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.
- UW Medicine Entity Codes of Conduct
- UWP Employee Handbook
- UW School of Medicine Policy on Potential Financial Conflicts of Interest for Commercial and Non-Profit Entities
- UW Medicine Advancement
- Washington State Code of Ethics for Municipal Officers
- Washington State Ethics in Public Service Act
- Anti-Kickback Statute