Conflict of Interest Policy

Purpose and Scope

The purpose of this policy is to establish a framework for identifying and providing guidance to manage conflicts of interest that may impact actions, decisions, and transactions of the American Society of Transplantation (AST). This policy is designed to foster member and public confidence in the AST’s integrity and credibility, allowing collaborations that are important to the mission of the AST to be pursued while protecting the AST’s interest when actions might benefit the personal interests of those in decision-making roles.

This policy governs conflicts of interest between individuals serving the AST in leadership, volunteer, and educational capacities. All relevant financial, fiduciary, or other relationships with professional and patient organizations, academia, government agencies, companies, and other entities with financial or strategic interests in organ transplantation or donation must be disclosed for the Covered Individual and their spouse/domestic partner, as defined in the policy.

Definitions

• Conflict of Interest Committee: A standing committee charged with applying the COI policy, providing guidance on management of conflict of interest, and recommending modifications to the policy
• Committee: A group of AST members appointed by the President with a common objective.
• Community of Practice: A group of self-selected AST members with a common interest, which has been formalized by the AST Board of Directors.
• Advisory Council: A special interest group of self-selected AST members which has been formalized by the AST Board.
• Task force: A group formed by the AST Board to analyze or solve a specific problem.
• Work group: A work group is a subgroup organized for a specific purpose by the AST Board or a COP’s Executive Committee, such as membership, education, public policy, online community, etc.
• Company: A for-profit entity that develops, produces, markets, or distributes drugs, devices, services or therapies used to diagnose, treat, monitor, manage, and alleviate health conditions, or a for-profit entity that provides fee-based consultation services to healthcare entities that deliver transplantation clinical services to patients[1]
   

Policy Statement

In pursuit of its mission to advance the field of transplantation and enhance patient care, the AST engages in thoughtful, strategic, and complex partnerships with professional and patient organizations, academia, government agencies, companies, and others. These collaborative partnerships must not create conflicts of interest that compromise the integrity or credibility of the AST or its mission. 

The AST offers opportunities for individuals with a diverse range of expertise and backgrounds to serve its mission. These individuals will, from time to time, have financial, fiduciary, or other relationships with entities that have financial or strategic interests in actions or transactions undertaken by the AST. The AST respects the autonomy of its members and volunteers to pursue and hold diverse relationships with professional and patient organizations, academia, government agencies, companies, and others, and the presence of these relationships often will not prevent service. The AST requires individuals to manage any potential or perceived conflicts of interest in a manner that ensures they can act in the best interests of the AST.  In instances where a conflict of interest cannot be reasonably managed, the individual is not recommended for service. 

Statement of Confidentiality

While serving the AST, individuals may have access to information that is confidential or proprietary. This information includes financial information, business plans, policy proposals and recommendations, policy development plans, confidential membership plans, and other information that could impede the implementation of AST activities if it were disclosed. A Covered Individual shall maintain the confidentiality of such information and shall not disclose confidential or proprietary information for personal gain.

Covered Individuals

Covered Individuals are those serving the AST in the capacities below, and the Covered Individual’s spouse/domestic partner.

1. Individuals providing service to the AST in leadership capacities, including but not limited to:
   1. Executive staff
   2. Board of Directors
   3. Governance committee members
   4. Financial committee members
   5. Conflict of Interest Committee members
   6. Board of Directors nominees
2. Individuals providing service to the AST in other volunteer capacities, including but not limited to:
   1. Committee, task force, advisory council, and Community of Practice chairs, co-chairs, and members
3. Individuals providing service in educational capacities, including but not limited to:
   1. Speakers, moderators, and discussants
   2. Authors of educational materials produced by the AST

Conflict of Interest

A conflict of interest emerges when a set of circumstances creates a risk, real or perceived, that an individual’s professional judgment or actions regarding the AST may be unduly influenced by their external financial, fiduciary, or other interest; or use of confidential or proprietary information of the AST could be used for personal gain.[2] 

Relevant disclosures include those financial, fiduciary, and other relationships that are:

1. Active and ongoing
2. Inactive but which existed in the 12 months prior; and
3. Under negotiation, and contractual terms can reasonably be expected to be executed within 3 months

The following must be disclosed for the Covered Individual and their spouse/domestic partner:

1. Financial relationships: Those relationships in which the Covered Individual receives or expects to receive renumeration through activities including, but not limited to, employment, management positions, independent contractor (including contracted research), consulting, speaking and teaching, membership on advisory committees or review panels, board membership, and other such activities. Renumeration may be in the form of:
   1. salary
   2. royalty
   3. intellectual property rights
   4. consulting fees
   5. independent contractor fees
   6. stipends or honoraria, including travel to non-academic institutions
   7. stocks, stock options or other ownership interest, excluding diversified mutual funds
   8. research, training, or unrestricted educational or philanthropic funds
   9. other personal financial benefit
2. Fiduciary relationships: Those relationships in which the Covered Individual plays a major leadership role in the strategic direction and/or financial oversight of a non-profit organization, company, or healthcare entity, even when such a role occurs in a volunteer capacity. Typically, these roles include, but are not limited to, director, council member, officer, and trustee.
3. Other relationships: Other relationships are those relationships in which the Covered Individual has a leadership role in an entity that may compete with the AST, either financially or in mission. Typically, these roles include, but are not limited to, editor of a non-AST journal that publishes in the field of transplantation or donation, and chair of a committee or task force in another patient or professional organization whose mission includes organ transplantation or donation.

