Future Of Conflict Of Interest Management

April 1, 2021
April 1, 2021

While healthcare organizations largely are committed to complying with COI Management rules and supporting its goals from the leadership level, there is progress to be made in improving the process. 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 fourth in a series, excerpts our article, “Ten Conclusions about Conflict of Interest (COI) Management in Healthcare,” based on those survey results.

Healthcare Conflicts of Interest Will Continue to Be a Focus

With recent high-level national scandals, healthcare organizations and the industry are taking a renewed interest in the management of COIs. Organizations are either focusing on establishing COI programs or enhancing and optimizing existing programs to align with current and future legislation. Media attention of organizational COI management failures are a great example of how the focus on healthcare COIs is not likely to diminish anytime soon.

The most noteworthy of these scandals, which led to an internal recalibration of the relationship between research healthcare and the pharmaceutical industry, began when The New York Times and ProPublica revealed in September 2018 that the Chief Medical Officer at Memorial Sloan Kettering Cancer Center in New York had failed to disclose his board memberships and substantial financial ties from dozens of authored research articles in various prestigious medical journals. The executive in question resigned from Memorial Sloan Kettering, prompting the chief executive to issue an enterprise-wide statement about standardizing the reporting process with medical journals and professional societies, as well as improving transparency and accountability. It is a widely held expectation that other organizations will re-examine their COI policies and change them accordingly.

Three Suggestions for Improving COI Management

If organizations are going to be successful about managing COI risks, they need to be more proactive in terms of their COI management programs. This requires a change in organizational mindset and culture, such that identification of COIs becomes a shared responsibility. Drawing from their survey responses and knowledge of the industry’s shared challenges, HCCS makes three recommendations for healthcare organizations who want to adapt to the new COI environment: If

  1. Leadership Must Become a COI Champion

    Changing an organization’s mindset and culture surrounding COIs can only truly be successful if fully championed and embodied by leadership. Everyone in the organization needs to understand the justification and value of the continuous effort of collecting data, monitoring disclosures, analyzing results, and enforcing mitigation plans required for an effective and comprehensive COI management program.

  2. Use Systems to Automate COI Management

    Collecting data via the mail and managing COI disclosures via paper creates inefficiency, duplication, inaccuracy, and risk. Manual processes are ripe for breakdowns and mistakes. Using systems that involve software and automation reduces risk and eliminates any appearance of subjectivity.

  3. Take Advantage of the Transparency Inherent to the CMS Open Payments Database
  4. By its very design and existence, the Open Payments Database makes data visible and easily queried. It can be used for comparison and validation purposes against COI disclosure data gathered throughout an organization. Organizations should use data about providers within the organization to promote stronger COI commitment.


    Download the full article here.