Purpose & Scope
The purpose of this policy is to identify and prevent conflicts of interest due to a medical
relationship between Rocky Vista University College of Osteopathic Medicine (RVUCOM)
employees and appointed faculty and RVUCOM students. RVUCOM students are encouraged to
seek medical care from health professionals who are not actively engaged in their educational
program as current or anticipated supervisors or evaluators to prevent any conflict of interests.
This policy aims to maintain objectivity and impartiality in the evaluation process and to avoid
any potential conflicts of interest that may arise from a treating physician-student relationship.
In the event of conflict with other university policy, the interest of the students’ privacy and the
examination integrity will prevail.
Policy Statement
An RVUCOM employee or appointed faculty who has provided any medical treatment to
a student must recuse themselves from participating in any activities or decisions related to assessment or promotion of the student.
- Faculty are required to vote on the promotion of students to graduate. In the event that a faculty member has a healthcare relationship with a student, they are required to follow RVUCOM process for recusal from the graduation vote.
- RVU is committed to ensuring the prevention of potential conflicts of interest for student academic advancement and assessment.
- Students in the preclinical phase of training are responsible to inform department leadership immediately upon recognizing that there is a potential conflict of interest based on a healthcare relationship. Procedures to report potential conflicts are noted in the appendices of this policy.
- In the clinical phase of training, neither RVUCOM faculty nor any RVUCOM adjunct clinical faculty will serve as health care providers for RVUCOM students except in emergency situations. Students in the clinical phase of training are responsible to inform appropriate department leader immediately upon recognizing that there is a potential conflict of interest based on a healthcare relationship. Procedures to report potential conflicts are noted in the appendices of this policy.
- 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 as long as this is not in conflict with any RVU program-specific policies. Patient confidentiality will be strictly protected for RVU students in clinical settings.
- Such conflicts of interests and recusals must be reported immediately to the department supervisor, course director, or designee.
Roles & Responsibilities
| Position | Roles/Responsibilities |
| Dean/Director/Chair/Clinical Dean | Annually communicates this policy to faculty and students and is ultimately responsible for compliance to this policy |
| Course Director/Clerkship Director/ Regional/Site Director | Ensures procedures are in place to ensure compliance to this policy |
| Faculty | Must disclose conflict of interest to course director or clerkship director and recuse themselves accordingly |
| Students | Must disclose a conflict of interest to course director or clerkship director and recuse themselves accordingly |
| Administrative assistants, preclinical | Manage databases, make schedules, review student encounters |
Related Processes, Procedures, and/or Definitions
- Appendix 1: Department of Osteopathic Principles and Practice Policies and procedures for faculty and student recusal (with forms)
- Appendix 2: Department of Primary Care Medicine and Ultrasound curriculum policies and procedures for faculty and student recusal (with forms)
- Appendix 3: Clinical Education Department Policies and Procedures for Conflict of Interest & Student Confidentiality in the Clinical Setting
Appendix 1
Osteopathic Principles and Practice (OPP) department policies and procedures for faculty and student recusal
Document 1
- Purpose and Scope:
Faculty and Fellows of the OPP department on both RVUCOM campuses offer Osteopathic Manipulative Medicine/Osteopathic Manipulative Treatment) services for all faculty, staff, and students of the RVU community. In the interest of academic integrity and excellent patient care, the OPP department strives to ensure that department members will not be responsible for proctoring competency or practical examinations for students that they have seen as patients in an RVU or external clinical setting. This policy applies to all OPP department members, including faculty, fellows, and adjunct faculty.
- Procedures:
The OPP Fellows and their respective administrative assistant will maintain a spreadsheet with a complete list of all students seen in the OPP Clinics/Clinical labs. This document will be housed within the OPP Fellowship Teams page in a secure folder. The administrative assistants, course directors, Chair, and Vice-Chair will have access to the document.
This list will include the name of the student, the fellow and the precepting faculty member. Individual faculty members seeing patients in their individual clinics, either private or RVU based clinic, will be responsible to report this information to the administrative assistant as soon as possible prior to assessments.
The administrative assistants will refer to this document as they are building the schedule for practical and competency examinations in OPP and work to ensure that no faculty member is proctoring an examination for a student they have seen in clinic.