Conflict Assessment and Management

The AST strives to offer guidance on assessing conflicts of interest but recognizes that such conflicts are inherently complex and dependent on specific facts and circumstances. The guidance provided below is not intended to cover every possible scenario, but rather to offer practical and reasonable recommendations for handling conflicts of interest. Every effort should be made to apply this policy and its recommendations fairly, impartially, and consistently to all Covered Individuals.

 As the field of organ transplantation and donation is dynamic and continuously evolving, there may be instances where certain affiliations previously permitted or prohibited will be reconsidered. The AST Board of Directors resolves the right to not permit certain affiliations, as determined by the current degree of controversy or public scrutiny, which can change over time. The AST Board also reserves the right to permit certain affiliations for initiatives requiring specific expertise, provided the conflicts are fully disclosed and appropriately managed.

All Covered Individuals in AST are prohibited from the following:

1. Employment income or salary from a company with financial interests in organ transplantation or donation
2. Ownership, partnership, or principal (e.g., CEO, chair of the Board) in a company with financial interests in organ transplantation or donation

Certain positions, including leadership positions as described above, are subject to more stringent conflict of interest standards due to the nature of responsibilities, influence, and potential impact of any conflicts. In addition to (a) and (b) above, Covered Individuals in AST leadership positions are prohibited from the following:

1. Paid or unpaid fiduciary relationship (i.e., Board of Directors member or its equivalent) with a patient or professional organization whose mission includes organ transplantation or donation
2. Simultaneous service as a member of the AST Board of Directors and as Editor-in-Chief of a journal in the field of organ donation or transplantation

For all Covered Individuals, there will be conflicts for which disclosure alone is insufficient, but the relationship is not prohibited and can be managed. This includes, but is not limited to:

1. Leadership positions (e.g., Committee Chair or Chair-Elect/Vice Chair) within a patient or professional organization whose mission includes organ transplantation or donation
2. Receiving $25,000 or more in the past 12 months from a company with financial interests in organ transplantation or donation in (a) non-salary compensation (e.g., consulting fees, independent contractor fees, etc.) and/or (b) equity interest
3. Intellectual Property Rights (patents, royalties, licensing fees) related to organ transplantation or donation with income in the past 12 months of $25,000 or more
4. Stock or stock options in a company with financial interests in organ transplantation or donation with a value of $25,000 or more (not part of a diversified fund)
5. Editor-in Chief of a non-AST journal in the field of organ transplantation or donation

For non-prohibited relationships, management for Covered Individuals includes, but is not limited to:

1. Required recusal during discussion and voting on matters pertinent to the relevant relationship if the Covered Individual received $25,000 or more in the past 12 months from a company with financial interests in organ transplantation or donation in non-salary compensation and/or equity interest, unless the funds are routed to the Covered Individual’s institution
2. Potential recusal from discussion, voting, or both on matters pertinent to all other relevant relationships. This is determined by vote of attendees, as there may be times when the knowledge and expertise from external relationships is beneficial to the discussion and further limiting participation would diminish the opportunity for a fully informed discourse
3. Ensuring at educational events that disclosures are accessible to attendees and verification that the content presented is unbiased and does not mention external entities, their products, or services.

Note on Spouses/Domestic Partners

Conflicts of interest may also extend to the spouse/partner if such relationships would otherwise be prohibited for the Covered Individual. The spouse/partner presumption may be overcome when, as reviewed by the appropriate AST parties, the Covered Individual has presented demonstrable, compelling justification for being permitted to simultaneously hold an AST leadership position while the spouse/partner has a substantial conflict.

