Practice Management Alert

Question: My practice is involved in a variety of business ventures. I am working with the compliance officer to develop policies and procedures for disclosing possible conflicts of interest by individuals within this practice. Where should I begin?

Oregon Subscriber

Answer: Because so many physicians have a variety of business interests, this issue comes up often, and your practice should know where to turn when it comes to disclosure of these issues.

First, make sure there is a conflict-of-interest policy in effect and include it in your compliance manual, e.g., “It is this company’s policy that employees shall avoid both real and perceived conflicts of interest. Any questions concerning conflicts of interest must be immediately addressed with the appropriate supervisors or the designated compliance officer.”

Second, set up a conflict-of-interest procedure that includes a financial disclosure statement, which lists all the employee’s business-related financial information (e.g., stock ownership in pharmaceutical companies, partnerships, commercial real estate, etc.).

Develop a conflict-of-interest disclosure statement that is signed by each employee. The statement must say that the employees have read and understood the company’s conflict-of-interest policy and will abide by it. The procedure should also include the requirements for an annual review and re-signing.

The importance of a conflict-of-interest policy cannot be understated. Senior management must promote strong personal integrity and set such an example, because a standpoint must be developed that it is every employee’s responsibility and obligation to protect the organization they work for.