UW Medicine Compliance

Gifts, Food, and Meals from External Sources – FAQs

The intent of the following FAQs is to help UW Medicine workforce members, including faculty, staff and trainees, navigate the applicable laws, policies and rules governing the receipt of gifts, food and meals from external sources.

At the heart of this issue is influence — whether the externally-supported gift, including food, meals, beverages, travel, services, supplies, equipment or pharmaceuticals, could be viewed as an attempt to influence your judgment about business-related decisions impacting the work you do for UW Medicine. Your entity’s policies may also put limits on what gifts you can accept. In addition, the State Ethics Law places restrictions on gifts for state employees.

This document primarily addresses gifts directed at individuals. If your job responsibilities include decision-making about contracting or purchasing with specific vendors, you should be aware that there are greater restrictions on the gifts you can accept from those vendors. If you are a state employee and have this type of job responsibility, then you are likely considered to be a “Section 4” employee with respect to the specific vendors with whom you are engaged in contract or purchasing decision-making. The Washington State Executive Ethics Board (EEB) website has additional resources which you are encouraged to review for more specific information on gift restrictions that may apply to you.1

In addition, UW School of Medicine faculty members are subject to stringent limitations, and cannot accept any gifts of any kind from commercial entities (including any food or beverages, as well as promotional items such as pens or pads), as further explained in the UW School of Medicine Policy on Potential Financial Conflicts of Interest for Commercial and Non-Profit Entities.

The FAQs represent general guidance, tailored to the facts of the scenarios described below. Accordingly, the appropriate guidance for other scenarios may vary, depending on the specific details of those scenarios. If you have any questions, consult with your department chair, department director, supervisor or manager.

1 The WA State Executive Ethics Board’s Ethics in Public Service Act material on “Gifts” provides additional information on the gifts limitations for state employees who are considered to be “Section 4” employees and those who are not.

Are you saying gift giving is bad or that we should just refuse all gifts?
Can I attend a vendor-sponsored offsite educational event?
What if I wanted to attend a vendor-sponsored dinner event at a restaurant or other location, during which a vendor representative or other speaker talks about a particular disease, technique or treatment, which may or may not mention the vendor’s products/services?
Are there other situations where I can accept meals and beverages?
A vendor wants to show us their new equipment, but the only time we can meet is during our lunch break. We will be working through our lunch as we listen to their sales pitch. Can they pay for our lunch?
What if I go to a work-related conference and a vendor is sponsoring the hosted happy hour? Can I have hors d’oeuvres and wine there?
I went to a conference paid for by work. Each attendee was automatically eligible to win a door prize and I won a tablet PC donated by a vendor. Can I personally keep it?
What if I had paid my own way to the same conference, including travel, lodging and conference registration fees and had gone on my vacation time? Could I keep the door prize?
We have a long-standing relationship with a vendor and we are midway through a five-year contract. The vendor wants to take my team out for a boat cruise to show their thanks for our business. Can we accept it?
A vendor with whom we do business really likes my work and wants me to participate in their corporate focus group. They will pay for my airfare, hotel, meals and time. Can I accept this invitation?
I never knew so many things were prohibited. What would be acceptable for a vendor to give me?
What about patients? May I accept a gift from a patient?

REFERENCE LINKS

FAQ – PDF VERSION

Gifts, Food and Meals from External Sources