Mass General Brigham welcomes and supports its relationships with Suppliers and has many different ways in which it interacts with them. These relationships are essential in supporting Mass General Brigham’s mission of providing, promoting, and supporting high quality and leading-edge patient care, research, and medical education. At the same time, Mass General Brigham recognizes that these relationships may give rise to conflicts of interest which create a risk of introducing bias, or the appearance of bias, in how Mass General Brigham carries out its mission and its business operations. In order to manage this risk, Mass General Brigham has an extensive conflict of interest policy that address the concern about potential bias in all the different types of relationships that Mass General Brigham has with Suppliers.
A primary component of the Mass General Brigham conflict of interest policy that is relevant in the context of business contracts is a comprehensive ban on gifts from all Suppliers. This ban applies to all employees of Mass General Brigham, including all full-time and part-time employed physicians, and to other individuals when they are acting in a Mass General Brigham capacity. The definition of gifts prohibited by this policy includes many things Suppliers are accustomed to offering to their clients or customers; it covers meals, trips, tickets to sporting events, holiday baskets and even items of minimal value such as pens and coffee mugs. In addition to this Mass General Brigham standard, physicians and other prescribers are subject to particularly stringent state and federal requirements concerning acceptance of items or services from pharmaceutical or medical device vendors, and gifts from Suppliers may also violate anti-kickback laws.
In addition to prohibiting gifts given directly to MGH-affiliated individuals, the Mass General Brigham gift policy prohibits gifts to a Mass General Brigham affiliated institution that are intended ultimately to be for the personal use or benefit of Mass General Brigham individuals – such as a gift to a Mass General Brigham department of food or support for a departmental meal for its members.
As Suppliers of Mass General Brigham, we expect companies to be aware of and to follow this gift policy, and to inform their representatives of the policy and to ensure that their representatives also follow the policy.