Ten Conclusions about Conflict Of Interest (COI) Management in Healthcare: Article

April 1, 2021
April 1, 2021

Methodologies to Manage Conflicts of Interest (COIs) vary widely across healthcare organizations. When COI management and compliance programs are effective and comprehensive, their success often can be attributed to the commitment of an organization’s leadership. Many organizations prioritize the management of COIs; however, many are still behind the curve even with a renewed industry emphasis of identifying and preventing COIs.

To evaluate how healthcare organizations are managing their efforts to reduce COIs, HCCS—A HealthStream Company surveyed 281 U.S. healthcare compliance leaders about their compliance programs, to discover how COIs are being monitored, identify common deficits among them, and uncover potential enhancements. This blog post, the first in a series,  excerpts our article, “Ten Conclusions about Conflict Of Interest (COI) Management in Healthcare,” based on those survey results.

What Is a Conflict of Interest in Healthcare?

At the most basic level, a conflict of interest exists when a person is in a position to derive personal benefit from actions or decisions made in his or her official capacity. A healthcare conflict of interest has a disastrous impact on the impartiality we all expect when it comes to healthcare. When revealed, a COI can make us question the care and judgment of our clinician. Nothing should come between the care decision made by a provider and the best interests of a patient. Some examples of healthcare COIs might be an executive who chooses a vendor based on gifts received or a physician prescribing medication based solely on financial arrangement with the pharmaceutical company that manufactured the drug. 

What Government Measures Reveal the Increased Efforts to Prevent COIs? Over recent decades, the U.S. Government has demonstrated their intention to prevent conflicts of interest to an extent that has not been seen before. Efforts to identify and prevent COIs have grown across multiple governmental measures applicable to healthcare and designed to make it harder to hide improper financial and influential relationships. Some of these measures include:

  • Anti-Kickback Statutes - prohibit offering, paying, soliciting, or receiving anything of value to induce or reward referrals.
  • Stark Laws - curb physician referrals to entities in which they have a financial relationship.
  • Physician Payments Sunshine Act (part of the Affordable Care Act) - requires healthcare manufacturers to report physician and teaching hospital payments in excess of $10.
  • IRS Form 990 - increases visibility into non-profit organizations and tax-exempt status.
  • CMS Open Payments Database - database containing payments made to physicians and teaching hospitals by drug and medical device companies required under the Physician Payments Sunshine Act.

Download the full article here.