This blog post excerpts an article by Bill Sacks MBA, VP, COI Product Management, HCCS - A HealthStream Company, in the Q3 2015 issue of PX Advisor, our quarterly magazine designed to bring you thought leadership and best practices for improving the patient experience.
With the publication in 2014 of the CMS “Open Payments” database, which makes all payments to physicians from Pharmaceutical and Medical Device companies available in a searchable database, conflicts of interest has become a hot-button issue in healthcare.
In fact, those individuals in the healthcare community who are closely involved with compliance and ethics have watched the evolution of the topic over the last four decades from dismissive denial (“How dare you imply I could be influenced by payments from industry!”) to a clear recognition of the potentially insidious influence of industry payments to physicians and hospitals.
Hospitals and other healthcare organizations are compelled to manage their conflicts of interest for several reasons. Their fiduciary responsibility motivates them to ensure that purchasing decisions are not being made based on which vendors (of pacemakers and cardiac stents, for example) give the best gifts. If they are nonprofit organizations, the IRS dictates that they annually complete the Form 990, which requires that steps are taken to manage conflicts of, and between, board members and key employees. If federal funds are received for research or clinical trials, the National Institutes of Health requires the identification and reporting of “Financial Conflicts of Interest” of research investigators.
Medicine and Industry… A Fraught Relationship
The relationship between medicine and industry is and has always been important. It is appropriate, in many cases, for industry to fund research and medical education, and to provide free or subsidized drugs for the indigent. It is essential, however that such funding does not influence the outcomes of research, the techniques being taught, the specific treatments received by patients or the drugs being commonly prescribed. Such potential conflicts of interest must be managed.
The management of conflicts of interest involves annual (or more frequent) surveys to solicit financial disclosures from employees, physicians, and researchers. These disclosures are then evaluated by appropriate reviewers to determine whether real or perceived conflicts of interest exist. When such conflicts are identified, management plans are devised to mitigate or eliminate the conflicts. Historically this entire process was conducted on paper.
In 2009, several Academic Medical Center (AMC) clients approached HCCS, now a HealthStream company, to automate the cumbersome, manual, and labor intensive process of managing conflicts of interest. They complained that they were spending all of their time and effort chasing paper and not enough managing conflicts. With the AMCs contributing their intellectual capital, HCCS agreed. The result of their combined effort, the cloud-based COI-SMART, was introduced in 2010.