Download Disclosure of Financial Interest

Disclosure of Financial
Interest Policy
Disclosure of Financial Interest Policy
• Medical Staff Policy Approved by the MEC’s
• Aimed at protecting the integrity of the LMHS
Medical Staffs
• Requires disclosure of certain financial interests
at the time of appointment, reappointment and
throughout appointment cycle
• Promotes transparency, does not prohibit legally
compliant payments or ownership interests
• Prompted by the Physician Payment Sunshine Act
Physician Payment Sunshine Act
• Part of the Patient Protection and Affordable Care
Act
• Final Rule released by the Centers for Medicare &
Medicaid Services in February 2013
• Purpose is to prevent fraud, abuse and waste in
the health care system
• Aims to increase transparency of financial
relationships between the drug and device
industries, healthcare providers and patients
• Now referred to as Open Payment Program
Physician Payment Sunshine Act
• Requires drug, device, biological and medical
supply manufacturers and distributors to report,
in significant detail, payments made to physicians
and other medical institutions to the Federal
Government on an annual basis
• Affected manufacturers and distributors
(including group purchasing organizations (GPOs))
must also report certain ownership or investment
interests held by physicians and their immediate
family members
Physician Payment Sunshine Act
• List of reportable payments is very broad
– Includes consulting fees, honoraria, food,
beverage, entertainment, travel, and education
• Data collection will start August 2013
• Must be reported to CMS by March 31, 2014
and annually thereafter
• The reported information will be posted on a
public website starting in September 2014
Disclosure of Financial Interest Policy
• Applies to Medical Staff Members & Allied
Health Practitioners-applicants & current
• Completed Disclosure of Financial Interest
Questionnaire sent to Medical Staff Services
• Failure to disclose/non-compliance
– Initially handled by Medical Staff Services
– 15 days to comply (optional additional 15 by MS
President)
– Referred to MEC
Disclosure of Financial Interest Policy
• Financial Interests are defined as Payment(s) or
Transfer(s) of Value from a Drug, Device, Biological or
Medical Supply Vendor, Manufacturer or Supplier to
the Medical Staff Member that are:
– $500.00 per payment/transfer or $1500/total for reporting
period, which is defined as (1) the twelve month period
prior to the initial disclosure or (2) the time period
between disclosures (i.e. reappointment period)
• Or an Ownership or Investment interest held by the
Medical Staff Member or Immediate Family Member in
such a Vendor, Manufacturer or Supplier
• Limited exceptions to disclosure for post-purchase
training programs approved on a case-by-case basis by
the Medical Staff Office and Compliance Department
Disclosure of Financial Interest Policy
• Medical Staff Members that have a Financial Interest
may provide input into Purchasing Decisions, but
may not make Purchasing Decisions that may be
influenced by their Financial Interest(s)
• A Purchasing Decision is the decision as to which
Vendors, Manufacturers, or Suppliers are chosen for
the purchase, lease, use, or acquisition of Drugs,
Devices, Biologicals, or Medical Supplies for LMHS,
made in accordance with LMHS policies and
procedures
Disclosure of Financial Interest Policy
The Questionnaire includes the following
mitigation plan options to address potential
conflicts:
– divestiture of ownership/investment interests;
– declination of future payments or transfers for
value; or
– declination of future purchasing decisions
connected to ownership/investment interests or
payments or transfers of value.