 Responsibilities

1. Covered Individual
   1. Covered Individuals, prior to engaging in an official capacity with the AST, and at least once a year thereafter as their service continues, will submit their disclosures to the AST
   2. Covered Individuals must disclose any new or modified relationships within 30 days of the effective date or modification of the relationship
   3. Covered Individuals must provide upon request by AST Staff, the COI Committee, or the AST Board of Directors, additional information to assist in determining the eligibility of the relationship. Should the Covered Individual not provide the requested information, the Covered Individual will no longer be able to serve.
   4. Covered Individuals participating in an AST meeting must review reported disclosures as the first agenda item and verbally announce any actual, potential, or perceived conflicts. Inaccuracies or modifications should additionally be announced and captured in meeting minutes and formally reported after
   5. Covered Individuals with identified manageable conflicts should manage according to the guidelines and recommendations set forth in this policy, or other recommendations as set forth by the Conflict of Interest Committee and/or AST Board of Directors
   6. Covered Individuals who speak, present, or moderate at an AST educational event must verbally disclose any relevant relationships related to their presentation. Additionally, they must have written documentation (slide, listing in program, etc.) presenting relevant relationships
   7. Covered Individuals in authoring an AST-produced educational product should, at the start of the product, identify potential conflicts of interest and determine bias mitigation procedures. Disclosures will be submitted for formal review when the product is ready for formal review
2. AST Staff
   1. AST staff members shall initially review disclosures for non-leadership volunteers to determine whether a relationship requires management or is prohibited.
   2. Management recommendations and guidance will be communicated to the Covered Individual.
   3. If AST staff cannot make an immediate determination or there is a prohibited relationship present, the disclosure will be submitted to the COI Committee for secondary assessment.
3. COI Committee
   1. The COI Committee shall review all disclosures for leadership to determine whether a relationship requires management or is prohibited.
   2. The COI Committee shall review additional disclosures submitted by AST staff for secondary assessment.
   3. The COI Committee shall refer to the AST Board of Directors for final determination of any prohibited relationship.
4. Board of Directors
   1. The Board of Directors shall formalize any decisions presented by the AST Conflict of Interest Committee.
   2. The Board of Directors will review the Conflict of Interest Committee’s disclosures.
5. CME Vendors
   1. For educational events in which CME is offered, the CME provider will review disclosures and slide presentations for bias in advance of the educational event.

Note on Joint Activities

Covered Individuals may represent the AST at joint activities involving one or more other organizations that have differing COI policies. Covered individuals are expected to adhere to the COI standards set forth by the collaborating entity, and as such, implementation and enforcement of this COI policy may be modified.

Compliance

Violations

A Covered Individual must adhere to all aspects of the COI Policy. If any member of AST Staff, committee, or Board has reasonable cause to believe that a Covered Individual failed to disclose actual or possible conflicts of interest, failed to make disclosures within the time specified by policy, or failed to adhere to conflict management strategies, the Covered Individual must be informed of the basis for such belief and afford them an opportunity to explain the alleged failure to disclose, untimely disclosure, or management plan nonadherence.

The appropriate party determines if the Covered Individual is in violation of the COI Policy after hearing the Covered Individual’s response and any warranted investigation. Corrective action for such may include delay in assuming official capacity with the AST, suspension of official capacity with the AST, disqualification from serving in an official capacity with the AST, suspension from participating as a speaker at future AST education events, or revocation of membership in the organization.

Disputes

If a dispute arises between a Covered Individual and the AST on matters related to COI determination or management, the President will appoint an Ad Hoc Adjudication Committee. This ad hoc committee should comprise no more than three Members, which may include a Past-President, a Past-Chair or former member of the COI Committee, and/or a former Board member. The ad hoc committee will review and assess the matter for the purpose of advising the Board of Directors Executive Committee, which will determine the final resolution.

Public Disclosures

The AST respects the privacy of personal information, including the monetary value of relevant disclosures. The AST will make available to Members and to the public via its website this COI Policy and make available, upon request, any relevant disclosures.  The AST believes that relevant disclosures from Covered Individuals should be accessible to all Members and participants at AST educational events.

Policy Revisions

The COI Policy shall be subject to appropriate modifications when appropriate, but no less frequently than every three years, to conform to emerging organizational standards and to remedy unintended omissions or consequences.

Code for Interactions with Companies

The AST endorses the Council of Medical Specialty Societies’ Code for Interactions with Companies (www.cmss.org), which describes guidelines to minimize conflicts of interest and achieving the highest ethical standards in interactions with commercial entities. The AST Board considers the Code a procedural appendix to the COI Policy.

Dates

Adopted First – February 15, 2001 

Revised – July 19, 2008 

Revised – March 10, 2010 

Revised – July 23, 2010 

Revised – December 1, 2011 

Revised – January 15, 2013 

Revised – July 26, 2013 

Revised – August 19, 2014 

Revised – November 18, 2014 

Revised – September 23, 2019 

Revised – April 21, 2021

Revised – June 2, 2022

Revised – September 7, 2023

Revised – June 18, 2025

[1]See Accreditation Council for Continuing Medical Education (ACCME; Standards for Integrity and Independence in Accredited Continuing Education) and Council of Medical Specialty Societies (CMSS; Code for Interactions with Companies). 

[2]Institute of Medicine. 2009. Conflict of Interest in Medical Research, Education, and Practice. Washington, DC: The National Academies Press.