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Conflict of Interest Compliance

Where We Stand with Healthcare Conflict of Interest (COI) Compliance

This blog post excerpts an article written by Bill Sacks, former Vice President of COI Management at HCCS, A HealthStream Company.

With the Trump administration considering changes to rules governing kickbacks and other conflicts of interest (Pear, 2018), I thought it would be interesting to revisit the topic and to take stock of the current state of affairs.

I recently had conversations with several compliance officers who have had distinguished careers at academic medical centers and health systems from coast to coast, including the states of Washington, California, Texas, Kentucky and Tennessee. My objective was to find common themes in their efforts to identify and manage real and perceived conflicts of interest at their institutions and to articulate key lessons learned.

Leadership Can Set the Tone for COI Compliance

Each of these Compliance Officers stressed that the tone from the top of the organization, (usually the Dean or Chief Medical Officer) was one of the most, if not the most important determining factor in how seriously conflicts of interest were taken at an institution. Where conflicts are taken seriously they are sought out and dealt with appropriately. Where they are not taken seriously, they tend to go unidentified or unresolved. When support from the very top does not exist, COI compliance becomes inconsistent, with some departments excelling and others falling behind.

Even with high level support, the degree to which conflicts are taken seriously can depend on how evolved or mature a compliance program is. A new compliance officer may find that senior administration, physicians, and other medical staff have never been educated in the insidious nature of some conflicts of interests and have never had specific policies in place to address them. In that case it is important that fair and reasonable policies are developed, in collaboration with the professional staff.

The full article includes:

  • Use Surveys and Questionnaires, Supplemented by the Open Payments Database and Google
  • Few Reported Payments or Relationships Are Problematic
  • Examples of Conflicts of Interest
  • Situations Ranging from Simple to Complex
  • Look for Unusual Prescribing Patterns
  • Inject Common Sense

Download it here.