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Learn MoreThis blog post is based on the article, Where We Stand with Healthcare Conflict of Interest (COI) Compliance, written by Bill Sacks, former Vice President of COI Management at HCCS, A HealthStream Company.
A conflict of interest in healthcare can range from the most simple and obvious to extraordinarily complex, as the few examples below can demonstrate. One healthcare meeting planner was found to be regularly sending business to a restaurant owned by her husband while neglecting to disclose the relationship as required. In another case, a department manager hired her husband, who was subsequently paid significant overtime, all while maintaining a full time job outside the university. In a particularly egregious example, a salaried Chief Compliance Officer (CCO) contracted with an outside firm—where she was the only employee—to provide compliance services normally provided by the CCO. These were clear conflicts, some of which amounted to outright fraud.
Other COI situations can be far more complex. One former CCO recounted the story of a clinical staff member who developed a software solution, retaining ownership with leadership approval. Under that arrangement no royalty payments were received from the healthcare institution. Shortly thereafter, the product was picked up by a third-party distributor, resulting in a “spider web” of ownership, financial, and management issues that needed to be untangled.
While some providers demonstrate total commitment to disclosure and seek to avoid even an appearance of conflict (an example being “I think I accidentally accepted a sandwich from Merck!”), others will “forget” or claim ignorance of disclosure requirements. In those cases, compliance officers can employ various tools to assess the accuracy of disclosures. The open payments database may be the most well-known resource, but savvy compliance officers will periodically Google the names of their most prominent physicians to identify relationships from press releases, conference agendas, etc.
A scandal involving a conflict of interest in healthcare can be significant and damaging. In the case of Memorial Sloan Kettering Cancer Center in New York, The New York Times and ProPublica revealed in September 2018 that its medical director failed to disclose substantial financial ties and corporate pharmaceutical backing related to medical conference appearances and scientific journal publications. The lack of disclosure was questionable, given that co-authors disclosed connected financial interests when applicable. The director ended up resigning, and the scandal widened to touch other executives at the organization and elsewhere in academic and research medicine. As a result of this scandal, Memorial Sloan Kettering announced a large-scale change in policy. Other similar organizations are examining their own policies and are expected to follow suit, both to protect public perceptions and mollify employee morale.
Perhaps it is long overdue for leading healthcare institutions to admit that when doctors enter into financial relationships with companies, the concern is that these ties can shape the way studies are designed and medications are prescribed to patients, potentially allowing bias to influence medical practice. Stronger policies are a way to reestablish the link to education and research, and away from industry influence.
Sacks offers the following advice for Improving COI Compliance:
Remember that only a small percentage of financial relationships and reported payments are problematic. Sacks offers that “ Most potential conflicts are addressed by the disclosure itself or by agreements for additional oversight.”
As stated earlier, well defined policies and procedures can provide a template for improved understanding and compliance with conflict of interest policies. Even the best designed policies and rules cannot anticipate every possible situation. One compliance officer from horse country recounted a conversation with one of her physicians, who complained that there was no specific rule prohibiting the action he had been called to task on. She told him: “There is no rule that says not to bring your horse to work, but… DON’T bring your horse to work!”
This article also includes:
Download our article: Where We Stand with Healthcare Conflict of Interest (COI) Compliance.
HealthStream provides online healthcare compliance solutions to help health systems, facilities, and organizations across the care continuum comply with government regulations and accrediting body requirements. COI-SMART™ provides comprehensive tools for tracking and managing Conflicts of Interest (COI) disclosures.
HealthStream’s learning management system and comprehensive suite of competency management tools empower your healthcare workforce to deliver the best patient care.
View All Learning & PerformanceHealthStream offers performance learning management solutions to help develop your healthcare staff into leaders and reduce turnover.
View All ProductsHealthStream works with healthcare organizations to create engaging and high-quality training videos for your staff and management.
View All ProductsImprove care quality and save money by making informed decisions about your healthcare facility and staff with HealthStream's reporting analytics solution.
View All ProductsHealthStream's proven methods for the improvement and overall engagement of your healthcare staff foster a positive workplace and increase retention rates.
View All ProductsThe leadership development program from HealthStream helps mold your high-potential healthcare employees into proven leaders.
View All ProductsWhen you enact HealthStream's quality compliance solutions, you can do so with the confidence your healthcare organization will meet all standards of care.
View All Quality & ComplianceFulfill compliance requirements with a variety of programs and courseware designed to address critical regulatory requirements as well as educate staff to recognize and mitigate risks.
View All ProductsBy increasing your healthcare staff's focus on quality and safety with HealthStream, they can help to reduce medical errors and readmission rates.
View All ProductsLearn about what HealthStream's healthcare policy management software and how it can help aid your organization efforts.
View All ProductsHealthStream's education helps address diversity, equity, and inclusion within your organization, as well as promoting health equity in the communities you serve.
View All ProductsHealthStream offers professional training and education on how to best optimize your reimbursement process within your healthcare organization.
View All ReimbursementTeach your healthcare staff about the revenue cycle and claim management through targeted training and video tools from HealthStream.
View All ProductsLearn about our advanced resuscitation training solutions. Our solutions are designed to help improve patient outcomes.
View All ResuscitationIn all areas of resuscitation, from neonatal to elderly care, clinical deterioration is a risk that can be avoided with the help of HealthStream's training programs.
View All ProductsHealthStream's EMS Program offers a comprehensive, CAPCE accredited EMS course library that meets National Registry annual recertification.
View All ProductsNurture the skills of your nurses and medical staff to help mold them into effective leaders with development training from HealthStream.
View All ProductsExpand the decision-making skills and effectiveness of your healthcare workforce with HealthStream's clinical development programs and services.
View All Clinical DevelopmentMake sure your clinicians have the support they need to provide competent care with clinical competency training and development from HealthStream.
View All ProductsHealthStream’s learning management system and comprehensive suite of competency management tools empower your healthcare workforce to deliver the best patient care.
View All ProductsThe suite of healthcare onboarding solutions available from HealthStream aids in nurse retention and improved patient outcomes.
View All ProductsGive your healthcare staff the decision support and skills training they need with the online products available from HealthStream.
View All ProductsHealthStream leverages medical professional development in healthcare by providing staff training programs
View All ProductsLearn more about HealthStream's Provider Credentialing, privileging, & enrollment solutions.
View All CredentialingExperience standardized and centralized healthcare credentialing, privileging, and enrollment that is smarter and faster than ever before.
View All ProductsAutomated, web-based provider credentialing and enrollment software for growing medical groups.
View All ProductsNCQA-certified CVO verification services for initial and re-credentialing files in an overflow or full-service capacity for healthcare organizations.
View All ProductsSearch, review, and add providers into the Epic provider master file with our Epic app integration, Provider Validate.
View All ProductsMake sure your healthcare staff can schedule out appointments and work schedules with ease using HealthStream's line of software solutions.
View All SchedulingHealthcare scheduling software designed to optimize staffing requirements & elevate patient care
View All ProductsPrecisely align staffing and needed resources to enable efficient patient flow and high-quality, cost-effective patient care.
View All ProductsHealthStream’s free nurse schedule app, NurseGrid™, is built to help you care for your staff and engage with their specific needs.
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