This blog post is taken from remarks by Bill Sacks, Vice President, COI Management, HCCS – a HealthStream Company during a recent Webinar featuring Bill Sacks and Alan Beer, Senior Systems Engineer, Corporate Compliance, Carolinas HealthCare System
Thirty years ago, if I had suggested to my faculty that their medical decisions could be influenced by money, they would have been outraged. The attitude then was “How dare you suggest that I am a crook?” They absolutely believed conflicts of interest were not an issue.
Evolution of Thought
In the 1990’s, we began to see data showing money could affect provider behavior. For example, data showed that when doctors had an interest in an ancillary facility, their referrals to that facility skyrocketed. This led to the Stark laws and anti-kickback regulations. In 1995, the NIH recommended that providers have a process in place to manage conflicts of interest.
By the early 2000’s, research was showing that even small gifts, like pens and mugs, could influence the behavior of the recipients. Several scandalous stories appeared on the front page of the New York Times, and by 2010, these stories were appearing every week.
Open Payments Database
With the passage of the Affordable Care Act came the publication by CMS of the open payments database. The federal open payments program collects information from drug and device companies about payments made to physicians and teaching hospitals for things like travel, research, gifts, speaking fees, and meals. It also includes ownership interests that physicians or their immediate family members have in these companies.
First released in 2014, and then annually published around June 30 each year, the database includes every payment over $10 made by pharmaceutical companies and medical device companies to any physician or teaching hospital in the country. Every year, when the data are published, the site receives significant attention from the national press, and as time goes by, articles show up in the local press as well.
The Risk of Failure to Monitor COI Effectively
Failing to manage physician conflicts of interest can jeopardize your organization’s financial health, tax-exempt status, and reputation. If you regularly acquire pharmaceuticals or medical devices, employ or provide a practice location for physicians, conduct federally funded research, or are non-profit, you should monitor the open payments database. If you identify potential conflicts of interest, you must take steps to mitigate them.
From a public relations standpoint, it’s important that administrators are prepared to answer questions from a skeptical public. Administrators should be know which of their physicians have received payments, who made the payments, and whether the payments are in line with institutional policies. Different organizations have different rules regarding outside income, and some payments may be completely appropriate. However, organizations should know about money paid to your physicians and the source of those dollars.
Efficient Monitoring and Big Data
If you have a large number of physicians, monitoring the massive open payments database is quite a challenge. To avoid a time-consuming and labor-intensive process, you can turn to big data to facilitate the process. Data tools such as Microsoft SQL Server and Microsoft Access make it easy to work with multiple large data bases to isolate data about your affiliated physicians.
For example, while CMS is prohibited from including a physician’s NPI in the open payments database, they can include physician names and addresses. The NPI database also includes names and addresses, so you can use data tools to query the databases and run hospital-specific and physician-level reports. By harnessing big data, you will be well-prepared to respond to any media inquiries.
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