSIS volunteers and speakers are required to submit an annual disclosure to IPSIS. When changes occur to the submitted disclosure, an update must be provided immediately in writing to staff.

REQUIRED DISCLOSURES

All of the relationships listed below must be disclosed; it is not up to the disclosing party to decide whether a conflict exists. Failure to disclose or recuse oneself will result in disciplinary action, including but not limited to removal from the position, revocation of membership, or legal action.

Recusal means refraining from participating in discussions, making recommendations, exerting influence, voicing opinions, providing advice, or being involved in any aspect of the work or decision-making relating to the matter where there are potential conflicts of interest. While the recusal might not always necessitate leaving the meeting, it is the best practice, especially in leadership positions.

There are three categories of relationships that IPSIS reviews:

1. Any relationship with a “commercial company,” which generally means an organization whose primary business is producing, marketing, selling, re-selling, or distributing healthcare products such as devices, pharmaceuticals, biologics, wearables, and medical startups. The list below is not exhaustive but provides common examples of relationships with commercial companies:

• Non-ACCME-accredited speaking arrangements
• Interest, ownership, and employment
• Consulting engagements
• Advisory engagements
• Deals/agreements that may result in future remuneration, including but not limited to options, stock, and royalties
• Travel expenses, dining expenses, or gifts provided by a commercial company, regardless of the amount

Note: Employment/ownership of any of the following does not need to be disclosed under this category -- physician practice, hospital, hospital system, outpatient surgery center, clinic, etc.

2. Any relationship with:

• Medical associations (outside of IPSIS)
• Insurance companies
• Medical publishing/authorship
• Governmental entities
• Advisory boards, committees, review panels
• Paid speaker, authorship
• Grant and research support
• Royalties

3. Position of influence (self or family member) or financial interest with any entity that currently conducts or may in the future conduct business with IPSIS (e.g., vendor, service provider, consultant)

The list above is not intended to be exclusive. Questions regarding the permissibility of specific relationships should be submitted to the Conflict-of-Interest Committee (COIC).

REVIEW OF DISCLOSURES

There are three review tracks based on the individual’s role within the Society:

A. Speakers/instructors for IPSIS CME activities
B. Members of any IPSIS divisions, committees, task forces, writing groups, etc.
C. IPSIS Leadership position candidates

• Members of the Executive Committee
• Chairs of all standing divisions
• Chairs/leaders of committees, task forces, and writing groups involved in prioritizing and formulating recommendations related to clinical practice, research, or educational content. Such projects include but are not limited to position statements, guidelines, FactFinders, “Technical Manual,” systematic reviews, research grants, online materials, and course curricula.
• CPT & RUC Advisors/Alternate Advisors
• Members of the Nominating Committee
• Annual Meeting Program Chair and Vice Chair
• Editor-in-Chief of the IPSIS journal -- Interventional Pain Medicine (IPM)

Review process:

A. Speakers/instructors for IPSIS CME activities: will be subject to the current IPSIS ACCME review policy.

B. Members of any IPSIS divisions, committees, task forces, writing groups

• The chair/leader of the group will review disclosures closely at the beginning of the term, noting any topics that will require recusal from each member, and verbally review each member’s disclosures and required recusal during the first meeting. A document outlining the disclosures of all members will be circulated and reviewed at each meeting.
• The review of the disclosure document by itself is not sufficient to mitigate potential conflicts. Volunteers are expected to recuse themselves any time the business at hand may pose a conflict. Volunteers are expected to verbalize their potential conflict before taking part in any division or committee business (e.g., discussion, emails, voting).
• It is assumed that a potential conflict may exist when the business at hand involves or may affect any product, business, or involves product or business potentially competing with that in which the volunteer is involved. This includes potential conflict arising from any entities listed in bullets 1, 2, or 3 above, depending on the topic/business item discussed (i.e., commercial companies, insurance organizations, other medical societies, vendors, or any other affiliations).
• The division or committee chair is responsible for evaluating potential conflicts of interest and adjudicating the appropriateness of a volunteer’s participation or recusal. In cases of uncertainty or controversy, the matter should be referred to the COIC for review and decision.

C. IPSIS Leadership position candidates
The COIC will decide, based on a blinded review of disclosure and position requirements, whether the member can or cannot serve in the selected leadership position. If the member can serve, a proper recusal process (e.g., specific issues handled by a vice chair), with a list of topics that may involve or affect the area of conflict, will be outlined by the COIC.

IPSIS Conflict of Interest Committee
The IPSIS Conflict of Interest Committee (COIC), consisting of 2 Board members and three non-Board members, will be formed for each term. All committee members must have no “commercial company” disclosures for at least three calendar years before being appointed.

The COIC will review disclosures of the members considered for leadership positions and questions regarding disclosures and other potential conflicts.

Appeal Process
Members who disagree with the COIC decision regarding their service or recusal may appeal the decision within 15 days by submitting an appeal to the IPSSIS staff. The request will be reviewed, and a determination will be made by the full IPSIS Board of Directors (excluding anyone who may need to recuse themselves due to conflicts) at the next IPSIS Board of Directors meeting.

Violations/Complaints
Members and volunteers who wish to submit complaints about non-adherence to this policy may do so by submitting a report here or by emailing conflict@IPSISmed.org Complaints will be reviewed by the COIC, and a report will be made to the full Board on a quarterly basis.