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Reminders to ensure Conflict of Interest (COI) compliance in FY 2021

The start of a new fiscal year is a good time to review policies and procedures.

As detailed by the YNHHS Interactions with Vendors and YNHHS COI Covered Individual policies:

  • Workforce includes YNHHS employees, such as employed medical staff members, nurses, APPs, pharmacists and those with a contractual relationship that must abide by YNHHS policies and procedures, including but not limited to PSA agreements.
  • Workforce participation in:
    • industry-sponsored speaker’s bureaus is not permitted.
    • any marketing/training programs designed for sales or marketing purposes is not permitted.
    • industry-sponsored programs is only permitted IF the workforce member retains full control and authority over the meeting or lecture’s content, including slides and written materials that the YNHHS workforce member will present.
    • consultation with industry to provide scientific advice is permitted as long as all the policies requirements are met.
    • “paid surveys” or “marketing research” activities are highly suspect under the anti-kickback statute, are highly susceptible to fraud and abuse, and are therefore strictly prohibited.
  • Workforce, including students and volunteers, may not accept any gifts, regardless of value, from any vendor. Gifts include cash in any form or cash equivalents such as gift certificates.
  • Food and beverages provided or funded by vendors/industry are not allowed on-site at YNHHS.
  • The industry can get very creative with physician arrangement/contract language, which may put you at higher risk. Remember, it’s always better to over-disclose your financial interests!

When in doubt, reach out to the Office of Privacy and Corporate Compliance (OPCC) at [email protected].