MPJEReview | CarePath Education, LLC
1. Purpose and Scope
This Conflict of Interest Policy (“Policy”) is established to ensure the integrity, transparency, and credibility of MPJEReview, operated by CarePath Education, LLC (“Company”). The purpose of this Policy is to identify, disclose, and appropriately manage potential, perceived, or actual conflicts of interest that may arise in the development, delivery, marketing, or governance of MPJEReview’s educational content, services, and operations.
This Policy applies to all individuals involved with MPJEReview, including but not limited to:
– Subject matter experts (SMEs)
– Contractors and consultants
– Employees and volunteers
– Advisory board members
– Business partners or collaborators contributing to educational content or decision-making processes
By adhering to this Policy, MPJEReview seeks to uphold the highest standards of objectivity and independence, ensuring that all educational offerings are free from improper influence and aligned with our mission to serve pharmacy professionals preparing for the MPJE.
2. Definitions
2.1 Conflict of Interest (COI): A conflict of interest exists when a person’s personal, professional, or financial relationships or affiliations have the potential to compromise, or appear to compromise, their objectivity, impartiality, or professional judgment in relation to MPJEReview’s activities.
2.2 Actual Conflict of Interest: A situation in which a conflict currently exists between a person’s responsibilities to MPJEReview and their outside interests.
2.3 Perceived or Apparent Conflict of Interest: A situation that could reasonably be perceived by others as a conflict, even if no actual conflict exists.
2.4 Potential Conflict of Interest: A situation that may develop into an actual conflict in the future depending on circumstances.
2.5 Interested Party: Any person subject to this Policy (as outlined in Section 1) who may be in a position to influence MPJEReview’s decisions, policies, content, or operations.
2.6 Disclosure: The process by which an Interested Party informs MPJEReview of any relationships, interests, or situations that may constitute a conflict of interest.
3. Disclosure Requirements and Procedures
3.1 Mandatory Disclosure: All Interested Parties must disclose any actual, perceived, or potential conflicts of interest as soon as they arise, and no later than ten (10) business days from becoming aware of the conflict. Disclosures must be made in writing using the Company’s designated Conflict of Interest Disclosure Form.
3.2 Annual Disclosure Statement: All SMEs, contractors, and individuals involved in content development or strategic decision-making must complete an annual Conflict of Interest Disclosure Statement, even if no conflicts exist. Updates must be submitted if circumstances change.
3.3 Examples of Disclosable Interests: Disclosable conflicts include, but are not limited to:
– Employment, consulting, or speaking engagements with competing MPJE prep companies.
– Ownership of intellectual property (e.g., study guides, question banks) that competes with MPJEReview products.
– Financial interests (e.g., stocks, royalties, payments) in companies related to test prep, pharmacy law education, or publishing.
– Membership on a state board of pharmacy or examination committee.
– Family or close personal relationships with individuals in conflicting roles.
3.4 Submission and Review: Disclosures must be submitted to the Compliance Officer (or other designated authority). Each disclosure will be reviewed for materiality and risk, and a determination will be made regarding appropriate next steps, which may include mitigation or recusal.
3.5 Confidentiality of Disclosures: All disclosures will be kept confidential and used solely for the purposes of conflict assessment and resolution, unless otherwise required by law.
4. Conflict Review and Management
4.1 Conflict Review Committee: Disclosed conflicts will be reviewed by a designated Conflict Review Committee composed of MPJEReview leadership or external advisors appointed by CarePath Education, LLC.
4.2 Evaluation Criteria: In determining whether a conflict exists and how it should be handled, the committee will consider:
– The nature and scope of the individual’s role at MPJEReview
– The degree to which the outside interest could influence MPJEReview decisions or content
– The appearance of impropriety or bias to third parties
– The risk to MPJEReview’s reputation and educational integrity
4.3 Management Strategies: If a conflict is confirmed, the Committee may take one or more of the following actions:
– Require the individual to recuse themselves from specific decisions or projects
– Implement independent peer review of affected content or work
– Require divestiture of conflicting financial interests
– Terminate or modify the individual’s involvement in certain activities
– Document and publicly disclose the conflict, where appropriate
4.4 Refusal to Comply: If an Interested Party refuses to disclose a conflict or fails to comply with a management plan, MPJEReview reserves the right to suspend or terminate their involvement with the organization.
5. Monitoring, Enforcement, and Sanctions
5.1 Ongoing Monitoring: MPJEReview will maintain active oversight of conflict of interest disclosures and management plans.
5.2 Reporting Violations: Any individual who suspects a violation of this Policy is encouraged to report it promptly to the Compliance Officer or another designated authority.
5.3 Investigation of Alleged Violations: All credible reports of non-compliance will be investigated promptly and thoroughly.
5.4 Sanctions: If a violation of this Policy is confirmed, MPJEReview may impose appropriate sanctions, which may include:
– Written warning or reprimand
– Removal from content development or advisory roles
– Suspension or termination of contractual or employment relationships
– Public disclosure of the violation, if deemed necessary to preserve trust
5.5 No Retaliation: MPJEReview prohibits retaliation against any individual who makes a good-faith report of a conflict or policy violation.
6. Acknowledgment and Policy Review
6.1 Acknowledgment Requirement: All individuals subject to this Policy must sign a written acknowledgment confirming that they have read, understood, and agreed to comply with the MPJEReview Conflict of Interest Policy.
6.2 Policy Review and Updates: This Policy will be reviewed at least annually by MPJEReview leadership.
6.3 Document Retention: All disclosure forms, acknowledgments, and related documentation will be retained securely for a minimum of five (5) years.