While healthcare organizations largely are committed to complying with COI Management rules, there is not consensus about how to go about it or to whom it applies. To evaluate how healthcare organizations are managing their efforts to reduce COIs, HCCS—A HealthStream Company surveyed 281 U.S. healthcare compliance leaders about their compliance programs, to discover how COIs are being monitored, identify common deficits among them, and uncover potential enhancements. This blog post, the third in a series, excerpts our article, “Ten Conclusions about Conflict Of Interest (COI) Management in Healthcare,” based on those survey results.
4. COI Data Collection Methods
The collection of COI data is similarly fragmented among multiple communication options. 38.4% of those surveyed collect COI data by email, with cloud-based systems (31.8%) and mail (22.2%) coming second and third as options. More than half of respondents indicated that the chance for duplication and overlap in their systems is “low” or “very low.”
5. How Often to Collect COI data
There is not a consistent standard for the cadence and duration of COI data collection—many organizations use the calendar year as a rough determinant for the length of a regular COI process. 35.3% rely on an annual COI process, while only 6.3% use a permission-based, or transactional process for COI management. Interestingly, 42.1% employ a mixture of the two. Most respondents designated January or December as the time when their programs end. There was no clear trend in the length of time a COI process lasted, with survey responses indicating anywhere from less than a month to six months or more.
6. What Employees Are Subject to COI Management
Most organizations include senior level management, employed physicians, and board members in the COI process. Other employees are less likely to be included. A large majority of those surveyed include the leadership of the organization in the COI management process. 73.0% include board members, 78.7% include employed physicians, and 87.1% target senior level management at the director level and above. A lesser but still significant number include purchasing (35.4%, supply chain management (34.8%), researchers/investigators (30.9%), and non-employed physicians (29.2%). Interestingly, 81.1% of compliance leaders send COI questionnaires to fewer than 15,000 participants.
Other conclusions drawn in this study concern:
- Organization Commitment to COI
- Leadership of COI Management
- COI Tracking Systems
- COI disclosure reviews
- Leadership and COI
- Improving COI management
- CMS Open Payments Database
Download the full article here.