Ready for Conflict of Interest (COI) Management Implementation? 10 Best Practices
June 12, 2017
By Kevin Kovalsky, COI Product Manager, HCCS, A HealthStream Company
Implementing a new software solution to manage conflicts of interest (COI) can be a daunting effort for an organization. The team must be fully prepared and engaged. Here are ten best practices that can help ensure a successful implementation.
- COI management should be a priority for executive leadership: Senior Leadership must understand and take seriously the risks posed by unmanaged conflicts of interest and should communicate that belief throughout the organization.
- Management must be committed: Corporate compliance personnel need to meet with the COI solution provider’s personnel on a regular basis in order to complete the necessary implementation tasks. In our experience, it takes approximately a dozen one-hour meetings.
- Appropriate IT resources brought into the process early: Even though IT involvement may be minimal overall, it is important that IT be involved during the implementation cycle. Whether “white-listing” IP addresses, creating and automating the demographic data extraction process, or setting up single sign-on, IT resources need to be available and engaged to complete these tasks.
- Identify your target population early in the implementation process: Based on the policies of the organization, determine who you want to include in your survey. Will you include Board Members? Executive leadership? Management? Physicians? Other employees? The ability of an organization to quickly identify and classify users will increase the likelihood of a successful implementation.
- Make sure you have accurate data: Knowing the population you want to survey is not enough. Many COI solutions send automated announcement emails to correctly identified users based on their job title/responsibility. You must be able to identify them in an automated fashion. Missing data elements will cause users not to be registered, reviewer assignments to be inaccurate, and reporting to produce incorrect results.
- Develop a communication plan: End-users should not be surprised by a new system or a new and increased focus on managing COIs. Corporate compliance should use newsletters, emails, and other tools to notify users of the new solution and their institutional responsibilities prior to the rollout of the COI solution.
- Conduct beta testing: Beta testing can discover questionnaire anomalies, format and design flaws, and grammatical errors, which if not resolved, can result in embarrassment and lack of confidence in corporate compliance if released to the general audience in the form of a “live” questionnaire.
- Schedule a go-live prep meeting: This is the last opportunity to review the pre-published questionnaire checklist with your Implementation Manager prior to publishing a questionnaire.
- Utilize COI Social Media Platforms, User Forums and Communities: Client administrators can interact with others in the industry and share best practices.
- When available, integrate with other systems: Simplify and automate data extraction. Leverage and integrate with other systems (HR, payroll, or your Learning Management System) to extract demographic data when possible. Note that some COI solution providers also host other systems like Learning Management Systems. Work with your provider to streamline one data process, eliminating duplication.
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