Conflicts of interest are a particularly challenging issue in healthcare. Medical professionals may moonlight at a rival hospital, have an interest in a medical device or real estate a hospital is thinking of acquiring, and, of course, family members who might work at a key vendor.
Steven Melinosky, Regional Director Compliance/Investigations and Policy at Trinity Health of New England, explains in this podcast that managing conflicts of interest is possible, with the right policies and procedures in place.
That begins with recognizing that one policy is likely not enough. The conflicts faced by leadership and the board are likely quite different than those faced by rank-and-file employees. Conflicts for senior leaders and board members likely should be reviewed by the board chair. Those for employees can typically be handled by the compliance team working with frontline managers.
Underlying these efforts must be a culture of compliance from the top down and bottom up. The danger of conflicts of interest must be taught from day one, along with encouragement to report and a clear explanation of the disclosure process. Supervisors need to be trained to identify conflicts, and periodic reminders need to be scheduled.
One tool that can help make conflict of interest management simpler is something he created and calls a “Conflict of Interest Dictionary.” It is a spreadsheet designed to help respond to common conflicts. It contains several columns:
- What the conflict is
- What else needs to be known about it, such as if the individual affected has purchasing authority, is in management and at what level
- Why this issue poses a conflict
- Standardized action plans that lay out expectations for behavior
Having this dictionary helps to ensure consistency in the process and greatly expedites actions since a starting point (and potentially an ending post) is already in place.
Along with this dictionary it’s important to take the time to assess the risk – both likelihood and potential impact – of a conflict and to ensure that the plans put in place are sufficient to mitigate the risk.
He also recommends providing both the affected employee and his or her manager with a written plan which includes the background, the risks and expectations.
Listen in to learn more about how to better manage conflicts of interest and whether a Conflict of Interest Dictionary is right for your program.