Protect the privacy of your patients and the reputation of your facility.
Training that’s smarter, more effective, and cost efficient.
Automate the COI disclosure and management process.
In January of 2012, I wrote an article titled “5 Reasons Your CFO Should Approve Your Training Budget In 2012”. It’s remarkable how little has changed. Those of you involved with regulatory compliance know that government regulations rarely terminate or remain stagnant. Quite the opposite. Most regulations expand over time and the requirements increase over time.
If you were to suggest the use of a game or gaming elements to provide training to staff, you would probably receive a wide variety of reactions. Some would be thrilled as video games are an integral part of their lives. Others would roll their eyes and feel that you are insulting their intelligence.
Patient safety has always been of primary importance for the delivery of care for any healthcare provider. Despite the focus on patient well-being, landmark studies have identified lapses in various patient safety procedures across the industry. In an attempt to correct these lapses, CMS created several programs that provide a financial incentive for patient safety in healthcare facilities. Programs from CMS either reduce payments to facilities that don’t meet certain thresholds for patient safety or present measurement information to the public to help the public make informed decisions.
In August 2014, an important summit of 50 nurse leaders was held in Baltimore to discuss nursing ethics for the 21st century. The summit was sponsored by the Johns Hopkins School of Nursing and Johns Hopkins Berman Institute of Bioethics.
Time will tell whether increased transparency will change dubious behavior, as designers of the database hope. What has become clear in the short term, however, is that the database is providing an excellent source of information for data mining by government investigators and reporters seeking evidence of connections between payments from industry and questionable actions by providers. It is the publicizing of these connections that will help to raise awareness and increase public pressure for the aforementioned changes in behavior.
The data included remuneration and other exchanges of value from August to December, 2013 from pharmaceutical and medical device companies to physicians, medical schools and other providers. Those with the wherewithal to download and analyze the 150+ megabytes of data posted in seven distinct database files began to provide some analysis within a few days.
In recent weeks, the NFL has been besieged by a number of high profile incidents of players involved in domestic abuse, child abuse and other violent behavior. The chief executives and team leaders of the NFL have come under intense criticism for reacting slowly to the evidence and accusations and for imposing weak and inadequate punishments. The criticism intensified further when the NFL changed its rulings on some issues multiple times and appeared to have no clear roadmap of how to deal with player conduct. Communications from the NFL leadership gave the appearance that they had no understanding of the severity of the issues and that they were completely out of sync with the strong feelings of their fan base and the public on these issues.
Pharmaceutical and Medical Device companies are required to track and report all payments or “transfers of value” to physicians and teaching hospitals that exceed $10.00.
CMS will make available the searchable, public-facing website displaying payment data from pharmaceutical and medical device companies to physicians and teaching hospitals. Despite some glitches in the pre-release website that physicians can use to review and dispute the data, CMS is holding to its planned publication date.
The Physician Payment Sunshine Act requires that all manufacturers of drugs, devices, and biological and medical supplies covered by federal health care programs report all financial relationships with physicians and teaching hospitals to the Centers for Medicare and Medicaid Services (CMS). The goal of the law is to enhance patient safety by increasing the transparency of financial relationships between health care providers and pharmaceutical manufacturers. CMS will then report the information publicly on a website scheduled to be launched on September 30, 2014.
In March of 2001, the Institute of Medicine (IOM) released a landmark report titled, Crossing the Quality Chasm: A New Health System for the 21st Century. The report “makes an urgent call for fundamental change to close the quality gap, recommends a redesign of the American health care system, and provides overarching principles for specific direction for policymakers, health care leaders, clinicians, regulators, purchasers, and others.”
As a healthcare administrator your responsibility is to "do the right thing" and to ensure that your staff acts with integrity at all times. Often, doing the right thing can be difficult and unpopular and you might feel as if you are swimming against the current. This list of famous quotations may help for those times when you need some extra motivation to do the right thing or to remember why it's critically important to maintain integrity! I hope you'll refer to this often.
As public access to this “Physician Payment Sunshine” database gets closer, many hospitals and physicians have started to seriously consider the impact of this data on public perceptions and institutional reputations. There is little doubt that local media outlets will be all over this data when it becomes available in September, looking for payments to physicians that they can portray as excessive and scandalous.
You’ve spent countless hours establishing a high quality effective compliance program within your facility and want to see the result of that effort. However, compliance is difficult to measure. What are some of the signs that indicate that your compliance program is reducing risk?
The companies represented at the conference used their Communication Department to publically promote the ethical values of their organization. These organizations want the world to know that they follow a code of ethics. This includes a willingness to publically communicate failures in meeting the ethical and compliance standards they set for themselves and how they dealt with those failures.
The purpose of gamification is to encourage users to move toward a goal or to increase engagement with a product or service. The term “gamification” is most typically applied to online and mobile applications. Often (but not always) these gaming elements are used in social applications that put users in friendly competition with each other or provide incentives for users to share content with other
As a psychiatrist, Dr. Pies delves more deeply than some into matters of the mind. He quotes ethicist James DuBois as saying: “…an induced COI is said to exist when a researcher knowingly creates situations of financial or other types of dependency that may compromise judgment,” but then points out that “…physicians and other researchers are not always aware of their own COIs, and are truly surprised when an outside observer points it out to them; thus, not all COI is conscious or ‘knowing.’”
In hospitals and academic medical centers, much of the focus on COI is on disclosure and reporting requirements related to the federal government, particularly for reporting to the NIH (for research) and to the IRS (for the form 990). There is, however, another important area where, (to quote Arthur Miller) “attention must be paid!” That is in procurement. Executives and compliance officers have a responsibility to assure that the resources of their institutions are protected, by guarding against conflicts of interest in the procurement process.
On August 1st, Pharmaceutical and Medical Device manufacturers will be required to begin collecting data on payments to physicians and other providers under the “Physician Payment Sunshine” provisions of the Affordable Care Act. Physicians are being urged, by professional societies, the American Hospital Association, the AMA and others to educate themselves on the “Sunshine” provisions so that they can accurately track and, if necessary, correct the payment information that will be reported in public databases in September 2014.
In July, 2008, The Pharmaceutical Research and Manufacturers of America (PhRMA), the trade association and lobbying group for the pharmaceutical industry, updated their Code of Interactions with Healthcare Professionals. This was followed in July, 2009 by an update to the AdvaMed Code, which provides the same function for the Medical Device industry. In both of these documents, the industry went further than ever before in recommending limits on the marketing efforts of their members.
The “Sunshine” provisions were designed to increase transparency in industry’s formal and informal relationships with medical providers. Ever since astute observers noticed that physicians could be influenced by financial considerations (the Stark anti-kickback laws date to the 1980’s) there has been concern that industry largesse could unduly influence research results, prescribing patterns, continuing medical education, and even practice patterns. The thinking is, to paraphrase Justice Brandeis, “Sunshine is the best disinfectant”.