Corporate Compliance

Tip: Protect yourself from inducements

Compliance Monitor, May 5, 2004

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It's common knowledge that the government believes all medical decisions should be made in the patient's best interest, not for the provider's financial interest. To protect yourself from being scrutinized for having relationships that could pose a conflict of interest, Bret Bissey, chief compliance and privacy officer at Deborah Heart and Lung Center in Browns Mills, NJ, has some advice:

Examine your conflict of interest policies. Do they include provisions to

  • establish thresholds regarding what are acceptable relationships and behavior
  • establish specific limits for goods and services
  • provide examples of conflicts
  • require disclosure of anything above a certain financial limit
  • outline consequences of failure to disclose
  • consider incorporating standards into your medical staff bylaws
  • establish a review and action plan upon disclosure

    Look at your conflict of interest disclosure policies. Are there stipulations for

  • a written document that must be completed and certified even if there is no disclosure
  • new employees completing the conflict of interest disclosure upon hire so that you know of any issues at that time, instead of when the annual process occurs
  • updates required for new requirements or changes
  • confidentiality when handling documents
  • relationships which may be potentially problematic

    When it comes to education, audits, and monitoring, your responsibilities are to

  • constantly remind your colleagues about the threat, but be creative about how you tell the story
  • structure audits with certain vendors, especially if you have vendors that have a major part of your business
  • make sure contracts with vendors include clauses that they must notify you of any relationships with your employees that might affect this relationship
  • monitor communication, including emails, if you have suspicion and make sure your policy allows surveillance if necessary

    Editor's note: Bissey spoke at the Health Care Compliance Association's annual meeting April 26.



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