Uncovering Healthcare Conflicts of Interest (COIs) May Require Creativity
This blog post excerpts an article written by Bill Sacks, former Vice President of COI Management at HCCS, A HealthStream Company.
To uncover healthcare conflicts of interest that must be addressed, Sacks suggests that compliance officers use standard surveys and questionnaires, supplemented by the Open Payments Database and Google.
One compliance officer indicated that physicians will push back on surveys or questions that they believe are too invasive to their personal lives; but other tools, such as the Open Payments database, and even Google can help a compliance officer gather enough information to identify real or potential problems. Hot lines and a compliance open door policy can uncover departmental gossip and scuttlebutt that may lead to more formal investigations.
Look for Signs of Potential COIs in Surprising Places
Some conflicts are identified in a most unexpected manner. One compliance officer saw one of his institution’s high flying doctors sitting in a courtside seat at a nationally broadcast basketball game, seated next to a known pharmaceutical rep. Subsequent investigation identified unreported gifts totaling thousands of dollars. Another CCO, following departmental rumors, found that the wife of a prominent physician had received a BMW automobile (which was not reported) from a medical device company, in exchange for medical-legal work that the physician had provided in a patent case.
Innocent Until Proven Guilty
Some reported potential conflicts turn out to be no conflict at all. One CCO followed up on a rumor about a condominium in ski country that referring physicians had been invited to use. It turned out that the unit was owned by one physician within a group who had a practice of allowing friends and partners access, with no evident “Stark” or other kickback implications.
Few Reported Payments or Relationships Are Problematic
Sacks offers that most of the interviewed compliance officers reported that only a tiny fraction (1-2%) of reported payments or relationships are found to be highly problematic, requiring significant mitigation. Most potential conflicts are addressed by the disclosure itself or by agreements for additional oversight.
The full article also includes:
- Leadership Can Set the Tone for COI Compliance
- Examples of Conflicts of Interest
- Situations Ranging from Simple to Complex
- Look for Unusual Prescribing Patterns
- Inject Common Sense
Download it here.