Often these schedules are built 3-4 weeks prior to the examination date. As a result, the administrative assistant will double check the documents against the schedule the day prior, as well as the day of the examination or competency date in the event changes need to be made.
Each OMM clinic will work within the constraints of their clinic structures to limit the number of faculty and fellows treating any individual student. Furthermore, students will be required to acknowledge and sign an attestation informing them of their rights pertaining to academic integrity related to faculty recusal and conflict of interest, and of their responsibility to alert the department of any conflicts of interest.
Despite these efforts, there may be times when a particular student will have been evaluated and treated by regular, full-time OPP department faculty members. In this event, adjunct faculty not involved in a student's medical care will be used for initial course examinations/competency evaluations. In the event of in-course mitigation or course failure remediation, which requires full-time faculty to administer, the Chair or Vice-Chair will either administer the course examination or competency or coordinate with the student and the Assistant Dean of Osteopathic Integration to find an acceptable faculty member.
- Additional Information:
Through the syllabus students will be informed of this policy and encouraged to communicate with the Course Director or department administrative assistants if they recognize a conflict has occurred
Appendix 1
Osteopathic Principles and Practice (OPP) department policies and procedures for faculty and student recusal
Document 2
Faculty and Fellows of the OPP department on both RVUCOM campuses offer OMM/OMT services for all faculty, staff, and students of the RVU community. In the interest of academic integrity and excellent patient care, the OPP department strives to ensure that department members will not be responsible for proctoring competency or practical examinations for students that they have seen as patients in the RVU or external clinic setting. This policy applies to all OPP department members, including faculty, fellows, and adjunct faculty.
- I understand that the Fellows and preceptors that care for me in this clinic setting are also part of my educational experience at RVUCOM. Student initials
- OPP Department is monitoring who is seen in clinic for scheduling purposes of competency and practical examinations only. No personal information is collected beyond who cared for me and the dates I was seen. Student initials
- To the best of their ability, the OPP Department will work to ensure that those who cared for me in clinic will not be placed in a position of examining me for competency or practical examinations. Student initials
- I understand that there may be circumstances beyond the control of the OPP Department that may make it impossible to avoid this altogether. In such a case, I understand that that OPP Department will work with me and the Assistant Dean of Osteopathic Integration to come to an acceptable alternative.
Student initials
- I understand that if I notice a conflict, it is my responsibility to bring it to the attention of the OPP Department (administrative assistant, course directors, or Chair/Vice-Chair).
Student initials
Student signature: Date:
Printed name:
Fellows signature: Date:
Printed name:
Faculty Signature: Date:
Printed name:
Appendix 1
Osteopathic Principles and Practice (OPP) department policies and procedures for faculty and student recusal
Document 3
Faculty and Fellows of the OPP department on both RVUCOM campuses offer OMM/OMT services for all faculty, staff, and students of the RVU community. In the interest of academic integrity and excellent patient care, the OPP department strives to ensure that department members will not be responsible for proctoring competency or practical examinations for students that they have seen as patients in the RVU or external clinic setting. This policy applies to all OPP department members, including faculty, fellows, and adjunct faculty.
The policy and procedures relative to each campus are located in the OPP Faculty onboarding document that is located on the OPP Department Teams page.
I am aware of the policy and procedures for my recusal from student grading as a result of conflict of interest including a doctor-patient relationship, as well as other personal or professional concerns.
Faculty Printed Name: Date:
Faculty Signature:
Appendix 1
Osteopathic Principles and Practice (OPP) department policies and procedures for faculty and student recusal
Document 4
OPP Practical – XX/XX/XXXX | |||
| By signing this form, I am attesting that I haveNOT been seen and medically treated by the assigned Faculty and/or Fellow for this exam. | |||
| No talkingis allowed betweenpartners while diagnosing (except to givepatient directions). | |||
| “By signing this form, I am attesting that I haveread and agreeto the termsof the Consent, Waiver and Release document provided at check-in for this examination.” | |||
This competency session could be recorded | |||
| First Name | Last Name | Faculty Member | Signature |
Appendix 2
Primary Care Medicine Department Policy on Faculty Recusal from Student Examination and Grading
Document 1
- Purpose and Scope:
Faculty of the PCM department and Ultrasound on both RVUCOM campuses offer clinical services for all faculty, staff, and students of the RVU community. In the interest of academic integrity and excellent patient care, the PCM department and Ultrasound strives to ensure that department members will not be responsible for proctoring competency or practical examinations for students that they have seen as patients in the RVU or external clinic setting. This policy applies to all PCM department and Ultrasound members, including faculty and adjunct faculty.
Procedures:
The PCM Department Faculty and Ultrasound will email their respective administrative assistant/coordinators weekly with a complete list of all students seen in RVUCOM or other clinical settings. This list will include the names of students and faculty members.
Individual faculty members seeing patients in their private clinics will be responsible to report this information to the administrative assistant/coordinators as soon as possible.
The administrative assistants/coordinators on each campus will populate and maintain a spreadsheet of this information. It will be located on the RVU Shared Drive as a password protected document. The administrative assistants, course directors, Chair, and Vice-Chair will have access to the password and document.
The administrative assistants/coordinators will utilize and cross-reference this spreadsheet document as they are building the schedule for practical and competency examinations in the PCM Courses and work to ensure that no faculty member is proctoring an examination for a student they have provided medical care in any clinical setting. Any grading such as SOAP notes, Procedure notes, and other assignments can be reassigned to another faculty at the discretion of the Course Director and or the Chair or Vice Chair.
In addition, the administrative assistant/coordinators will recheck the spreadsheet document and make any necessary updates to prevent a breach in the RVU policy Conflict of Interest & Student Confidentially in the Clinical Setting.
Each RVU clinic will work within the constraints of their clinic structures to ensure that students are treated by the least number of faculty. Furthermore, students will be required to acknowledge and sign a waiver informing them of their rights and that the PCM Department and Ultrasound will do their best to avoid instances where students may be academically assessed by a PCM Department and/or Ultrasound faculty member that they have seen in a clinical setting. The student will also be informed of their right and responsibility to let the department know of potential conflicts.
Despite these efforts, there may be times when a particular student will have been evaluated and treated by regular, full time PCM Department and Ultrasound faculty members. In this event, an adjunct faculty not involved in their patient care will be used for initial examinations / competency evaluations. In the event of in-course mitigation or course failure remediation, which requires full-time faculty to administer, the Chair or Vice-Chair will either administer the examination or competency or coordinate with the student to find an acceptable faculty member.
A separate document entitled ‘Procedure for Faculty Recusal from Student Examination, Practical Exams & Competency Exam Schedules’ held in the PCM Department and Ultrasound outlines the process for tracking student/preceptor interaction in the clinics on each campus. It also outlines the recusal process and procedures.
Additional Information:
Through the syllabus students will be informed of this policy and encouraged to communicate with the Course Director or department administrative assistants if they recognize a conflict has occurred.
Appendix 2
Primary Care Medicine Department Policy on Faculty Recusal from Student Examination and Grading
Document 2
Procedure for Faculty Recusal from Student Examination Practical & Competency Exams Schedules RVUCOM CO/UT Campuses
The faculty for any practical or competency examination cannot test students they have seen in a RVU clinic or in a private clinic.
Guidelines for tracking and scheduling these examinations:
The faculty will notify the Administrative Assistant/Coordinator to populate and maintain an excel spreadsheet with the information needed to track and monitor students who are seen by a faculty. This spreadsheet is located on the RVU (U:) Drive and is only accessible by those that have permission. Those with access will be administrative assistants, course directors, Chair/Vice Chair, and fellows.
- In addition, any Physician seeing patients in a private clinic will email the Administrative Assistant/Coordinator if a student of RVU was seen and the spreadsheet will be updated to reflect those changes.
- Scheduling the practical and competency examinations:
- Administrative Assistants/Coordinators create the schedule for exams.
- Once the faculty are assigned to the groups, the Administrative Assistants/Coordinators check the master excel file for conflicts.
- If there is a conflict, reassign the student and/or the faculty.
- If a student has been seen by a full or part time faculty in the department, use an adjunct to test.
If the student has failed one of these exams and are in the process of remediation/mitigation, and the student has been seen at the clinic by all the full time or part time faculty that are testing, the Chair/Vice Chair would then talk to the student in order to find an acceptable alternative. This could include the Chair/Vice Chair testing or a faculty member acceptable to all parties.
Any grading such as SOAP notes, Procedure notes and other assignments can be reassigned to another faculty at the discretion of the Course Director and or the Chair/Vice Chair.
Appendix 2
Primary Care Medicine Department Policy on Faculty Recusal from Student Examination and Grading
Document 3
PCM and Ultrasound Department Faculty Acknowledgement of Recusal Policies and Procedures
Faculty of the PCM department and Ultrasound on both RVUCOM campuses offer clinical services for all faculty, staff, and students of the RVU community. In the interest of academic integrity and excellent patient care, the PCM department and Ultrasound strives to ensure that department members will not be responsible for proctoring competency or practical examinations for students that they have seen as patients in the RVU or external clinic setting. This policy applies to all PCM department and Ultrasound members, including faculty and adjunct faculty. The policy and procedures relative to each campus are located in the PCM and Ultrasound Faculty onboarding document that is located in the PCM Teams page.
I am aware of the policy and procedures for my recusal from student grading as a result of conflict of interest including a doctor-patient relationship, as well as other personal or professional concerns.
Faculty name: Date:
Appendix 2
Primary Care Medicine Department Policy on Faculty Recusal from Student Examination and Grading
Document 4
RVUCOM PCM and Ultrasound Department Notice of Student Acknowledgement of Faculty Recusal from Student Examination
- I understand that the PCM Department Faculty and Ultrasound that care for me in a clinic setting are also part of my educational experience at RVUCOM.
Student initials
- The PCM Department and Ultrasound is monitoring the schedule for purposes of competency and practical examinations only. No personal information is collected beyond who cared for me and the dates I was seen.
Student initials
- The PCM Department and Ultrasound will work to ensure that those who cared for me will not be placed in a position of grading me for competency or practical examinations.
Student initials
- I understand that there may be circumstances beyond the control of the PCM Department and Ultrasound that may make it impossible to avoid this altogether. In such a case, I understand that that PCM Department and Ultrasound will work with me and the Director of Pre-Clinical Education to come to an acceptable alternative. Any grading such as SOAP notes, Procedure notes and other assignments can be reassigned to another faculty at the discretion of the Course Director and or the Chair/Vice Chair.
Student initials
- I understand that if I notice a conflict, it is my responsibility to bring it to the attention of the PCM Department and Ultrasound (administrative assistant, course directors, or Chair/Vice-Chair).
Student initials
Student signature:
Faculty Signature:
Appendix 3
Clinical Education Department Policies and Procedures for Conflict of Interest & Student Confidentiality in the Clinical Setting
Document 1
Rocky Vista University College of Osteopathic Medicine (RVUCOM) 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.
RVUCOM 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 RVUCOM faculty nor any RVUCOM adjunct clinical faculty will serve as health care providers for RVUCOM students except in emergency situations. RVUCOM 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 as long as 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 policy 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
Appendix 3
Clinical Education Department Policies and Procedures for Conflict of Interest & Student Confidentiality in the Clinical Setting
Document 2
RVUCOM Students have the right to not be assessed by a physician who has seen them as a patient in the clinical setting. will inform my clinical coordinator and regional/site director of any potential conflict of interest or breach of student confidentiality immediately.
To affirm that potential conflicts to the policy do not exist, OMS III and OMS IV students complete an End-of-Clerkship Evaluation for each clinical clerkship. To ensure that students seeking healthcare should not be placed in a position in which they could potentially interact with any preceptor that has authority over their educational pursuits, they will be asked to state that they did not receive medical or other professional services or treatment from the preceptor or if they did, that it was voluntary.
End-of-Clerkship Evaluation Questions 25
Please select one and then enter your preceptor’s name in the comments box:
- I have read the Conflict of Interest & Student Confidentiality in Clinical Setting policy located 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 Conflict of Interest & Student Confidentiality in Clinical Setting policy located in the course syllabus and attest that I have voluntarily 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 forwarded to the Director of Clinical Curriculum Management for review and investigation if necessary.